DQSP-00080 Product Labelling Procedure
DQSP-00080 Product Labelling Procedure
1.0 Purpose
The purpose of this procedure is to define global regulatory and commercial requirements and
harmonized guidelines for labeling of products within Siemens Healthcare Diagnostics, including
Laboratory Solutions (LS) and Point of Care (POC). These requirements include those for In
Vitro Diagnostics (IVD), Research Use Only (RUO), Investigational Use Only (IUO), General
Purpose Reagent (GPR), and Analyte-Specific Reagent (ASR) regulatory classifications.
New requirements in this version of the procedure shall be applied to new product labeling
projects starting 90 days after this procedure is effective. Requirements in this procedure may
be incorporated into labeling revision of commercial products, but the impact of content changes
to product registration or importation must be evaluated by Quality and Regulatory functions.
2.0 Scope
This procedure applies to product labeling for products that are manufactured or distributed as
Siemens or Siemens Healthineers-branded. “Product Labeling” is defined as information
provided to end-users, either directly on a product or supplied with a product, describing
features, performance claims and specifications, storage and handling requirements, correct
product use, and product safety. Examples of product labeling include on-product marking,
instructions for use, operator guides, online help, user interface content, quick reference guides,
text and graphics for primary component, outer container/unit of sale carton, and shipping
container packaging.
Requirements for other forms of customer communication, including Service, Marketing, and
Advertising materials, are not within the scope of this procedure.
This procedure includes regulatory and corporate requirements, including the FDA Labeling
Regulations, EC-In Vitro Diagnostic Directive (IVDD), EC In Vitro Diagnostic Regulation (IVDR),
EN and ISO standards, global country regulatory requirements, and Siemens EHS, Legal,
Corporate Communications and Design requirements.
NOTE: The new requirements for IVDR need to be fulfilled after the application date on May 26,
2022, unless the prolonged transitional provision of the IVDR (latest May 26, 2024) is used for
non-changed products. However, the registration requirements need to be fulfilled starting May
26, 2022.
This document does not define country-specific regulatory or product safety requirements for
Russia, Japan, China, Taiwan, Korea, Vietnam, or Thailand. Developers shall obtain labeling
requirements directly from Quality/Regulatory functions in these countries. Many countries
require additional labeling on products for commercial importation or customs purposes with
local contact information; these requirements are not covered in this document.
This procedure does not include guidance on local language requirements for system or assay
labeling or use of electronic delivery of IFUs.
This procedure reflects use of both Siemens and Siemens Healthineers branding guidance; the
organization’s PLM function is responsible for decisions regarding a specific product’s branding.
Environment, Health Provide product safety classifications and guidelines for Environment, Health and
and Safety (EHS) the specification of Hazard, Risk and Safety information, Safety
including placement and delivery of that information to
product users.
Technical Monitor, define, and communicate new and revised Technical Regulations
Regulations and Technical Regulations and Standards (TR&S) that are and Standards
Standards relevant to product labeling content requirements. Management (TRSM-
Management Support the business through interpretation and DX)
(TRSM-DX) analysis of TR&S.
Requirements listed are preceded by the word “shall” or “will”; suggested practices are generally
preceded with the word “may”. Italicized examples in the document are guidance for the
structure of required words or phrases.
Issues that limit the complete implementation of specified labeling requirements shall be
reviewed with the appropriate Quality and Product Labeling functional management before
content deletions or modifications may be implemented.
In some cases, physical space on labeling limits the application of complete information. In such
cases, alternative specifications and formats are described in the requirements. If an alternative
specification cannot be implemented, contact appropriate Quality and Product Labeling
functional management to identify implementation options.
Each component shall be identified by name, letter, number, symbol, color, or graphics
in the same manner on all labels and in the instructions for use.
Warnings and Any storage and handling risks, Space-constrained sizing 4.3.10
Precautions including GHS Chemical Safety for symbols (refer to 4.5
Information Hazard Symbol and attachment DQSP-00080-
DQSP-00080-G1
Signal Word. G1, Symbols Glossary);
Symbols Glossary
GHS Hazard Symbol
Compliance Marking CE mark, for IVD products sold CE mark provided on 4.3.12
(if component is a in the EU; with Notified Body outer packaging and IFU
registered medical number for IVDD Annex II is acceptable
device) products and IVDR class B, C
and D products.
