Labeler Code - Private labelling for OTC (Over the Counter)

#1
My company does private labelling for OTC's. We come across several companies who do not have labeler code. FDA guidance and CFRs are too contradictory. Some say PLDs must have their own labeler code. while, some say they don't need it. Can someone please help with is?

I want to know if PLDs can sell the product under our labeler code or they need to have their own? The product is registered with the FDA under my companies NDC number already

Thank you!
 
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