FDA 483 OBSERVATION · #30 OF 1,923 MOST-CITED

Specifications - identity, purity, strength, composition

FDA cited this observation 687 times across 563 firms in recent inspections. Below: how it breaks down by program area and fiscal year, and real examples of how FDA worded it on Form FDA 483.

What this grouping is not

An observation-type page groups FDA’s published citation records. The grouping, the compliance steps and the root causes are SPEQ synthesis, not an FDA classification of any citation, and a count measures what FDA published rather than risk.

BY PROGRAM AREA
Foods687
BY FISCAL YEAR
FY202484
FY202377
FY2022101
FY202159
FY202044
FY201976
FY201878
FY201797
FY201671

What this observation means, and how to comply

SPEQ's practitioner reading of this finding. The regulatory basis is a cited fact; the interpretation, compliance steps, and root causes are SPEQ synthesis — not an FDA classification of the citation.

21 CFR 211.160 · 211.165

The firm did not establish or follow adequate specifications and test methods to assure the identity, strength, quality, purity, and — where applicable — composition of components, in-process materials, and finished products before release.

Why FDA writes it — Specifications are the definition of an acceptable product. Missing, weak, or unfollowed specifications mean the firm cannot demonstrate a released lot actually met what the label and application promise.

HOW TO COMPLY
  • Establish scientifically sound specifications for identity, strength, quality, and purity for components, in-process materials, and finished products.
  • Test each batch against the finished-product specification for identity and strength of every active ingredient before release.
  • Justify specification limits and any change to them, and control them as approved documents.
  • Reject and document any material or batch that fails to meet its specification rather than dispositioning around it.
WHY FIRMS GET CITED
  • Specifications inherited or copied without confirming they suit the specific product and process.
  • Release testing that checks some attributes but not every one the specification and regulation require.
PROFESSIONAL · REMEDIATION PLAYBOOK · SPEQ SYNTHESIS

How to close this finding — and stop it recurring

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What this observation is associated with

Firms cited for this observation also appear in FDA compliance actions — warning letters, injunctions, or seizures — at 4× the rate of the average FDA-cited firm (30.9% vs 7.8%), across 563 FEI-matched firms.

This is an association, not causation, and reflects co-occurrence in FDA's records — not a claim that the observation caused or preceded the action.

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How FDA worded it — real examples

You did not establish product specifications for the identity, purity, strength and composition of the finished dietary supplement.

Neopharm Bulgaria Ltd. · Gurmazovo · Foods · 2024-09-13

You did not establish product specifications for the identity, purity, strength and composition of the finished dietary supplement.

Quantum Fulfillment and Support, LLC · Cedar Creek, Texas · Foods · 2024-07-26

You did not establish product specifications for the strength and composition of the finished dietary supplement.

Alfa Vitamins Laboratories Inc. · Miami, Florida · Foods · 2024-07-17

You did not establish product specifications for the of the finished dietary supplement.

Dert Inc. · Velva, North Dakota · Foods · 2024-07-17

You did not establish product specifications for the strength of the finished dietary supplement.

Country Life, LLC · Hauppauge, New York · Foods · 2024-07-12

You did not establish product specifications for the identity, purity, strength and composition of the finished dietary supplement.

Greenland Inc · Seattle, Washington · Foods · 2024-07-11

Related SPEQ references

Where to read the requirements behind this observation area on SPEQ. These are SPEQ's topic and audience pages — not an FDA classification of the citation.

Food industry →

Examples are a representative sample of FDA's published inspection observations. Open the 483 observation explorer →