Specimen Type Type of specimen(s) required to Outer packaging and IFU N/A
(devices for self- perform the test (e.g. blood, acceptable.
testing only) urine, or saliva).
Additional Materials The need for additional materials Outer packaging and IFU N/A
(devices for self- for the test to function properly. acceptable.
testing only)
Contact Details Contact details for further advice Outer packaging and IFU N/A
(devices for self- and assistance. acceptable.
testing only)
Self-testing or Near “Self-Test” or “Near Patient Test” Outer packaging and IFU 4.3.13
Patient Testing symbol if the device is intended acceptable. DQSP-00080-G1
Indication (product for self-testing or near-patient Symbols Glossary
sold in EU countries testing.
only)
Exclusion for Rapid “Non Self-Test” or “Non Near Outer packaging and IFU 4.3.13
Assays (product sold Patient Test” symbol where rapid acceptable. DQSP-00080-G1
in EU countries only) assays are not intended for self- Symbols Glossary
testing or near-patient testing.
Biological Hazard “Biohazard” Symbol and warning “Biohazard” symbol alone, 4.3.11
phrase if product contains a known statement shall be in IFU. DQSP-00080-G1
biological hazard. Symbols Glossary
Additional Materials The need for additional materials If outer packaging is N/A
(devices for self-testing for the test to function properly. space constrained, IFU
only) only is acceptable.
Contact Details Contact details for further advice If outer packaging is N/A
(devices for self-testing and assistance. space constrained, IFU
only) only is acceptable.
d. Risk and Safety information (GHS) required for safe handling is provided on
product packaging or other means with the product.
Where applicable, information regarding batch to batch variation with relevant figures
and units of measure shall be provided to the customer. This information may be
included in the IFU or in another document that accompanies the IFU.
4.1.3.2 Readability
For Self-Test and CLIA-waived products, the IFU shall be written to
audiences with limited diagnostics training, and for Self-Test products,
enabling a lay user (for example, in the US, at a seventh grade reading
level) to correctly and safely perform the IVD test procedure and
understand the IVD test results.
4.1.3.3 Revisions
Changes to content from old to new versions of IFUs shall use change-
bars or other highlighting features that visually identifies new or revised
text. Alternatively, a revision information section can be added identifying
new or updated content. Change bars, highlighting or revision information
section shall be included in all language IFUs.
a. IFUs for RUO product shall include the for research use only
statement.
b. IFUs for IUO product shall include the for investigational use only
statement.
c. IFUs for PEO product shall include the for performance evaluation
only statement.
d. IFUs for devices for performance studies shall include the device
for performance study only statement.
4.1.3.12 Procedure
a. Materials Provided
b. Materials Required but Not Provided
c. Optional Materials (if applicable)
d. Procedure
e. Preparing the Reagents (for manual methods)
f. Preparing the System
g. Performing Calibration
h. Performing Quality Control
For Self-Test products, details of the test procedure shall be given,
including any reagent preparation, specimen collection and/or
preparation and information on how to run the test and interpret the
results.
4.1.3.13 Results
a. Calculation of Results
b. Interpretation of Results
4.1.3.14 Limitations
For products sold in the European Union, the name and address of the
manufacturer's EC Authorized Representative is required if the product
is CE marked and the legal manufacturer is not located within the EU.
Note: If the name and address of the EC Authorized Representative is
present on the outer packaging, they are not required to be in the
instructions for use.
Product labeling for systems and software includes on-product marking, packaging /unit
of sale carton and the Instructions for Use and other mandatory information that is
provided to customers.
The basic content requirements for the system identification/rating label are
included in the summary table below. All product identification content shall be
marked on a permanent part of the system, printed using permanent inks, label
stocks and adhesive systems from approved and compliant marking systems.
Some elements may be presented on the UDI labeling adjacent to the rating
label.
AC or DC input.
