Dayanand Education society's Dayanand College of Pharmacy, Latur, India.
The pharmaceutical sector is one of the most highly regulated industries worldwide, and the labelling of medicines is a crucial aspect that ensures patient safety and proper use. Drug labeling falls under the purview of pharmaceutical regulation and ensures that both patients and professionals are adequately informed about the safety, efficacy, and use of a medication. The FDA in the USA and the CDSCO in India are the major regulatory bodies entrusted with ensuring the safety and efficacy of drugs through proper labeling. In the process of enhancing international governance of pharmaceuticals, this review aimed to highlight commonalities, discrepancies, and any potential opportunities for harmonization. The main features of drug labeling laws of the USA and India are summarized in a comprehensive comparative table. The study aimed to determine the need for and importance of pharmaceutical labeling regulations to help protect the customers by including appropriate directions for the use of the drug product in an appropriate location and format
Drug labeling plays a critical role in ensuring the safe and efficacious use of medications. Drug labeling acts as a bridge between the manufacturer, healthcare professionals, and patients it provides healthcare professionals and patients with essential information about a drug's indications, dosage, contraindications, warnings, and potential side effects. Clear and comprehensive labeling empowers informed decision-making, promotes medication adherence, and minimizes the risk of adverse events. Regulatory authorities in different countries impose stringent labeling requirements to protect public health and ensure the safe and effective use of pharmaceuticals. This article delves into a comparative analysis of drug labeling requirements in the USA and India, two prominent pharmaceutical markets with distinct regulatory frameworks. The United States Food and Drug Administration (FDA) and the Central Drugs Standard Control Organization (CDSCO) are the respective regulatory bodies responsible for overseeing drug labeling in these countries. [1]
The safe use of all medicines depends on users reading the labeling and packaging carefully and accurately and being able to assimilate and act on the information presented. The primary purpose of medicines labeling and packaging should be the clear unambiguous identification of the medicine and the conditions for its safe use. [2]
Information
Certain items of information are vital for the safe use of the medicine.
Format
The information must be presented in a legible manner that is easily understood by all those involved in the supply and use of the medicine.
Style
Labeling refers to all the printed information which accompanies with the drug, including the label, wrapping and packaging insert etc. According to the Federal Food, Drug, and Cosmetic Act - Labeling means all labels and other written, printed, or graphic matters upon any article or any of its containers or wrappers, or accompanying such article. The primary purpose of the labeling is to make identification of the product clear and unambiguous. Labeling information is important for both healthcare professionals and patients. Label must provide accurate and clear instructions to the medical practitioners and consumers. Labeling is required to contain all the details of ingredients. It must describe the uses, directions of usage and contraindications of medicinal product. Prescription drug labeling contains three sections includes highlights of prescribing information, contents and full prescribing information. The safe use of medicine depends on the presentation of the information by manufacturer and understanding the same by the practitioner and user.
Labeling means all labels and other written, printed, or graphic matters upon any article or any of its containers or wrappers, or accompanying such article. The primary purpose of the labeling is to make identification of the product clear and unambiguous. Labeling information is important for both healthcare professionals and patients. [3] [4].
2. OBJECTIVE OF LABELING:-
1. The information and instructions in respect of pharmaceuticals must be shown on the product or on its innermost container or packing.
2. Consumers take in information from labels through three methods: visual, auditory, and kinaesthetic.
3 The label needs to have proper, correct information and instruction so that the patients or consumers are assisted and educated.
4. This study aimed at finding out whether Indian pharmaceutical companies adhere to national standards for packaging and labeling of drugs set by CDSCO.
5. To compare the evidence cited in the labeling of the proposed drugs to the evidence cited by the largest US commercial payers in their policies related to the coverage of specialty drugs.
3. LABELING
The best source of information on a medicine should be its label. The label is expected to satisfactorily meet the requirements for safe and efficient use of medication, although written material and oral communication with medical professionals may be available. The information to be contained on the labels of product containers and cartons should include the essential information for safe medication use. Several causes are behind medication errors; the following are some of them [5] [6].
