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§820.60 / 820.65 → ISO 13485 §7.5.8 / 7.5.9

Maps to

FDA QMSR (Part 820): §820.60 / 820.65

ISO 13485: ISO 13485 §7.5.8 / 7.5.9

Requirement text

Product must be identified by suitable means (lot number, batch, serial number, UDI) throughout all stages of product realization. A documented traceability procedure must exist. Traceability records must be maintained to allow investigation of safety-related events.

Atomic constraints

  • Product identification methods (lot, batch, serial number, UDI) must be documented.
  • Product shall be identified throughout all stages of manufacturing.
  • A documented traceability procedure must exist.
  • UDI must be assigned and applied to device labels in accordance with applicable requirements.
  • Traceability records must be maintained to allow investigation of safety-related events.
  • For implantable devices, traceability to components, materials, and environmental conditions must be maintained.

Evidence signals

  • FILE_EXISTS

    (Traceability|UDI.*Procedure|Identification.*Procedure|Lot.*Control|Batch.*Record|Serial.*Number)

  • CONTENT_MATCH

    Does this document describe product identification methods, lot or batch numbering, UDI assignment, or traceability requirements from components to finished devices?

Audit defense

Product identification and traceability for [your product] is documented in [your document ID]. Our traceability system assigns unique lot/batch/serial numbers at defined stages, applies UDI to device labels, and maintains batch records linking each finished device to its component lots and production conditions per ISO 13485 7.5.8/7.5.9 and QMSR 820.65.

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