Electrical Safety
Electrical/mechanical safety Standards as
compliance marking (UL, TUV, applicable
etc.) as required.
The basic content requirements for system supplies and consumables labeling
are included in the summary table below. Examples of system consumables
include plastic disposables, such as cuvettes, reaction tubes or sealing caps.
Consumable components that are active parts of an analytical process, such as
single-use and multi-use electro-chemical sensors, shall follow the labeling
requirements found under the assay/reagent section as applicable.
As there are generally no labeling space issues with system consumables and
supplies supplied in bulk packaging, requirements have not been adjusted for
space- constraint.
The basic content requirements for the system packaging are included in the
summary table below. As there is generally no labeling space issues with system
or accessory packaging, requirements have not been adjusted for space-
constraint cases.
Date of Manufacture The date when the source code Same N/A
was completed, for IVDD
Annex II and IVDR class C or D
Standalone Medical Device
Software on outer packaging.
Instructions for Use (IFUs) are required for all IVD, consumables and
accessories. In many cases, instructions for use for consumables and supplies
are most effectively included as part of the system’s IFU.
All Instructions for Use shall be developed using a standardized sequence of
information topics, based on both regulatory and usability criteria. Determining
whether IFU content constitutes performance or usability claims is the
responsibility of the Regulatory Affairs function.
For Self-Test and CLIA-waived products, the IFU shall be written to audiences
with limited diagnostics training, and for Self-Test products, enabling a lay user
th
(for example, in US at a 7 grade reading level) to correctly and safely perform
the IVD test procedure, understand the IVD test results, and complete any
customer maintenance activity required to maintain product readiness and
performance.
The FDA has defined the following information sections for system instructions
for use that shall be provided, except where information is not applicable, or as
specified in requirements for a particular product class:
The proprietary name and common name, if any.
The model number included on the system’s UDI.
The intended use or uses of the product and the type of procedure,
e.g. qualitative or quantitative
The intended purpose
Use or function
Installation procedures and requirements
Principles of operation
Performance characteristics and specifications
Operating instructions
Calibration procedures, including equipment and/or materials
Operational precautions and limitations
Hazards
Service and maintenance information
Name and place of business of legal manufacturer
Revision code and date of issuance of revision (YYYY-MM)
4.2.6.1 Manufacturer
To include full address of Legal Manufacturer, plus Siemens
Healthineers headquarters address and internet URL:
For products sold in the European Union, the name and address of the
manufacturer's EC Authorized Representative is required if the product
is CE marked and the legal manufacturer is not located within the EU.
Note: If the name and address of the EC Authorized Representative is
present on the outer packaging, they are not required to be in the
instructions for use.
When the name does not uniquely identify the IVD instrument, an
additional means of identification shall also be given. (Example: Model
Number, Catalogue number)
The intended use and intended purpose of the IVD instrument shall be
described. Refer to section 4.3.13.
Benefits and limitations of the IVD medical device with respect to the
intended use shall be described. Medical use may be described, where
appropriate.
d) Dimensions, mass;
a) Unpacking;
4.2.6.7 Functions
For each specific IVD system function, information shall be provided on
the following:
f) Interface protocol
4.2.6.19 Maintenance
4.2.6.21 Troubleshooting
4.2.6.25 References
4.2.6.27 Unique Document identifier to control version and its use with
specific product configurations. SMN, revision code and date of
issuance of revision (YYYY-MM).
Additional Requirements for System Instructions for Use, derived from IVDR
European Requirements
Under the Regulation (EU) 2017/746 of the European Parliament and of the council
of 5 April 2017, all instrument Instructions for Use for products imported into the
European Union must contain the following additional content:
4.2.6.32 CE Marking
The “Legal Manufacturer”, if not the actual manufacturer, is the entity that has
taken legal responsibility for the product’s sale and use. If Siemens is not the
Legal Manufacturer, the Siemens or Siemens Healthineers logo shall not be used
on product labeling or related customer documents.
After the prominent use of the full company name (in document text, any
subsequent references to the company may be shortened to “Siemens” or
“Siemens Healthineers”.