Omission of critical information such as product name, strength, and dose form
Table no 1 Prescription drug labeling (Old format vs. new format)
|
Old format |
New format |
|
Description |
Highlights of prescribing information |
|
Clinical pharmacology |
Product names, Other required information |
|
Indications and usage |
Boxed warning |
|
Contraindications |
Recent major changes |
|
Warnings |
Indications and usage |
|
Precautions |
Dosage and administration |
|
Adverse reactions |
Dosage forms and strengths |
|
Drug abuse and dependence |
Contraindications |
|
Over dosage |
Warnings and precautions |
|
Dosage and Administration |
Adverse reactions |
|
How supplied |
Drug interactions Use in specific populations |
3.1. DRUG LABELING REQUIREMENTS IN THE USA
In the United States, the main regulatory agency in charge of medicine labelling is the Food and medicine Administration (FDA). The FDA is authorized by the Federal Food, Drug, and Cosmetic Act (FD&C Act) to create labelling guidelines for both prescription and over the counter (OTC) medications. Through its Center for Drug Evaluation and Research (CDER), the FDA upholds these rules. A few guidance documents that offer comprehensive directions on labelling format and content are published by the CDER. Comparable to CDSCO, the US Food and Drug Administration (US FDA) are responsible for regulating and overseeing the safety of food, medications, vaccines, nutritional supplements, biological medical goods, blood products, medical devices, and cosmetics. It has four directorates that supervise the agency's operations in addition to the Office of Commissioner. The Food and Drug Administration (FDA) is revising its rules for the format and content of labels for prescription drugs for humans, including biological products that fall within the drug category. To update its rules governing the structure and content of labelling for human prescription medication products, which are found in 21 CFR 201.56 and 201.57 (21 CFR 201.56 and 201.57), the FDA released a proposed rule. According to the final regulation, all FDA-approved patient labelling for both new and recently approved products as well as older products must be reprinted with or included with the labelling. Additionally, the final rule clarifies some criteria in the present regulations for prescription medicine labelling of older goods. With these modifications, medical professionals will be able to learn more from the labelling of older products. [7]
Why is Labeling Crucial in the Pharmaceutical Industry? [8]
Pharmaceutical labeling is a must because it keeps the cases safe from detriment threat and builds trust in medical products. Labeling is important for the following main reasons
3.2 INDIA'S REGULATIONS REGARDING DRUG LABELLING
In India, medicine labelling is governed by the pivotal medicines Fashion Manipulation Corporation (CDSCO).The Ministry of Fitness and Family Welfare oversees this body, which is responsible for regulating tradition specifics and cosmetics in India. The drug and Cosmetics Act of 1940 and its after emendations serve as the foundation for Indian regulations governing drug labelling. The CDSCO posts guidelines for marker format and content. The medicines and Cosmetics( Markers) rules, 1970, is one of the guidelines released by the CDSCO that describes the labelling design and conditions for colorful classes of drug.( 9) Important data for the package insert Labelling regulations In India, the" tablets and Cosmetics Act( 1940) and programs( 1945)" govern package insert regulations. Eight parameters pertaining to remedial pointers under section 6.2 and eight parameters pertaining to pharmacological statistics under phase 6.3 are listed in schedule D. The package deal insert's textbook should be in" English," as per section 6.2. The arrangement and contents of the inmost and remotest drug holders are specified in guidelines 96 and 97.
Crucial obligatory Labeling Conditions under CDSCO
Table no. 2 General Label Elements (Rule 96)
|
Label Element
|
Requirement |
Regulatory Basis |
|
Name of the Drug |
Must display the proper name (INN/generic) followed by the brand/trade name, if any. |
Rule 96 (1)(i) |
|
Net Contents |
Quantity must be stated in weight, volume, or number of dosage units. |
Rule 96 (1)(ii) |
|
Active Ingredients |
Name(s) and exact quantity of each active ingredient per dosage unit. |
Rule 96 (1)(iii) |
|
Manufacture Details |
Full name and address of manufacturer, along with manufacturing license number. |
Rule 96 (1)(iv) |
|
Batch Number |
Unique batch/lot number for traceability |
Rule 96 (1)(v) |
|
Manufacturing & Expiry Dates |
Dates in MM/YYYY format, clearly printed and legible. |
Rule 96 (1)(vi) |
|
Storage Conditions |
As per Schedule P1 ( e.g., “Store below 25C.Protect from light and moisture”). |
Rule 96 (1)(vii) + Schedule P1 |
|
Cautionary Statements & Symbols |
Must include statutory warnings and symbols (e.g,.Rx, NRx) based on drug schedule |
Rule 96 (1)(ix) + Schedule H, H1, X. |
|
Import License Number |
For imported drugs, the label must display ‘’IMP” followed by the license number. |
Rule 96 (1)(ix) |
4. REGULATORY FRAMEWORK:
The FDA is the main regulatory body for pharmaceutical product labeling in the USA. The FD&C Act provides authority for the FDA to adopt regulations pertaining to the labeling of prescription and OTC drugs. The role of enforcing such regulations falls under the FDA's CDER. A series of guidance documents with detailed guidelines on labeling content and format has been issued by the CDER. Key elements of the framework include:
FD&C Act: Defines labeling requirements and gives the FDA legal authority to enforce those requirements.
• Parts 201 and 601 of Title 21 of the Code of Federal Regulations, respectively, provide specific regulation for the form and content of labels for OTC and prescription drugs.
