Comments on Cross-Labeled Combination Products « Combination Products Coalition (CPC)

The CPC’s comments detail major questions that were posed and discussed during the March 2, 2011 meeting with OCP relating to the regulation of cross-labeled combination products, including:

The necessity of a cross-labeling category;
Differences between cross-labeling and a mutually conforming labels;
The relabeling of combination products;
The overuse of the title “cross-labeling”;
How the European Union handles cross-labeling; and
Examples of cross-labeled products.

The document also includes an appendix that addresses where cross labeling is important in the regulation of a product.