Unique Device Identification (UDI) is an alphanumeric code that marks and identifies medical devices.
These codes are created by manufacturers who follow internationally recognised standards and rules for device identification.
UDI provides a system for tracking and tracing medical devices. It also serves as an identifier in administrative processes, some of which are listed below.
- Purchase orders
- Invoice generation
- Inventory management
- Compliance reporting
- Warranty claims
- Recall management
- Supply chain logistics
This article will explain the structure of UDI and how it is displayed on medical devices. We will also discuss who issues UDIs, where they are published, and the benefits they offer. Additionally, we will compare UDI with UDID to clear up confusion and outline the requirements for UDI in the USA, Australia, and New Zealand.
Structure of a UDI
A UDI consists of two main components: the Device Identifier (DI) and the Production Identifier (PI).
Device Identifier (DI)
The Device Identifier is a mandatory, fixed portion of a UDI. It uniquely identifies a device’s specific version, model, and the labeller (manufacturer or entity responsible for the device.)
Production Identifier (PI)
The Production Identifier is a conditional, variable portion of a UDI. It includes production-related information about the device, such as.
- Lot or batch number
- Serial number
- SKU
- Manufacturing date
- Expiration date
- Identification code for human cell, tissue, or cellular and tissue-based product (HCT/P)
The PI is vital for tracking detailed production information. This information is essential for managing recalls, inventory control, and quality assurance.
How is a UDI Displayed?
UDI codes are displayed on product and package labels and, in some cases, directly on the device itself.
UDI can be presented in two main methods:
- Human-readable Format
- Machine-readable format uses automatic identification and data capture (AIDC) technology.
Reusable and reprocessed devices, such as surgical scalpels, endoscopes, and surgical forceps, require direct marking because product packaging is often discarded before.
Laser itching or similar techniques are used to apply the UDI number for such devices.
Human-Readable Interpretation
The human-readable format is the UDI code in alphanumeric text. This format must include both the Device Identifier and the Production Identifier.
The text can be displayed as a single line or multiple lines. It should be positioned near the UDI’s AIDC (Automatic Identification and Data Capture) version.
Machine-Readable Format
The machine-readable format uses AIDC technology to encode the UDI in a format that can be scanned and entered into computer systems automatically.
This format includes one-dimensional barcodes, two-dimensional barcodes, and RFID tags, which barcode scanners and other AIDC devices can read.
Ideally, the AIDC form of the UDI should be displayed in a single segment. However, it can be split into multiple segments if necessary. For example, the UDI might be presented in a linear and two-dimensional barcode: one for the DI and another for the PI segments.
Labellers can also opt to use multiple types of AIDC technology on a single device label, package, or device to accommodate users who employ different methods of UDI capture.
The quality of printed barcodes must adhere to the following standards and technical references:
- ISO/IEC 15416: Bar code print quality test specification for linear symbols
- ISO/IEC 15415: Bar code symbol print quality test specification for two-dimensional symbols
- ISO/IEC TR 29158: Direct Part Mark (DPM) Quality Guideline for automatic identification and data capture techniques.
Note – It must be explicitly indicated if the AIDC technology used to convey the UDI is not visible upon visual inspection of the device label or packaging. This disclosure ensures that users are aware of the presence of AIDC technology, even if it is not immediately apparent. Some cases where the UDI is not visible are as follows: Barcodes Printed in UV Ink: Surgical sutures may have their barcodes printed in UV ink on the packaging, requiring UV light to be visible. Laser-Etched Codes on Transparent Surfaces: IV fluid bags sometimes use laser-etched barcodes on the transparent bag material, which can be difficult to see without proper lighting. |
Who Issues a UDI?
The issuance of a UDI device identifier is managed by accredited organisations that follow international standards. These organisations ensure that the UDIs are unique, consistent, and compliant with regulatory requirements.
Each health authority may create its custom list of approved organisations. Here are the primary entities responsible for issuing UDIs:
- GS1 – GS1 is a nonprofit global organisation that develops and maintains standards for supply and demand chains across multiple sectors, including healthcare. GS1 issues UDIs that comply with international standards, ensuring medical devices are easily identifiable and traceable across the international supply chain. They use standards such as the Global Trade Item Number (GTIN) for device identification and provide GS1-128 linear barcodes and GS1 data matrix code standards for encoding UDIs.
