UDI Suggestions for consumable devices


Hello all!

We are a specifier for a consumable product that is about to have its UDI Alternative Exemption expire toward the end of this year, and are working to ensure we can find an efficient way to label our products. The issue we are running into is that based on inconsistencies in supply chain and manufacturing schedules, we cannot preprint the labeling of the UDI codes on packaging prior to providing it to our (3rd party) manufacturer, as the date of manufacture/expiry date is likely to change based on scheduling. And when a batch of product is produced, it may be packaged over a period of days, with each receiving a new lot code and thus requiring a different PI, which will likely lead to errors at some point.

We have considered stickers to be applied so that they could be printed on site and applied with the appropriate PI information, however this significantly alters the presentation of the product (which primarily exists in retail space - not heath care settings), and marketing is not pleased with that idea.

Has anyone found any efficient ways to work with the requirements without overburdening manufacturing and risking significant errors? Any suggestions would be amazing, whether that be equipment, labeling methods, using batches instead of lot codes, anything at all! None of our manufacturers seem to have any concept or ideas of how we will manage this and have put it on us to find a solution.

Thank you!
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