• FDA Guidelines: Provide other drugs, recommendations clarifications on particular areas of labeling. And clarifications on specific components of labeling.
New Drug Application and Abbreviated New Drug Application:
NDA is needed for the approval of new drugs, which includes complete labeling information .ANDA is utilized in the case of generic pharmaceuticals and mandates labeling exactly identical to the reference listed drug[10], [11].
Drug labelling in India is governed by CDSCO, the Central Tablets Fashionable Control Company. CDSCO, which guarantees that capsules and cosmetics are approved for use in India, is overseen by the Ministry of Health and Family Welfare. The 1940 Medication and Cosmetics Act and its subsequent amendments provide India's criminal framework for drug labelling. The CDSCO issues recommendations regarding the format and content of labels. The Drugs and Cosmetics (Labels) rules, 1970 are one of the CDSCO's guidelines that specify the labelling requirements for various drug categories.
The 1940 pills and Cosmetics Act laid down the specs required at the labeling of drug treatments and cosmetics.
• Pills and Cosmetics rules, 1945: give specific indications as to the form and substance of labels.
• Time table M: it forms a specific part of the requirements for medicine and Cosmetics regulations. Sure
Agenda D and agenda Y: Labeling requirements for imported tablets are provided in agenda D. clinical trial requirements, along with the requirements of labeling information for investigational capsules, are contained in schedule Y. [12]
Label Content. [13]
Similarities: The United States and India both require labels to show very important information such as
• Product name and brand name, if any
• Active medicinal ingredient(s) and their strength
• Clinical pharmacology
• The type of therapy
• Dosage type and route of administration
• Indications for use
• Contraindications and warnings
• Dosage and administration instructions
• Possible side effects
• Drug abuse and dependence
• Storage conditions
• Expiration date
• Manufacturer information
5. COMPLIANCE STANDARD: [14, 15]
FDA enforces labeling compliance through post-market surveillance, pre-market approvals, and inspections. Manufacturers are responsible for ensuring that their labels are accurate, complete, and up-to-date. The FDA has enforcement measures available for non-compliant labels, including warning letters, product seizures, or injunctions. The use of post-marketing surveillance and inspections enforces labeling compliance by the CDSCO. A random sample is taken from commercially available medications to confirm correctness in labeling. Sanctions imposed on firms, which may include product recall or suspension of production licenses, apply for non-compliance labeling. However, enforcement measures relating to labeling infractions may be less rigorous compared to the USA.
5.1. Pre-Market Approval:
All new drugs are subject to a rigorous premarket approval process that includes thorough review of the proposed labeling.
5.2. Post-Market Surveillance:
The FDA monitors marketed drugs through post-market surveillance programs to ensure that labeling requirements are being adhered to.
5.3. Inspections and Audits:
The FDA makes regular audits and inspections of manufacturing plants to ensure that the regulations on labeling are followed.
5.4. Penalties and Recalls:
Non-compliance can result in fines, product recalls, and other enforcement measures that are needed to protect public health.
6. TITLE 21 CFR:
The CFR codifies general and permanent rules published in the Federal Register by the departments and agencies of the federal government's executive department. Title 21 CFR's regulates the Food and Drug Administration. They contains rules relevant to Food, Drugs, Cosmetics, Medical Devices other related objects under the jurisdiction of the USFDA. [16]
7. EFFICACY & SAFETY
7.1 United States Food and Drug Administration
The Food and Drug Administration (FDA or Agency) is the administrative, scientific, public health, and consumer protection agency in charge of ensuring that all medications for humans and animals, medical devices, cosmetics, foods, food additives, medications and medicated feeds for food-producing animals, tobacco, and radiation-emitting devices are safe. It ensures that all products marketed in the United States are appropriately, truthfully, and satisfactorily labeled and that they are manufactured, transported, and controlled. Besides protecting the health and safety of American consumers, the FDA's operations directly and significantly touch multibillion-dollar businesses. The agency's activities are nationwide in scope and impact. More than 18,000 researchers, doctors, two regulators, and other staff members are stationed across the United States to carry out the Agency's duties. [17]
7.2 Indian Pharmaceutical Regulatory Authority
The NRA of India is Central Drugs Standard Control Organization (CDSCO), under the Directorate General of Health Services, Ministry of Health & Family Welfare, and Government of India. Besides having six zonal offices, four sub zonal offices, thirteen harbor offices, and seven laboratories spread across the country, its common headquarters is at FDA Bhawan, Kotla Road, New Delhi 110002. Medications & Cosmetics Act, 1940, and rules, 1945, confer awesome roles for the nation and federal regulators in the regulation of drug treatments and cosmetics. [18]
CDSCO's main responsibilities involve:
1. Clinical trials, new drug approvals, and import control.
2. Meetings of the Drug Treatment Advisory Board (DTAB) and Drug Control Committee (DCC)
3. Central License Approving Authority
8. POST-MARKETING UPDATE [19, 20]
• Adverse event reporting: all major adverse events associated with their drugs have to be reported by the manufacturers.