- HIBCC – The Health Industry Business Communications Council (HIBCC) is an industry-supported nonprofit organisation that develops standards for healthcare data exchange. HIBCC provides UDIs through its Labeler Identification Code (LIC) system, which supports the unique identification of medical devices. HIBCC uses the Health Industry Bar Code (HIBC) standard for UDI encoding.
- ICCBBA – The International Council for Commonality in Blood Banking Automation (ICCBBA) is an international nonprofit organisation managing the ISBT 128 barcode standard. This barcode standard is used globally for the identification, labelling, and information transfer of medical products of human origin. ICCBBA issues UDIs for these products, ensuring accurate identification and traceability.
Where Are UDIs Published?
UDIs are published in centralised databases that act as information repositories. These databases help regulatory bodies, healthcare professionals, and manufacturers track and trace medical devices efficiently throughout their lifecycle.
Once a UDI is established, the data must be stored securely in the manufacturer’s repository. It is then submitted to the respective health authority’s Unique Device Identification Database (UDID) before the device enters the market.
Each country’s health authority maintains its own centralised database. These databases provide a searchable, public-facing index for devices within their respective markets.
Here are some examples.
- United States: The Food and Drug Administration (FDA) manages the Global Unique Device Identification Database (GUDID).
- European Union: The European Database on Medical Devices (EUDAMED) is the central repository for UDI information.
- Australia: The Australian UDI Database (AusUDID) is the repository for UDI information.
- New Zealand: Medsafe, under the Ministry of Health, is the UDI regulator in New Zealand. All medical devices must be registered in the Web-Assisted Notification of Devices (WAND) database within 30 days of commercialisation. At the time of writing this article, New Zealand did not have a centralised UDI repository equivalent to those in the United States (GUDID), European Union (EUDAMED), or Australia (AusUDID).
UDI vs UDID - Are They the Same?
Unique Device Identification and Unique Device Identifier Database are related but serve different purposes.
UDI is a unique code assigned to medical devices, ensuring each device can be distinctly identified throughout its lifecycle. For example, a pacemaker will have a UDI that includes a Device Identifier for the model and a Production Identifier for production details like the serial number and manufacturing date.
On the other hand, UDID is the database where these UDI codes and related information are stored and managed. For instance, the GUDID in the United States would store detailed information about the pacemaker, including its UDI, regulatory status, and production details.
Benefits of UDI
Improved Traceability
UDI enhances traceability by providing a unique identifier for each medical device. This identifier allows for precise tracking throughout the supply chain, from manufacturing to distribution to the end user.
The PIP breast implant recall highlighted the importance of the UDI system. These implants, containing industrial-grade silicone, required the identification of 47,000 UK women who had received them. The implants did not have UDI, which made the process difficult and time-consuming. |
Improve Patient Safety
Enhanced patient safety is one of the primary benefits of UDI implementation.
With a unique identifier, healthcare providers can quickly identify devices subject to recalls or safety alerts. This rapid identification allows for the swift removal of potentially harmful devices from use, reducing the risk to patients.
FDA’s UDI system helped streamline the recall process during the 2020 recall of certain models of Medtronic’s MiniMed insulin pumps, which were found to have cybersecurity vulnerabilities. |
Better Inventory Management
UDIs contribute to better inventory management by providing accurate and real-time information about medical devices.
Healthcare facilities can maintain precise device quantities, locations, and usage records. This accuracy reduces the risk of stockouts or overstocking and ensures that the right devices are available when needed.
Geisinger Health improved inventory efficiency by implementing a UDI-based inventory management system. The integration eliminated manual tracking processes, reduced human errors, and ensured precise inventory levels. This reduced over-ordering and product expirations and streamlined the tracking of approximately SKUs across their facilities. |
Improved Postmarket Surveillance
UDIs enable the collection of detailed data on device usage and outcomes, facilitating better analysis and reporting. This data helps identify trends and potential issues early, supporting proactive measures to address problems and improve device quality over time.
Ensured Regulatory Compliance
UDIs help manufacturers and healthcare providers meet national and international regulatory requirements. By maintaining accurate records of device identifiers, companies can demonstrate compliance during inspections and audits.
UDIs also simplify the reporting process to regulatory authorities, making it easier to submit required information and maintain up-to-date records.
