How Does the UDI Rule Address Subcomponents or Accessories in Regards to the Statement that Every Medical Device Needs UDI?

Although the words “accessory” and “component” are often used as generic terms when discussing devices, they each have regulatory definitions. From a regulatory perspective, “accessories” are specific objects that work with finished medical devices and are therefore regulated devices in their own right and subject to UDI. “Components” are defined as objects that manufacturers acquire or build and then use to create medical devices. These are not put into commercial distribution. Therefore, UDI does not apply to components. UDI applies to finished medical devices and accessories that are put into commercial distribution, sold, and distributed.

USDM Life Sciences will help you assess, plan and execute the changes and enhancements necessary to meet UDI regulations. Our team of UDI experts will assess your products, the markets where they are sold and determine an implementation strategy for the changes that need to be made. USDM's assessment methodology is extensive and includes the labels and packaging, the management of identification changes to each product, the changes to PLM, ERP, EPCIS and packaging systems, changes to printing, vision inspection and warehouse/inventory management systems and interfaces to the GUDID.