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EAS Blog

EAS Independent Consultants and staff provide in-depth regulatory expertise and authoritative reporting on a variety of compliance requirements for industries that EAS serves. Our experts break down complicated topics into easily understandable summaries and analysis. Subscribe to our newsletter and receive these monthly updates directly in your in-box.

MoCRA Preparations Should be in Progress

MoCRA Preparations Should be in Progress

As the cosmetic facility registration and product listing requirement date approaches (29 December 2023), companies needing to register their facility, or list cosmetic products should be gathering the information required to submit to FDA. For facilities that need to register [every person who...

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FDA Issues New Guidance for Allergen Management and Control

FDA Issues New Guidance for Allergen Management and Control

On September 26, 2023, US FDA issued an updated Draft Guidance for Industry: Hazard Analysis and Risk-Based Preventive Controls for Human Food. This new guidance material includes a new chapter specific to allergens. Key take-aways include: Establish and Implement a Food Allergen Program. The...

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Drug and Device September 2023

Drug and Device September 2023

Reminder that FY2024 GDUFA payments are due 2 October 2023. The FDA does allow a 20 calendar day grace period, after which arrears lists will be published with the names of companies that have failed to make payment. Failure to pay required user fees by this deadline deems any generic drugs...

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Food labeling: EU versus USA

Food labeling: EU versus USA

Gisela Leon, EAS Consulting Group Independent ConsultantInterviewed for Industrie- und Handelskammer HannoverSeptember 21, 2023Published in GermanThere are uniform EU-wide regulations on how food should be labelled in general and what minimum information must be included on the packaging. However,...

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“Tree Nut” Allergy; Is It a Misnomer?

“Tree Nut” Allergy; Is It a Misnomer?

By Lisa Zitiello, EAS Consulting Group, Independent ConsultantFood safety professionals across the globe will agree that one key safety factor in food production today is the avoidance of allergen cross-contact. This is closely followed by declaring an allergen ingredient on the finished product...

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FDA Extends Comment Period for TPMP Proposed Rule

FDA Extends Comment Period for TPMP Proposed Rule

On March 10, the U.S. Food and Drug Administration published a proposed rule titled, Requirements for Tobacco Product Manufacturing Practice. FDA is extending the proposed rule’s comment period by an additional 30 days to allow people additional time to submit comments. Comments on the proposed...

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Drug and Device August 2023

Drug and Device August 2023

We will be entering the establishment renewal and product listing certification period soon. As your regulatory support partner, EAS is here for any questions you may have.  If you wish for us to handle the annual requirements, please email Victoria Pankovich to get on the schedule. The annual...

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Federal Judge Strikes Down FDA Regulation of Premium Cigars

Federal Judge Strikes Down FDA Regulation of Premium Cigars

In a major win for the premium cigar industry, Judge Amit Mehta of the U.S. District Court for Washington D.C. has vacated FDA’s deeming regulations for premium, hand-rolled cigars. As a result, the regulations introduced by the FDA in 2016 do not apply to cigars that meet the following criteria:...

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Beverage Manufacturing

Beverage Manufacturing

What’s Hot in the Beverage Industry? A look at trends and regulations for beverage manufacturingSeptember 12, 2023 at 1 p.m. EasternPresented by Omar Oyarzabal, Ph.D., EAS Consulting Group and Alex Brandt, Ph.D. Certified GroupThe beverage industry is thriving. From sports recovery to hydration,...

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Drug and Device July 2023

Drug and Device July 2023

Thinking about an FDA gap assessment this year? Contact EAS now to schedule your 2023 audit. Schedules toward the end of the year tend to book up suddenly, now is the time to lock in your audit, whether it be onsite or virtual. We would be happy to prepare an audit proposal so you can review and...

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Congress Seeks Input on CBD Regulation by August 18

Congress Seeks Input on CBD Regulation by August 18

On July 27, 2023, the U.S. Congress requested information to guide the assessment of the potential for a regulatory pathway for hemp-derived Cannabidiol (CBD) products with the goal to prioritize consumer safety and bring certainty to the U.S. market. Since the passage of the 2018 Farm Bill,...

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Biofilms and Healthcare

Biofilms and Healthcare

By David W Koenig, PhD., EAS Consulting Group Independent ConsultantHealthcare facilities -- such as hospitals, nursing homes and outpatient facilities -- are opportunistic locations for acquiring secondary infections unrelated to a patient's primary condition. Healthcare-acquired infections...

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Drug and Device June 2023

Drug and Device June 2023

The FDA has published a new Guidance Document Assessing User Fees Under the Generic Drug User Fee Amendments of 2022 which explains in great detail the GDUFA program user fee obligations. GDUFA III made slight changes to the user fee structure. (API facility fees changed from 7% to 6% and the...

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The Food Safety Language

The Food Safety Language

By Rafael Olivares, EAS Independent ConsultantA career in food safety is not an easy one. It is a stressful profession that requires dedication and a commitment to learn continuously and to teach, to communicate effectively to an audience, in most cases, obstinate, and not open to listen. After...

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Drug and Device May 2023

Drug and Device May 2023

As we approach June, keep in mind that drug establishment registrations and NDC listings that have had any changes to their information must update their files with the FDA within 30 days. Failing that, the agency expects updates to be submitted the JUNE or December following such a change. Do...

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FDA Proposes Long-Awaited Tobacco Product Manufacturing Practices

FDA Proposes Long-Awaited Tobacco Product Manufacturing Practices

By Shelly Blackwell, Senior Director for Dietary Supplement and Tobacco ServicesOver 12 years after the FDA began regulating tobacco products, the long-anticipated Tobacco Product Manufacturing Practices (TPMP’s) have been proposed. The new requirements were proposed by the FDA on March 8, 2023,...

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Drug and Device Corner April 2023

Drug and Device Corner April 2023

Reminder that the FDA has announced the 2023 OMUFA user fee rates, please see the Over-The-Counter Monograph Drug User Fee Program (OMUFA) website for full details. Monograph Drug Facility (MDF) Facility fee: $26,153; