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China Regulatory

IMPLEMENTATION OF UDI


 
REGULATORY AGENCY National Medical Products Administration (NMPA)
REGULATION NAME Implementation of UDI
COMPLIANCE DATES High risk class III (active and passive implants): 1 January 2021 Rest Class III: 1st June 2022 Class II: 1st August 2024 The rest: 1st August 2026
APPLIES TO These devices shall be assigned a UDI and their related data shall be uploaded into the UDI database before they are put on the market for sale. The production date shall be used to confirm whether the device must have a UDI or not, not matter the device is a newly licensed item or not.

PRIMARY PACKAGING

(Packaging which is in direct physical contact with the active ingredient)
 
BARCODE SYMBOLOGY GS1 DataMatrix (inter alia, ID/linear bar code, 2D/Matrix bar code, RFID)
BARCODE CONTENTS
  • GTIN(AI 01)
  • Serial number(AI 21)
  • Batch number(AI 10)
  • Expiry date(AI 17)

blank

SERIAL NUMBER RANDOMIZATION NA
SERIAL NUMBER REUSE

No

HUMAN READABLE EXPIRY DATE FORMAT

YYMMDD

BARCODE DATA ENCODING

UDI – DI

PRODUCT CODE NOTES
  • Higher levels of packaging shall have their own unique UDI.
  • The UDI must appear in a plain-text version/human readable information (HRI) and in a form that uses AIDC technology.
FREE SAMPLES MUST BE MARKED?

Not Specified

SECONDARY PACKAGING

(A carton containing one or more primary packs and includes a “mono carton” containing one primary pack)
 
BARCODE SYMBOLOGY GS1 DataMatrix (inter alia, ID/linear bar code, 2D/Matrix bar code, RFID)
BARCODE CONTENTS
  • GTIN(AI 01)
  • Serial number(AI 21)
  • Batch number(AI 10)
  • Expiry date(AI 17)

blank

SERIAL NUMBER RANDOMIZATION NA
SERIAL NUMBER REUSE

No

HUMAN READABLE EXPIRY DATE FORMAT

YYMMDD

BARCODE DATA ENCODING

UDI – DI

PRODUCT CODE NOTES

FREE SAMPLES MUST BE MARKED?

No

TERTIARY PACKAGING

(A shipper containing one or more secondary packs)
 
BARCODE   SYMBOLOGY SSCC blank
BARCODE CONTENTS GS1-128 (SSCC)

AGGREGATION DATA CAPTURE


 
PARENT-CHILD MAPPING AGGREGATION CAPTURE?
Yes

DATA EXCHANGE


 
SEND UNIT DATA TO GOVERNMENT REPOSITORY? Yes (NMPA UDI information management system)
SEND UNIT DATA TO THIRD-PARTY REPOSITORY?

Not Specified

SEND UNIT DATA TO TRADING PARTNER?

Not Specified

SEND AGGREGATION DATA TO GOVERNMENT REPOSITORY? Yes
SEND AGGREGATION DATA TO THIRD-PARTY REPOSITORY?

Not Specified

SEND AGGREGATION DATA TO TRADING PARTNER?

Not Specified

AUTHENTICATION


 
WHO OFFERS DATA REPOSITORY FOR AUTHENTICATION? NMPA
MANUFACTURERS MUST REGISTER SHIPMENTS IN REPOSITORY?

Yes (Import & Exports)

DOWNSTREAM TRADING PARTNERS MUST AUTHENTICATE ON RECEIPT?

Yes

DOWNSTREAM TRADING PARTNERS MUST AUTHENTICATE ON SHIPMENT? Yes

GOVERNMENT REPORTING


 
MANUFACTURER ACTIVITY REPORTED? Yes
DOWNSTREAM TRADING PARTNER ACTIVITY REPORTED?

