In an increasingly digital world, printed labeling and information options, which provide instructions, guidance and warnings, remain critically important for consumers. Approximately 30% of all Americans, roughly 90 million people, remain without consistent access to Wi-Fi or similar Internet services and technology. Natural and other disasters can also cut off access to existing technology for long periods of time.
Several federal government agencies have relaxed or rescinded printed labeling information and mailing requirements over the past few years. Some of these changes to digital or electronic format include delivery of financial reports, tax forms, notice of tax filing options and Social Security statements.
Beyond these relaxed printed paper regulatory requirements, some federal agencies are also transforming existing printed label information into an electronic format.
A recently issued final rule highlighting the presence of Bioengineered (BE) foods require simple QR codes for the consumer to scan with their smartphone to find additional product information. This rule not only reduces the amount of printed labeling required to be “on-product”, but also minimizes information provided to consumers without access to smartphone or similar technology.
The FDA has also considered for several years a move from required printed medicine and prescription drug information to delivery of information in a TBD electronic format
TLMI Position Statement:
- TLMI recognizes that not all Americans have ready access to necessary product information through smartphones or similar online technology.
- The information and format provided via printed labeling is an important element of consumer education and safety.
- Electronic labeling has a role to play in accompanying rather than replacing traditional label and other paper-based information.
- Printed labeling should remain mandatory in all areas where consumer or patient safety is at potential risk. Content via electronic format may also be offered in a complementary fashion.