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New GMP Implementation: Compliance on Lot Traceability of Packaging Materials under Mandatory Material Balance Rules

Starting from November 1, 2026, the revised Good Manufacturing Practice for Medical Devices of China officially takes effect. Material balance has become a mandatory general requirement covering all categories of medical devices under this local Chinese regulation. For medical device manufacturers, lot control and data traceability of packaging materials are critical to passing regulatory audits on material balance calculation. This article outlines three key compliance points.
Nov 5th,2026 7 Visualizações

Starting from November 1, 2026, the revised Good Manufacturing Practice for Medical Devices of China officially takes effect. Material balance has become a mandatory general requirement covering all categories of medical devices under this China local regulation. For medical device manufacturers, lot control and data traceability of packaging materials are critical to passing regulatory audits on material balance calculation. This article outlines three key compliance points.


01 Key Regulatory Update: Mandatory Material Balance for All Product Classes

Material balance has been moved from the appendix into the main text of the revised GMP. It requires manufacturers to document material balance calculation within batch records for every lot or unit produced.

Material balance compares the sum of actual output / consumption plus collected waste against the theoretical quantity, within an approved permissible deviation.

Printed packaging materials are classified as high-risk materials and require lot-by-lot material balance calculation. If the result falls outside approved limits, the batch shall be quarantined immediately and a deviation investigation launched. The batch cannot be released until risks are fully resolved and root causes confirmed.

02 Data Alignment for Digital Traceability

The regulation does not make MES deployment compulsory. However, companies using digital systems must ensure electronic records are authentic, accurate, complete, timely and traceable, with user permission control, audit trails and data backup. Many Chinese medical device manufacturers are implementing MES for automatic material data capture and electronic batch records.

Reliable digital traceability depends on standardized incoming material data. As part of material balance calculation, packaging materials require clear lot marking, accurate delivery quantities and accessible test certificates to support trustworthy traceability inside customers’ systems.

03 Three Ways Martin Supports Customers on Material Balance

1
Verifiable lot number & quantity reconciliation Martin provides thermoformed trays, lidding films and sterile pouches with full lot control and clear lot marking. We recommend customers mark Martin lot numbers on purchase orders and receiving documents, and link consumption records to corresponding lots, to establish a solid baseline for material balance calculation in batch records.
2
Separate recording of packaging waste Collected waste must be included in material balance. We recommend recording rejected incoming goods, setup scrap and sampling loss separately in batch records with linked lot numbers, to satisfy regulatory requirements and facilitate quality feedback.
3
Quick access to batch data during out-of-limit investigations If a material balance deviation occurs and packaging material consumption is suspected, customers may request full batch test records using Martin lot numbers. Martin applies stricter internal control limits than general industry standards:
Test Item Martin Internal Control General Standard
Initial bioburden ≤30 CFU/100cm² ≤100 CFU/100cm²
Particle contamination ≤50 /100cm² ≤90 /100cm²
Seal integrity (dye penetration) No leakage after >30 seconds static hold Observation window: 5–30 seconds

Tighter internal specifications reduce quality variation, helping customers rule out packaging as a contributing factor and focus investigation on production processes.

04 Martin Quality Assurance

Martin Medical Packaging operates under ISO 13485. Our sterile barrier systems are validated to ISO 11607 and manufactured in a Class 10,000 (ISO Class 7) cleanroom. Full lot traceability runs from raw material receiving to finished goods dispatch.

Every shipment of thermoformed trays, lidding and sterile pouches carries clear lot identification, reconciled delivery quantities and retrievable inspection records, delivering standardized data for customers to meet China’s material balance requirements and integrate with their digital quality systems.

For lot traceability statements or summaries of our internal control standards, please contact your sales engineer or call +86-756-8988 909.