• Label changes: The FDA may require changes to labels due to new safety information or post-marketing studies.
• Pharmacovigilance program: Even though there exists a system for monitoring adverse responses to drugs, the reporting may not be as comprehensive as in the USA.
• Label updates: The CDSCO may be less proactive than the FDA in effecting changes for safety reasons.
Table no 3 Comparative Analysis [21, 22]
|
Parameter |
USA |
INDIA |
|
Regulatory agency |
Food and drug administration |
Central drugs standard control organization(CDSCO)
|
|
Rule |
It comes under 21 CFR 201.56(d) and 201.57. It became final rule. |
It come under drug and cosmetic rule 1945 |
|
Searchable data base |
Drugs@FDA , DailyMed, drug safety related labeling changes database, FDALabel |
not any other database |
|
Approval Process |
Stringent approval process with clinical trials and extensive documentation. Prior approval is required. |
Approval process may vary, clinical trials may be required. Prior approval is not required. |
|
Contents |
Drug name and active ingredients - Dosage form and strength - Indications and usage – Contraindications - Warnings and precautions - Adverse reactions - Drug interactions - Use in specific populations - Instructions for use - Storage and handling - Package insert information |
Drug name and active ingredients - Dosage form and strength - Indications and usage – Contraindications - Warnings and precautions - Adverse reactions - Drug interactions - Use in specific populations - Instructions for use - Storage and handling - Package insert information |
|
Language |
English |
English /Hindi |
|
Package insert format |
PLR format/ non-PLR format |
Not specific format |
|
Oder of label display |
Highlights of Prescribing Information include all the parameters that involve pharmacokinetics and pharmacodynamics of the drug. |
Section 6.2: Therapeutic Indications Section 6.3: Pharmaceutical Information |
|
Initial approval process |
Statement of initial approval process should be displayed with year |
This information is not given in label |
|
Review Process |
Centralized, extensive clinical trial data |
Includes state-level authorities |
|
Size of Label |
Generally standardized, with variations for different drug types |
May vary in size and format |
|
Code no. |
NDC (National drug Code) number |
Barcode no. |
|
Batch number and Expiration date |
It should be included |
It should be included |
|
Dosage and Administration |
Aconcised information with subheadings, dose range, dosage regimen, starting dose, critical differences among population subsets. |
Aconcised information with subheadings, dose range, dosage regimen, starting dose, critical differences among population subsets. |
|
Warning and precautions |
A summary of the most clinically significant information is needed with any Appropriate subheadings |
Box warning is required if drug come under schedule (H,G,X) |
|
Drug interaction |
A concise summary of the information required with any appropriate subheadings |
Not given |
|
Prescription status |
Rx |
Rx, NRx, XRx |
|
Post-Marketing Surveillance |
Robust, centralized |
Pharmacovigilance Program of India (PvPI) |
|
Compliance standards |
Centralized federal oversight |
State-level variations |
|
Child resistance packaging |
Yes |
No |
|
Drug come under controlled substance schedule |
Information shows in form of symbol |
Not given |
|
Paralyzing Agent requirement |
Warning with Paralyzing Agent in cap |
No |
|
Side by side comparison |
Vials/Carton |
Vials/Carton |
|
Pricing (MRP) |
Not shown on U.S. labels |
Must display MRP inclusive of taxes |
CONCLUSION
Drug labeling plays a crucial role in ensuring the safe and effective use of pharmaceuticals. Similarly, their healthcare agendas and regulatory environments are reflected in the different regulatory frameworks and standards for compliance in both the USA and India. By recognizing the similarities and variations in these standards, regulators can find common areas of cooperation and development to enhance medication safety and efficacy for patients worldwide. In order to achieve these goals, future efforts will need to focus on increasing global cooperation, transparency, and harmonization of regulatory requirements. While labeling policies in both countries include key provisions for assuring the safe and effective use of pharmaceuticals, significant differences remain regarding format, depth of information content, and requirements. Pharmaceutical firms that wish to enter both markets must understand these regulatory complexities. Increased harmonization of requirements could advance global patient safety and compliance as pharmaceutical products continue to become more global in nature.
REFERENCES:
Sneha Patil, Lohiya G. V., Satpute K. L., Comparative Study about Requirements of Drug Labeling in the USA and India., Int. J. of Pharm. Sci., 2026, Vol 4, Issue 2, 4099-4108. https://doi.org/10.5281/zenodo.18774163
10.5281/zenodo.18774163