Should a different GTIN or NDC code be used for packaging and product?
If you have product packaging that contains the unit-of-use (in other words, quantity = one), both must comply with the Rule since the packaging might not go to the bedside, whereas the product would. But should a different GTIN or NDC code be used for the packaging and the product? (GTIN is the Global Trade Item Number as defined by EAN.UCC that includes the NDC in one of EAN.UCC’s standard bar code symbols.) The answer is no. The same code is used on the packaging and the item since they are, essentially, interchangeable from an inventory and administration point-of-view. (Obviously, there’s a difference between administering packaging to a patient as opposed to administering medication.) The bar code symbology on the item, however, does not need to be the same as on the product packaging. The code may be encoded in any of the linear EAN.UCC symbologies, including RSS if space is an issue. (At this point, the FDA does not recognize the Data Matrix 2D symbology under the Rule.) For mo