Yes

CHINA NATIONAL MEDICAL PRODUCTS ADMINISTRATION (NMPA)


 
REGULATORY AGENCY China National Medical Products Administration (NMPA)
REGULATION NAME Guidelines for drug traceability information system construction
COMPLIANCE DATES Both standards "Guidelines for drug traceability information system construction" and "Encoding requirements for drug traceability" have to be implemented from the date of publication (April 2019) The deadline for achieving traceability of the key products is 31st December 2020.
APPLIES TO Marketing authorization holders, drug manufacturers, pharmaceutical operating units to establish the drug traceability systems and drug supervision and management departments of supervision and inspection. It does NOT apply to the production and operation of Chinese herbal medicines, raw materials and special packaging preparations

SECONDARY PACKAGING

(A carton containing one or more primary packs and includes a “mono carton” containing one primary pack)
 
BARCODE SYMBOLOGY linear/2D barcode, RFID, and HRI
BARCODE CONTENTS Structure of the drug traceability code: drug identification code + production identification code + check digit
Drug identification code should be unique at each packaging level, and production identification code should include serial number, and can include lot number, production date, expiry date based on actual needs. Currently two coding system are still issued in China:
  • GS1 standards using a GTIN as product code with the relevant AIs and encoded in a DataMatrix
  • AliHealth eCode:a 20 digits code (7 digits product ID + 9 digits serial number + 4 digits check digits) assigned by AliHealth and encoded in a 128 barcode.
 
SERIAL NUMBER RANDOMIZATION NA
SERIAL NUMBER REUSE

No

HUMAN READABLE EXPIRY DATE FORMAT

YYMMDD

BARCODE DATA ENCODING

GS1 standard

PRODUCT CODE NOTES

Drug identification code should be unique at each packaging level, and production identification code should include serial number, and can include lot number, production date, expiry date based on actual needs.

FREE SAMPLES MUST BE MARKED?

No

TERTIARY PACKAGING

(A shipper containing one or more secondary packs)
 
BARCODE   SYMBOLOGY SSCC blank
BARCODE CONTENTS GS1-128 (SSCC)

AGGREGATION DATA CAPTURE


 
PARENT-CHILD MAPPING AGGREGATION CAPTURE?
No

DATA EXCHANGE


 
SEND UNIT DATA TO GOVERNMENT REPOSITORY? Proposed
SEND UNIT DATA TO THIRD-PARTY REPOSITORY?

Not Specified

SEND UNIT DATA TO TRADING PARTNER?

Not Specified

SEND AGGREGATION DATA TO GOVERNMENT REPOSITORY? Yes (Through Ali-Health)
SEND AGGREGATION DATA TO THIRD-PARTY REPOSITORY?

Not Specified

SEND AGGREGATION DATA TO TRADING PARTNER?

Not Specified

AUTHENTICATION


 
WHO OFFERS DATA REPOSITORY FOR AUTHENTICATION? NMPA
MANUFACTURERS MUST REGISTER SHIPMENTS IN REPOSITORY?

Proposed (Import & Exports)

DOWNSTREAM TRADING PARTNERS MUST AUTHENTICATE ON RECEIPT?

No Specified

DOWNSTREAM TRADING PARTNERS MUST AUTHENTICATE ON SHIPMENT? No Specified

GOVERNMENT REPORTING


 
MANUFACTURER ACTIVITY REPORTED? Yes (Proposed)
DOWNSTREAM TRADING PARTNER ACTIVITY REPORTED?

No Specified

Source and Credit: This information is fully or partly based on the GS1 master document (all rights reserved). As GS1 does not control the content of the information, GS1 shall not be held liable, under any circumstance, if it differs from the master document.

DISCLAIMER

This information is being provided ‘As Is’ with no claims of suitability for a particular purpose. It represents just a possible interpretation of information available in the public domain and that interpretation is subject to change. This information does not constitute legal advice.

ABOUT KEVISION SYSTEMS

Kevision Systems, a part of the Kevin Group, is a leading solutions provider for complete end to end inspection of products & services for the inspection of pharmaceutical products like tablets, capsules and more. In addition to the inspection systems, Kevision’s Track & Trace Software & related equipment provide a fully integrated solution to the traceability of pharmaceutical products & Supply Chain Integrity.

Built on the cornerstone of strong quality focus, we deliver excellent solutions with very high quality & reliability.

Kevision Systems is dedicated and driven to provide the finest & the most optimum solutions for the Supply Chain Integrity as well as Optical Inspection Systems. We stand strong on the pillars of integrity, professionalism, innovation and expertise and have earned the credibility to work with any size of projects. We strive to excel in terms of quality and technology and be a preferred partner for our valued clientele.

For Further Information, please contact our Compliance Team at info@kevision.in

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