Examples:
®
Clinitek Microalbumin 9 (proprietary product name)
Reagent Strips for Urinalysis (descriptive phrase to be translated)
or
MultiCap (proprietary product name)
Blood collection capillary tubes (descriptive phrase to be translated)
Both trademark and copyright notices should appear on all product labeling
documents that are published externally.
Contact the Intellectual Property (IP) group to determine the strategy, use and
restrictions for product trademarks.
The Trademark notice must also appear as below for documents authored and
produced within the USA:
“(trademark A), (trademark B) and (trademark C) are trademarks of (Legal
Entity).
If third-party trademarks are used as part of the product or in product labeling,
the statement “All other trademarks and brands are the property of their
respective owners.” shall be included.
To determine trademark requirements of OEM-sourced or co-branded products,
contact the IP department for any contractual agreements or restrictions in use.
®
Do not use the ™ or with another company’s product name without first
contacting the IP group.
Copyright Notice
The copyright notice shall appear on all product manuals, instructions for use and
related technical documents distributed to customers. The copyright notice shall
appear as below:
© YYYY (Legal Entity). All rights reserved
Patent Marking
Patent Marking is the application of patent numbers (a) directly to products that
contain or incorporate patented features or aspects, or (b) indirectly to product
labeling, packaging or associated materials.
Tag or label that is directly applied to the product (e.g., with an adhesive)
Immediate container for the product
Other product packaging, product insert documentation, operator manual,
or documentation sold with and accompanying the product at sale.
Applicable patent URL displayed on packaging and instructions for use.
Format Example:
US Pat 4,745,181 (Single patent)
US Pats 4,745,181; 4,918,192; D341,779 (Multiple patents)
Both the patent numbers and the application instructions are provided by the
IP Department.
All product labeling shall clearly identify the Legal Manufacturer by its full name
and address.
In addition to the address, the Siemens Healthineers URL shall be included for all
products
If the product is CE marked and the Legal Manufacturer is located outside of the
European Union, the EC Authorized Representative name and address shall be
included adjacent the Legal Manufacturer address block on outer container/unit
of sale labeling and/or IFUs.
The Batch/Lot number provided on the outer container shall be specific enough
to enable product history to be traced to individual components and production
processes in the manufacturer’s production file. For multi -component kits or bulk
packaging, there is no regulatory requirement to print individual Batch/Lot codes
on the outer package for all contained components. For lot marking of duplicated
software media, if there is no established lot code, it is recommended to use
numeric week/year of manufacture, in the format WWYYYY.
All product components and unit-of-sale kits that have a defined use life shall
have a “use by” or “expiration” date on labeling, preceded by the “Expiration”
symbol (See Symbols Glossary). The date may be printed in one of four formats:
YYYY-MM (Year-Month): Expiration is assumed to be the last day of that month
YYYY-MM-DD (Year-Month-Day)
A legend “YYYY-MM-DD” printed near the date code is a useful tool for making
month/day order clear, due to regional conventions for month/day order. This is a
good practice but not a requirement.
The Expiration date printed on the outer container of components shall be the
date of the component having the earliest expiration date, or earlier if appropriate
to product use. There is no regulatory requirement to print expiration dates for
individual components on the outer unit-of-sale package.
For products that do not have a stated expiration date or use life, the date of
manufacture (YYYY-MM) shall be provided on the sales/kit packaging, marked
with the “Date of Manufacture” symbol. Alternatively, the date may be included as
part of the batch/lot code or serial number, provided the date portion is clearly
identifiable.
i.
Storage Temperature
+2°C to +8°C
+15°C to +25°C
All symbols shall be explained in the reagent IFU and/or system manual.
Chemical Risk and Safety classification and customer information is defined for a
reagent or consumable product by the EHS function. This information is aligned
to the chemical Safety Data Sheet developed and controlled by EHS. Risk
Management procedures are also used during the product lifecycle to identify
other potential material hazards.
For Sales/Kit Packaging, each symbol shall measure 1.4 cm across corners.