Efficient Recalls and Safety Alerts
UDIs play a crucial role in making recalls and safety alerts more efficient.
When a device is found to be defective or harmful, the UDI allows for precise identification and swift action. Manufacturers can quickly notify all stakeholders, including healthcare providers and patients, about the recall.
This targeted approach ensures that affected devices are promptly removed from circulation, reducing the risk of harm and maintaining trust in the healthcare system.
Global Standardisation
UDIs provide a consistent method for identifying medical devices across different regions and systems. This standardisation facilitates international trade and regulatory harmonisation, making it easier for manufacturers to comply with diverse regulations.
It also ensures that healthcare providers worldwide can access accurate and consistent information about medical devices, improving patient care and safety.
United States UDI Rules
The FDA has established detailed requirements for the Unique Device Identification system to enhance the traceability and safety of medical devices in the USA. Here are the key elements of the FDA’s UDI requirements.
UDI Composition
The UDI consists of two main components.
- Device Identifier
- Production Identifier
Additionally, device labellers must present dates such as manufacturing and expiration dates on device labels and packages in a standard format that aligns with international standards, specifically YYYY-MM-DD.
UDI Placement Requirements
- Device Labels and Packages: The UDI must be included on device labels and packages, except where exceptions or alternatives are provided.
- Direct Marking on Devices: If a device is intended for more than one use and is reprocessed before each use, the UDI must be directly marked on the device itself.
Labelling Requirements
- Human-Readable Format: The UDI must be presented in plain text on the device label and packaging.
- Machine-Readable Format: The UDI must be included in a machine-readable format, such as a barcode or RFID tag, to facilitate automated data capture.
Submission to GUDID
Manufacturers must submit UDI information to the Global Unique Device Identification Database (GUDID), which the FDA maintains and manages. This submission should include details about the device’s DI, PI, and other relevant information.
Compliance Dates
The FDA has established a phased implementation schedule for UDI requirements based on the device’s risk class. Higher-risk devices (Class III) have earlier compliance dates, while lower-risk devices (Class I) have later deadlines.
Exceptions and Alternatives
The FDA allows for certain exceptions and alternatives to the standard UDI requirements. These include.
- Field devices
- Research devices
- Custom devices
- Investigation devices
- Veterinary medical devices
- Export medical devices
- Combo products or convenience kit products
- Bulk single-use devices
- Rx spectacle lens (HQG)
Australia Requirements for UDI
The Therapeutic Goods Administration (TGA) has established specific guidelines for Unique Device Identification. Here are the key elements of Australia’s UDI requirements.
UDI Composition
The UDI consists of two main components.
- Device Identifier (DI)
- Production Identifier (PI)
Labelling Requirements
- Human-Readable Format (HRF): A legible interpretation of the data characters encoded in the UDI carrier should be presented next to or below the AIDC carrier.
- Machine-Readable Format (MRF): UDI must use AIDC technology to encode the codes. If space constraints prevent using both AIDC and HRF on the label, the AIDC format shall be preferred. If RFID technology is used, it must comply with ISO 17366:2013 international standards.
UDI Placement Requirements
- Device Labels and Packages: The UDI must be included on device labels and packages.
- Higher Levels of Packaging: A UDI must be present on all higher levels of device packaging, excluding shipping containers. Each packaging level containing a fixed quantity of devices must have a unique UDI-DI. For example, a primary package with a single device, a secondary package with 30 primary packages, and a tertiary package with five secondary packages all need their unique UDI-DI.
UDI Direct Marking Requirements
If a device is intended for more than one use and reprocessed between uses, the UDI must be directly marked on it. The manufacturer determines the direct marking method, but it must withstand normal usage and cleaning procedures for the device’s lifetime.
If there is insufficient space for AIDC and HRI carriers, the manufacturer shall decide which carrier to mark based on the best method for the expected end-use.
Direct marking exemptions apply for the following.
- Devices reprocessed between uses on the same patient
- Implantable devices
- If marking interferes with the device’s safety, performance, or effectiveness
- If it is not technically feasible to mark the device
Devices to Meet UDI Requirements
Unless exempt, medical and in vitro diagnostic (IVD) devices must comply with UDI requirements. Compliance is based on device classification.
