21 CFR Part 820 · Quality System Regulation (before Feb 2, 2026)

21 CFR 820.120

Device labeling

21 CFR 820.120 is the regulation titled “Device labeling” in 21 CFR Part 820, Quality System Regulation (before Feb 2, 2026). Since 2021, 8 FDA warning letters have cited it.

Part 820 changed when FDA's Quality Management System Regulation took effect on February 2, 2026. This is the earlier text these letters cite.

Letters citing it
8 since 2021
Jan 1 to Oct 30, 2026
0 against 4 on the same dates in 2025
Most often cited with
21 CFR 820.198, in 6 letters
Closed out
13% of these letters have a published close-out
See the 8 letters citing 21 CFR 820.120 →

Letters citing it, by year issued

All are medical device letters. 2026 runs to Oct 30, 2026. Pick a year to see its letters.

  1. 02021
  2. 12022
  3. 22023
  4. 12024
  5. 42025
  6. 02026

What FDA writes when it cites it

The finding headings that cite 21 CFR 820.120 most often, as written in the letters.

  • 1 letterFailure to adequately establish procedures for the control of labeling operations to ensure that the label and labeling used for each production unit, lot, or batch is documented in the Device History Record (DHR), as…
  • 1 letterFailure to develop, maintain, and implement written labeling procedures to control UDI labeling activities pursuant to 21 CFR 820.120
  • 1 letterFailure to establish and maintain acceptance procedures to control labeling activities, as required by 21 CFR 820.120. Specifically, your firm has yet to establish procedures to control labeling activities for the…

The regulation

Read the text of 21 CFR 820.120 (eCFR, as of Jun 1, 2025)

Each manufacturer shall establish and maintain procedures to control labeling activities.

(a) Label integrity. Labels shall be printed and applied so as to remain legible and affixed during the customary conditions of processing, storage, handling, distribution, and where appropriate use.

(b) Labeling inspection. Labeling shall not be released for storage or use until a designated individual(s) has examined the labeling for accuracy including, where applicable, the correct unique device identifier (UDI) or universal product code (UPC), expiration date, control number, storage instructions, handling instructions, and any additional processing instructions. The release, including the date and signature of the individual(s) performing the examination, shall be documented in the DHR.

(c) Labeling storage. Each manufacturer shall store labeling in a manner that provides proper identification and is designed to prevent mixups.

(d) Labeling operations. Each manufacturer shall control labeling and packaging operations to prevent labeling mixups. The label and labeling used for each production unit, lot, or batch shall be documented in the DHR.

(e) Control number. Where a control number is required by § 820.65, that control number shall be on or shall accompany the device through distribution.

[61 FR 52654, Oct. 7, 1996, as amended at 78 FR 58822, Sept. 24, 2013]

Text from eCFR as of Jun 1, 2025.

Cited alongside it

Regulations that appear in the same letters as 21 CFR 820.120.

Latest letters citing it

The 3 letters citing 21 CFR 820.120 that FDA posted most recently.

See the 8 letters citing 21 CFR 820.120 →
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