21 CFR Part 207 · Requirements for Foreign and Domestic Establishment Registration and Listing for Human Drugs, Including Drugs That Are Regulated Under a Biologics License Application, and Animal Drugs, and the National Drug Code

21 CFR 207.77

What legal status is conferred by registration and listing?

21 CFR 207.77 is the regulation titled “What legal status is conferred by registration and listing?” in 21 CFR Part 207, Requirements for Foreign and Domestic Establishment Registration and Listing for Human Drugs, Including Drugs That Are Regulated Under a Biologics License Application, and Animal Drugs, and the National Drug Code. Since 2021, 19 FDA warning letters have cited it.

Letters citing it
19 since 2021
Jan 1 to Oct 30, 2026
3 against 4 on the same dates in 2025
Most often cited with
21 CFR 201.128, in 17 letters
Closed out
0% of these letters have a published close-out
See the 19 letters citing 21 CFR 207.77 →

Letters citing it, by year issued

Most are drug letters (18 of 19). 2026 runs to Oct 30, 2026. Pick a year to see its letters.

  1. 62021
  2. 12022
  3. 12023
  4. 42024
  5. 42025
  6. 32026

What FDA writes when it cites it

The finding headings that cite 21 CFR 207.77 most often, as written in the letters.

  • 1 letterDAESI Hand Sanitizer is further misbranded under section 502(a) of the FD&C Act, 21 U.S.C. 352(a), because the “FDA” logo is displayed on the product label above the NDC number, which creates the impression that the…
  • 1 letterIn addition, DISINFECT™ & SHIELD HAND SANITIZER is misbranded under section 502(a) of the FD&C Act, 21 U.S.C. § 352(a), because your firm’s website misleadingly implies that FDA has endorsed or approved your DISINFECT™…
  • 1 letteryour SaniiSwab™ product is also misbranded under section 502(a) of the FD&C Act, 21 U.S.C. 352(a), because your product’s website falsely states that the FDA has approved your product

The regulation

Read the text of 21 CFR 207.77 (eCFR, as of Sep 1, 2026)

(a) Registration of an establishment or listing of a drug does not denote approval of the establishment, the drug, or other drugs of the establishment, nor does it mean that a product may be legally marketed. Any representation that creates an impression of official approval or that a drug is approved or is legally marketable because of registration or listing is misleading and constitutes misbranding.

(b) FDA's acceptance of registration and listing information, inclusion of a drug in our database of drugs, or assignment of an NDC does not denote approval of the establishment or the drug or any other drugs of the establishment, nor does it mean that the drug may be legally marketed. Any representation that creates the impression that a drug is approved or is legally marketable because it appears in our database of drugs, has been assigned or displays an NDC, or the establishment has been assigned an establishment registration number or Unique Facility Identifier is misleading and constitutes misbranding. Failure to comply with § 207.37 may also constitute misbranding.

(c) Neither registration nor listing constitutes a determination by FDA that a product is a drug as defined by section 201(g)(1) of the Federal Food, Drug, and Cosmetic Act. Registration or listing may, however, be evidence that a facility intends to or does manufacture, repack, relabel, distribute, or salvage drugs or that a product is intended to be a drug.

Text from eCFR as of Sep 1, 2026.

Cited alongside it

Regulations that appear in the same letters as 21 CFR 207.77.

Latest letters citing it

The 3 letters citing 21 CFR 207.77 that FDA posted most recently.

See the 19 letters citing 21 CFR 207.77 →
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