Example:
If the product is not accompanied by instructions for use, the warning symbol(s),
signal word, H+P statements, and supplemental labeling shall either be included
on the label of the outer/unit-of-sale container or on another document supplied
with the product, translated into the languages appropriate for the market.
Guidance on the application GHS Hazard symbol, minimum and nominal sizing
and printing constraints is contained in Symbols Glossary.
For product containing known biological hazards, the Biohazard symbol (see
Symbols Glossary) shall be printed on the component and outer container/unit of
sale labeling.
Animal Source
4.3.12 CE Marking
All IVD products sold in the European Community shall either be self-certified by
the manufacturer or registered by a Notified Body.
Many IVD products must be registered in the EC prior to sale. If a product has
been registered and approved for sale by a Notified Body, the Notified Body’s
agency number (a four-digit numeric) is placed adjacent or below the CE mark.
The CE mark shall be applied to the registered medical device and it’s IFU. In the
case of IVD kits containing multiple components, the ‘medical device’ is the kit
itself, and the CE mark shall be applied to the kit’s outer/unit-of-sale packaging
and its IFU.
For assay and reagent products, the Intended Use statement is required on outer
packaging and IFUs. For Instruments and IVD Software, this information is
required in operating documentation supplied with the product.
For product sales / outer packaging, the Intended Use statement shall include
these elements:
IVD or other supported regulatory classification
Specific Analyte
If an automated test, the system that the reagent is used with to complete
sample analysis (such as ADVIA Centaur Systems)
This statement may be provided in English only on the outer container to meet
US requirements, as the full Intended Use statement is provided in the IFU
“Caution: Federal (USA) law restricts this device to sale by or on the order of a
licensed healthcare professional.”
The RXOnly symbol or statement on the kit or IFU shall be clearly indicated as a
US- only requirement and it may be positioned within a designated “For US/CA”
content area of the package.
For assay and reagent products, the Intended Purpose is required in the
instructions for use. For product IFUs the Intended Purpose is comprised of
these elements. The elements of the intended purpose do not necessarily have
to be together in the IFUs.
Automated or not
Testing population
Type of specimen
For assay and reagent products, the Intended Purpose is required on product
packaging unless the “IVD” symbol and product name are on the packaging.
For Self-Test products, a statement that the product is intended for self-
testing shall be provided. For IVDR CE marked Near-Patient Test products, a
statement that the product is intended for near-patient testing shall be
required. For IVDR CE marked products, self-test and near-patient test
symbols may be used on the packaging in place of text.
For IVDR CE marked product, rapid tests which are not intended for self-
testing or near-patient testing shall indicate this. “Not intended for self-testing”
and “Not intended for near-patient testing” symbols may be used on the
packaging in place of text.
If the intended use is not indicated by the name of the IVD reagent, then an
abbreviated intended use statement shall be given on the product or included in
the instructions for use in terminology and local language suitable for a lay
person (Example: Pregnancy Test). Medical use and limitations of use shall be
described where appropriate and written for lay audience. (Example: Self-testing
of cholesterol, suitable for the demonstration of an elevated cholesterol but not
for its monitoring)
IVD For in vitro diagnostic use, with conditions above. For packaging, use with
either “IVD” symbol or translate IVD statement in all supported EC languages
For Self-Test products, The in vitro diagnostic use of the reagent shall be
indicated in terminology and local language suitable for a lay person
(Example: Only for use outside the body.)
IUO (USA) For Investigational Use Only. The performance characteristics of this
product have not been established . (prominently placed)
PEO For Performance Evaluation Only (in local language or with “IVD
(equivalent to Performance Evaluation Only” symbol)
IUO for EC Device for Performance Study
countries)
RUO For Research Use Only. Not for use in diagnostic procedures. (in local
language)
GPR No special statement for use, but no performance claims are included with
product or IFU
Intended Use statement for a primary IVD reagent product may follow the structure in this
example:
For in vitro diagnostic use in the (test type) determination of (analyte) in (sample type) using the
(name of system). For Professional Use.
For a calibrator product, the structure of the Intended Use statement may follow this
example:
For in vitro diagnostic use in the calibration of (analytical test) using the (name of system). For
Near Patient Testing and Professional Use.
