FDA 483 OBSERVATION · #132 OF 1,923 MOST-CITED

Specifications - labels, packaging

FDA cited this observation 228 times across 196 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
Foods228
BY FISCAL YEAR
FY202631
FY202537
FY202421
FY202319
FY202218
FY20219
FY202017
FY201917
FY201822
FY201719
FY201618

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 211.122

Written procedures and specifications for the receipt, identification, examination, storage, handling, and approval or rejection of labeling and packaging materials are lacking or inadequate, as required by §211.122 — the controls that keep incorrect or unapproved labels and packaging out of finished drug product.

Why FDA writes it — Labeling and packaging errors are a leading cause of drug recalls and patient harm — a mislabeled product can deliver the wrong drug or strength. FDA protects against unexamined or uncontrolled labeling by requiring specifications and approval controls before any label reaches the line.

HOW TO COMPLY
  • Establish specifications and written procedures for receipt, examination, and approval or rejection of all labeling and packaging materials.
  • Examine incoming labeling against the approved specimen and quarantine until the quality unit approves it.
  • Control storage and issuance so obsolete or superseded labeling is destroyed and cannot be reissued.
  • Reconcile issued, used, and returned labeling for each batch to detect mix-ups or shortages.
WHY FIRMS GET CITED
  • Labeling is received and used without a documented examination against an approved master specimen.
  • Obsolete labels are not destroyed on a revision, so an outdated version is later pulled and applied.
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 3.8× the rate of the average FDA-cited firm (29.1% vs 7.8%), across 196 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 packaging specifications.

Organic By Nature, Inc. · Rancho Dominguez, California · Foods · 2026-08-25

You did not establish label and packaging specifications.

Vitamin Energy · Elsmere, Delaware · Foods · 2026-08-17

You did not establish label and packaging specifications.

Ele Chocolates, LLC · Omaha, Nebraska · Foods · 2026-08-12

You did not establish packaging specifications.

Marlyn Nutraceuticals Inc · Phoenix, Arizona · Foods · 2026-07-31

You did not establish label and packaging specifications.

Immudyne Nutritional LLC · Pensacola, Florida · Foods · 2026-07-23

You did not establish label and packaging specifications.

Krakatoa Inc (FL) · Palm Bay, Florida · Foods · 2026-07-14

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 →