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Common Compliance Issues on Expiration Dating and Packaging Control

Updated: Feb 16


To ensure the quality, potency, and safety of pharmaceutical products, regulatory bodies like the Food and Drug Administration (FDA) in the United States have established stringent guidelines and regulations. Title 21, Chapter I of the Code of Federal Regulations, overseen by the FDA under the Department of Health and Human Services, is a cornerstone of these regulations. The pharmaceutical industry plays a vital role in promoting public health and well-being by developing and manufacturing safe and effective drugs.   This Regulation focuses on Current Good Manufacturing Practice (cGMP) for Finished Pharmaceuticals. Subpart G of this regulation addresses the critical aspects of packaging and labeling control, with a specific emphasis on expiration dating. The expiration date serves as a crucial indicator of a drug's potency, efficacy, and safety, ensuring that it meets applicable standards of identity, strength, quality, and purity at the time of use.


To ensure the quality, potency, and safety of pharmaceutical products, regulatory bodies like the Food and Drug Administration (FDA) in the United States have established stringent guidelines and regulations. Title 21, Chapter I of the Code of Federal Regulations, overseen by the FDA under the Department of Health and Human Services, is a cornerstone of these regulations. The pharmaceutical industry plays a vital role in promoting public health and well-being by developing and manufacturing safe and effective drugs.


This Regulation focuses on Current Good Manufacturing Practice (cGMP) for Finished Pharmaceuticals. Subpart G of this regulation addresses the critical aspects of packaging and labeling control, with a specific emphasis on expiration dating. The expiration date serves as a crucial indicator of a drug's potency, efficacy, and safety, ensuring that it meets applicable standards of identity, strength, quality, and purity at the time of use.


This comprehensive guide aims to provide pharmaceutical manufacturers, regulatory professionals, and stakeholders with a deeper understanding of the provisions outlined in Title 21, Chapter I, Subpart G, while shedding light on the most common compliance issues encountered in relation to expiration dating and packaging control. By adhering to these regulations, manufacturers can uphold the highest standards of product quality, protect patient safety, and maintain regulatory compliance.


Expiration Dating and Its Significance

Sec. 211.137 of Part 211 establishes the requirement for expiration dating on drug product labels. The expiration date plays a vital role in ensuring a drug's potency, efficacy, and safety by guaranteeing that it meets the applicable standards of identity, strength, quality, and purity at the time of use. To determine an appropriate expiration date, manufacturers are required to conduct stability testing, as described in § 211.166.


Storage Conditions and Labeling

In order to provide accurate and reliable information to healthcare professionals and patients, expiration dates must be directly related to any specified storage conditions stated on the drug product labeling. Manufacturers must conduct stability studies, outlined in § 211.166, to establish the correlation between storage conditions and expiration dates. This ensures that drugs maintain their quality and efficacy throughout their shelf life, thereby promoting safe and effective patient use.


Reconstitution and Labeling

In cases where a drug product requires reconstitution before dispensing, the labeling must include expiration information for both the reconstituted and unreconstituted drug products. This requirement ensures that healthcare professionals are properly informed about the stability and viability of the reconstituted product, enabling them to make informed decisions regarding patient care.


Exemptions and Considerations

The regulation provides specific exemptions and considerations for certain drug products. Homeopathic drug products, as stated in § 211.137(e), are exempt from the expiration dating requirements. Similarly, allergenic extracts labeled as "No U.S. Standard of Potency" are also exempt, as per § 211.137(f).


New drug products for investigational use, as outlined in § 211.137(g), are exempt from expiration dating requirements if they meet appropriate standards or specifications demonstrated through stability studies during clinical investigations. However, if reconstitution is necessary, the labeling should provide expiration information for the reconstituted drug product.


Furthermore, the regulation acknowledges the potential for a proposed exemption, as published in the Federal Register on September 29, 1978, for human over-the-counter (OTC) drug products. The requirements in § 211.137(h) are not enforced for these OTC drug products if their labeling does not bear dosage limitations and they demonstrate stability for at least three years, supported by appropriate stability data.


Common Compliance Issues


While Title 21, Chapter I provides clear guidelines, compliance issues may still arise regarding expiration dating and packaging control. Pharmaceutical manufacturers commonly encounter the following challenges:

  1. Inaccurate expiration dating: Failure to conduct appropriate stability testing and establish accurate expiration dates for drug products may result in the distribution of expired or ineffective medications, jeopardizing patient safety.

  2. Inconsistent labeling: Inadequate or inconsistent inclusion of expiration information on drug product labels, particularly regarding reconstituted products, can lead to confusion among healthcare professionals and compromise patient care.

  3. Lack of storage condition correlation: Failure to establish a direct correlation between storage conditions and expiration dates may result in drugs being stored or dispensed under inappropriate conditions, leading to degradation and diminished efficacy.

  4. Insufficient stability data: Inadequate stability data to support the claimed shelf life of drug products can lead to non-compliance with the regulations and pose potential risks to patient health.

Compliance with Title 21, Chapter I is of utmost importance for pharmaceutical manufacturers to ensure the quality, potency, and safety of finished pharmaceuticals. Adhering to the regulations regarding expiration dating and packaging control is essential in meeting applicable standards, maintaining drug product integrity, and safeguarding patient well-being. By conducting proper stability testing, correlating storage conditions, and accurately labeling drug products, manufacturers can uphold cGMP and contribute to the overall safety and efficacy of pharmaceuticals available on the market. Adherence to these regulations is crucial for fostering trust in the pharmaceutical industry and ensuring optimal patient outcomes.


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