US FDA
21 CFR 211.132 - Tamper-Evident Packaging Requirements for OTC Human Drug Products
Plain-language explanation, inspection context and common violation patterns.
What it says
Most over-the-counter drug products for retail sale must have a tamper-evident package designed to provide visible evidence to consumers that tampering has occurred, with a prominently labeled statement alerting consumers to the specific tamper-evident feature so its absence can be recognised.
Paraphrased for plain-language clarity. Always verify against the current published regulation text.
What it means in practice
- The labeling statement identifying the specific tamper-evident feature is as important as the feature itself, since the requirement's consumer-protection purpose depends on consumers actually knowing what to look for.
- This provision arose directly from historical incidents of product tampering after retail sale, making it one of the clearer examples of a regulation whose specific requirements can be traced to a documented real-world harm event.
- Packaging validation must confirm the tamper-evident feature actually functions as intended and survives normal distribution and handling without false triggering or failure.
What FDA inspectors look for
- Whether the tamper-evident feature used is appropriate for the specific package type and whether its presence is clearly and accurately described in the product labeling.
- Whether packaging validation data demonstrates the tamper-evident feature reliably functions through normal distribution and handling conditions.
- Whether packaging line operations include verification that the tamper-evident feature was correctly applied to each unit, not just assumed based on the packaging equipment's general performance.
Most common violation
A tamper-evident feature present on the package but not clearly or accurately described in the product labeling, undermining the consumer-protection purpose the feature is meant to serve.
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