Our UKRP Toolkit enables you to easily set up all necessary procedures to act as a UKRP for UK Medical Device Distributors
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Aspect | USA | EU | Australia | China | UAE |
Regulatory Authority | FDA | EFSA & Member State Authorities | FSANZ | SAMR & NHC | ESMA & MOHAP |
Major Regulation Governing Compliance | Federal Food, Drug, and Cosmetic Act (FFDCA); 21 CFR Part 110 (Current Good Manufacturing Practices) | Regulation (EC) No 178/2002 (General Food Law); Regulation (EU) No 1169/2011 on Food Information to Consumers | Food Standards Code (Australia New Zealand Food Standards Code) | Food Safety Law of the People's Republic of China (Revised 2015); GB Standards for Food Safety | UAE.S GSO 9:2017 (GCC General Requirements for Prepackaged Food) |
Pre-market Approval Required? | No pre-market approval except for novel ingredients, color additives, or specific claims | No pre-market approval for general foods, but novel foods or health claims require EFSA approval. | No pre-market approval unless it's a novel food or makes health claims | Pre-market registration is required for novel foods, health foods, or products with new ingredients | Pre-market approval is required for certain foods, health products, and products with new ingredients |
Processed Food Labeling Compliance /Labeling Requirements | Mandatory labeling as per FDA guidelines (Nutrition Facts, Ingredient Declaration, Allergens) | Must comply with EU Food Information Regulation (1169/2011); includes allergens, nutrition, and origin labeling. | Must follow FSANZ Food Standards Code for labeling; nutrition panels, allergens, and ingredient lists required | Must follow GB 7718-2011 (National Food Safety Standards) for labeling; mandatory nutrition facts, allergens, and shelf-life | Must follow GSO 9:2017 for pre-packaged food labeling; Arabic labeling, allergens, and nutrition facts required |
Timeline for Registration | No fixed timeline: products can enter the market once compliant | No formal registration unless novel food; EFSA approval for health claims takes 12-18 months | No formal registration unless it's a novel food or makes health claims | Typically, 12-24 months for novel foods, shorter for regular processed foods | Approval may take 6-12 months for certain products. Regular processed foods can enter the market once label approval is obtained |
| Aspect | USA | EU | Australia | China | India |
|---|---|---|---|---|---|
| Regulatory Authority | FDA (U.S. Food and Drug Administration) | EFSA (European Food Safety Authority) & European Commission | FSANZ (Food Standards Australia New Zealand) | SAMR (State Administration for Market Regulation) | FSSAI (Food Safety and Standards Authority of India) |
| Major Regulation Governing Compliance | 21 CFR Part 106 & 107 – Infant Formula Regulations | Regulation (EU) No 609/2013 on Foods for Specific Groups (FSG) | Australia New Zealand Food Standards Code | GB Standards (e.g., GB 10765-2021) for infant formula | Food Safety and Standards (Foods for Infant Nutrition) Regulations, 2019 |
| Pre-market Approval Required? | Yes – Manufacturer registration and notification | Yes – Pre-market notification and composition review | No – Comply with standards, but no pre-approval | Yes – Mandatory registration with SAMR | Yes – Prior approval and product registration required |
| Labeling Requirements | Must meet strict CFS 21 Part 107 labeling and nutritional information requirements for infant formula. | Must comply with harmonized EU labeling rules, including allergens, nutrition info | Must comply with FSANZ labeling codes | Must follow GB labeling standards, including mandatory warnings | Must follow specific infant food labeling rules under FSSAI |
| Nutritional Composition Requirements | Specific nutrient content, quality control & Good Manufacturing Practices (GMP) required | Detailed compositional criteria for energy, protein, vitamins, and minerals | Must meet nutrition content standards specified by FSANZ | Stringent GB compositional standards; new updates in 2021 | As per Schedules under FSSAI regulations, modeled on Codex guidelines |
| Claims Allowed | Limited; FDA approval required for structure-function or health claims | Only EU-authorized claims permitted; No health or nutritional claims on infant formula | Functional and nutrient claims allowed within Regulatory limits | Strict control; health/nutritional claims require SAMR review | Only pre-approved nutrition claims allowed; therapeutic claims not permitted |
| Clinical Evidence Required? | Yes – Especially for new formulations or ingredients | Yes – EFSA scientific dossier for novel ingredients or composition | Required for novel ingredients or changes in nutrient bioavailability | Yes – For new products or ingredient combinations | Yes – If deviating from standard composition or for novel formulations |
| Timeline for Registration | ~6–12 months, depending on product review | ~12–18 months, including EFSA evaluation | ~3–6 months for market entry if compliant | ~18–24 months, including safety and technical review | ~12–18 months for full Regulatory clearance |
| Need for Local Representative | Yes | Yes | No | Yes | Yes |
Aspect | USA | EU | Australia | India | UAE |
| Regulatory Authority | FDA Center for Tobacco Products (CTP) / CDER | EC / Member States | TGA / FSANZ | Ministry of Health and Family Welfare and National Tobacco Control Cell (NTCC) | ESMA / MOHAP |
| Major Regulation Governing Compliance | Family Smoking Prevention and Tobacco Control Act (TCA); | Tobacco Products Directive 2014/40/EU (TPD); Novel Food Regulation | Therapeutic Goods Act 1989; Tobacco and Nicotine legislation; (Therapeutic Goods Standards for Nicotine and Therapeutic Vaping Products – TGO 110) | Food Safety and Standards Act (COTPA, 2003 and 2023 Amendment Rules; Prohibition of Electronic Cigarettes Act, 2019) | UAE Federal Law No. 15 (Tobacco Control); ESMA standards |
| Pre-market Approval Required? | Yes [Pre-market Tobacco Product Application (PMTA) for vaping products; drug approvals for nicotine gum) | Yes (Novel Food approval for some products; TPD notification for tobacco products) | Yes (Therapeutic Goods Administration approval) | Conventional tobacco products – not subject to registration; Nicotine products – approval required from Drug Authorities; Vapes/e-cigarettes – not applicable | Yes (Registration and conformity assessment required) |
| Labeling Requirements | FDA labeling rules for tobacco and nicotine products, including warnings | EU TPD labeling requirements, health warnings | TGA labeling for therapeutic/tobacco products | Labeling requirements as per MoHFW, including warnings and prescribed content | Mandatory health warnings and labeling per ESMA/MOHAP |
| Timeline for Registration | 12-24 months (PMTA review can be lengthy) | 6-18 months, depending on product and approval | 6-12 months depending on product class | Traditional tobacco – no registration pathway; Other nicotine categories – as applicable | 6-12 months registration and approval |