- Medical Device Classes: Class III, Class IIb, Class IIa, Class Is (supplied sterile)
- IVD Classes: Class 4, Class 3, Class 2, Class 1 (Instrument/analyser, Software)
Exempted Devices
Certain medical devices and IVDs are exempt from UDI requirements under Schedule 4 of the Therapeutic Goods Regulations 1990. These include.
- Export-only devices
- Custom-made devices
- Patient-matched devices with a volume of 5 or less supplied each financial year
- Devices under the Special Access Scheme (SAS) or Authorised Prescriber Scheme (APS)
- Class 1, 2, and 3 in-house IVDs
While these devices are exempt, manufacturers can voluntarily choose to meet the UDI requirements.
Submission to AusUDID
Manufacturers must submit UDI information to the Australian UDI Database (AusUDID). In addition to the UDI-DI, manufacturers must submit device information, including.
- Device Identifiers: Primary DI and issuing agency
- Device Information: Model name, device class, Global Medical Device Nomenclature (GMDN), device description
- Packaging Data: Packaging type, quantity per package
- Production Data: Lot/batch number on the label
- Sponsor and Manufacturer Details: Australian Register of Therapeutic Goods (ARTG) ID, Sponsor ID, and Manufacturer ID
- Clinical Characteristics: Clinical size, storage and handling conditions, critical warnings, number of uses
Compliance Time Frame
Mandatory compliance will be phased in by device classification, starting with high-risk and implantable medical devices, followed by lower-risk devices. Full implementation and the launch of the AusUDID are expected in 2024, with staged compliance for different device classes over subsequent years.
Recognised Authority to Issue a UDI
The TGA recognises certain issuing agencies to ensure the uniqueness of the UDI. Recognised agencies include.
- GS1
- Health Industry Business Communications Council (HIBCC)
- International Council for Commonality in Blood Banking Automation (ICCBBA)
Conclusion
Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.Implementing the Unique Device Identification system is a significant step forward in enhancing medical devices’ traceability, safety, and efficiency. Adhering to the detailed requirements, manufacturers and healthcare providers ensure that devices are accurately identified and tracked throughout their lifecycle.
UDI requirements contribute to a safer healthcare environment, improve patient outcomes and facilitate medical device innovation. As global standards continue to evolve, staying informed and compliant with UDI regulations is essential for all stakeholders in the medical device industry.
Frequently Asked Questions
How Long Can a Unique Device Identification Be?
No set standard or rule specifies the exact character length of UDIs. However, the character length is often limited by the AIDC technology used.
For example, a GTIN by GS1 can encode 8, 12, 13, or 14 digits, so the UDI length must conform to these lengths.
What Characters Can Be Encoded in UDI?
The UDI system must use characters and numbers from the invariant character set of ISO/IEC 646, 7-bit Coded Character Set for Information Interchange, including the following.
- Uppercase letters (A-Z)
- Digits (0-9)
- Special characters:
- Space
- Double quote (“)
- Number sign (#)
- Dollar sign ($)
- Percent sign (%)
- Ampersand (&)
- Apostrophe (‘)
- Parentheses (())
- Asterisk (*)
- Plus sign (+)
- Comma (,)
- Hyphen (-)
- Period (.)
- Slash (/)
- Colon (:)
- Semicolon (;)
- Less than (<)
- Equals (=)
- Greater than (>)
- Question mark (?)
- At sign (@)
- Left square bracket ([)
- Right square bracket (])
- Backslash ()
- Caret (^)
- Underscore (_)
- Grave accent (`)
Does a UDI Have a Check Digit?
Yes, the UDI has a check digit. The check digit is used to verify the integrity of the UDI and ensure it has been correctly entered or scanned.
Issuing Agencies design the check digit rules to validate the UDI.
What Is the Basic UDI-DI?
The Basic UDI-DI is the main identifier of a device model. It is key to device registration and regulatory activities such as certification.
Who Is Responsible for Complying and Placing the UDI Carrier on the Device, Label, and Device Packages?
The manufacturer or labeller of the device is responsible for complying with UDI system regulations and placing the UDI carrier on the device, label, and package.
What Is an Issuing Agency?
An issuing agency is an organisation accredited to assign UDIs to medical devices. These agencies ensure that the UDIs are unique, standardised, and compliant with international regulations. Examples include GS1, HIBCC, and ICCBBA.