21 CFR 111.70: What specifications must you establish?
Requires dietary supplement manufacturers to establish specifications for process control points, components, in-process production, labels and packaging, finished product, received products for repackaging or relabeling, and finished packaging and labeling, with QC-approved documentation of in-proc
Part 111, Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary Supplements · Subpart E, Requirement to Establish a Production and Process Control System
How FDA words it
The opening lines investigators use most when they cite 111.70, from the 483s we hold.
You did not establish product specifications for the identity, purity, strength and composition of the finished dietary supplement.Most used
Recent 483s citing 111.70
- Neeyaan LLC · Cranbury, New JerseyFor component(s) used in the manufacture of a dietary supplement, you did not… Jan 27, 2026
- Eagle Labs Inc. · Seminole, FloridaYou did not establish product specifications for identity, purity, strength,… Oct 31, 2024
- AMF Pharma LLC · Ontario, CaliforniaYou did not establish an identity specification for each component… Jan 16, 2024
- Catalent Pharma Solutions, LLC · St Petersburg, FloridaYou did not establish an identity specification for each component… Jul 21, 2023
- Fruit of the Earth, Inc. · Grand Prairie, TexasYou did not establish product specifications for the identity, purity, strength and… Dec 22, 2021
The regulation text
§ 111.70 What specifications must you establish?.
(a)You must establish a specification for any point, step, or stage in the manufacturing process where control is necessary to ensure the quality of the dietary supplement and that the dietary supplement is packaged and labeled as specified in the master manufacturing record.
(b)For each component that you use in the manufacture of a dietary supplement, you must establish component specifications as follows:
(1)You must establish an identity specification;
(2)You must establish component specifications that are necessary to ensure that specifications for the purity, strength and composition of dietary supplements manufactured using the components are met; and
(3)You must establish limits on those types of contamination that may adulterate or may lead to adulteration of the finished batch of the dietary supplement to ensure the quality of the dietary supplement.
(c)For the in-process production:
(1)You must establish in-process specifications for any point, step, or stage in the master manufacturing record where control is necessary to help ensure that specifications are met for the identity, purity, strength, and composition of the dietary supplements and, as necessary, for limits on those types of contamination that may adulterate or may lead to adulteration of the finished batch of the dietary supplement;
(2)You must provide adequate documentation of your basis for why meeting the in-process specifications, in combination with meeting component specifications, will help ensure that the specifications are met for the identity, purity, strength, and composition of the dietary supplements and for limits on those types of contamination that may adulterate or may lead to adulteration of the finished batch of the dietary supplement; and
(3)Quality control personnel must review and approve the documentation that you provide under paragraph (c)(2) of this section.
(d)You must establish specifications for dietary supplement labels (label specifications) and for packaging that may come in contact with dietary supplements (packaging specifications). Packaging that may come into contact with dietary supplements must be safe and suitable for its intended use and must not be reactive or absorptive or otherwise affect the safety or quality of the dietary supplement.
(e)For each dietary supplement that you manufacture you must establish product specifications for the identity, purity, strength, and composition of the finished batch of the dietary supplement, and for limits on those types of contamination that may adulterate, or that may lead to adulteration of, the finished batch of the dietary supplement to ensure the quality of the dietary supplement.
(f)If you receive a product from a supplier for packaging or labeling as a dietary supplement (and for distribution rather than for return to the supplier), you must establish specifications to provide sufficient assurance that the product you receive is adequately identified and is consistent with your purchase order.
(g)You must establish specifications for the packaging and labeling of the finished packaged and labeled dietary supplements, including specifications that ensure that you used the specified packaging and that you applied the specified label.
Questions
What does 21 CFR 111.70 require?
Requires dietary supplement manufacturers to establish specifications for process control points, components, in-process production, labels and packaging, finished product, received products for repackaging or relabeling, and finished packaging and labeling, with QC-approved documentation of in-proc
How do FDA investigators word a 111.70 observation?
The most common opening is: “You did not establish product specifications for the identity, purity, strength and composition of the finished dietary supplement.”
Which sections are cited alongside 111.70?
In the same 483s, investigators most often also cite 111.75 (What must you do to determine whether specifications are met?), 111.123 (What quality control operations are required for the master manufacturing record, the batch production record, and manufacturing operations?), 111.205 (What is the requirement to establish a master manufacturing record?), 111.255 (What is the requirement to establish a batch production record?).