For a quality control product, the structure of the Intended Use statement May follow this
example:
For in vitro diagnostic use to monitor the (precision and the accuracy) of (analytical test)
procedures using the (name of system). For Professional Use.
For an IVD reagent product or consumable that is part of an analytical procedure, and does
not produce a diagnostic result directly, (such as diluent, plastic disposable or wash
solution), the Intended Use statement should follow this example:
For in vitro diagnostic use with the (name of system)
In all cases, for professional-use IVD reagent products sold in the Americas region and in
the EC, this statement may be provided in English only on the carton, if used with the ‘IVD’
symbol and ‘Consult Instructions for Use’ symbol. Translated intended use statements are
required in the product IFU.
Performance Evaluation Only, Device for Performance Study and Investigational Use Only
products distributed in the EC and US shall include the appropriate statement above in
English, and the appropriate symbol.
For Self-Test IVD products, the Intended Use statement shall contain the same elements as
above but be provided in terminology and language suitable for a lay person. For example,
For in vitro diagnostic use could be expressed as Only for use outside the body.
The fact that the IVD reagent is intended for self-testing shall be clearly stated on the
sales/outer carton and IFU.
For assay unit of sale packaging, a contents description is required. This shall be
contained in a “For CA” area of packaging, and this information may be in
English only.
Component and kit labeling shall be in English, Instructions for Use must be
supplied in both English and French.
in Canada and a Test Kit (TK) number assigned for each product configuration.
The format for this number is T.K. 00-00.
The product sales/outer packaging shall include the TK number; if the TK number
is not available at the time of printing for product release, space should be
allocated on the package for imprinting the number in future.
The FDA and EU have defined a subset of graphical symbols that do not strictly require
a glossary definition, but developers should consider usability and risk in any decision to
delete these definitions in the product’s Symbol s Glossary.
Any symbol or identification color used shall conform to the harmonized standards. In
areas for which no harmonized standards exist, the symbols and color usage shall be
described in the Instructions for Use.
Certain descriptive names for reagents and consumables may be replaced with
component symbols, satisfying the needs for translated terms in many markets.
The symbol meanings are provided to customers via the Symbols Glossary on in
the body text of the product IFU or manual. The construction of these symbols
has been based on CE-Norm symbols in use.
For product lines utilizing electronic delivery of IFUs, an “eIFU Indicator” shall be
provided on product sales/kit packaging, including access URL for downloading
the IFU and indication of the correct IFU version to use with the product.
These statements shall be provided clearly, completely, and legibly in the product
labeling. Product safety warning instances and classifications may be distinct from
chemical safety warnings defined by GHS.
Warning statements indicate the risk of personal injury or loss of life if operating
procedures and practices are not strictly observed.
According to the FDA definition, a warning alerts the reader about a situation
which, if not avoided, could result in death or serious injury. It may also describe
potential serious adverse reactions and safety hazards in normal use or under
foreseeable misuse.
The term “WARNING” is used as the signal word for this type of hazard alert and
regulatory agencies may expect that this warning is emphasized by placing it
within a ruled outline or highlighted box.
The term “WARNING” and associated information is translated in the IFU in local
languages.
The word “CAUTION” is used as the signal word for a precaution statement. The
distinction between warnings and precautions is a matter of degree of likelihood
and seriousness of the hazard.
The term “CAUTION” and associated information are translated in the IFU in
local languages
5.0 Terms
The definitions for these words can be found in the Diagnostics Glossary of Terms App or in
DQSP-00021-A2 Diagnostics Glossary of Terms and Glossary Guidance.
1. Accessory
2. Analyte-Specific Reagent (ASR)
3. Component
4. General Purpose Reagent (GPR)
5. Instructions for Use (IFU)
6. In vitro Diagnostic (IVD) Medical Device
7. Investigational Use Only (IUO)
8. Kit
9. Label
10. Medical Device
11. Outer Container (sales packaging)
12. Product Code
13. Product Labeling
14. Professional Use
15. Research Use Only (RUO)
16. Self-Testing
17. SMN
6.0 Appendices
None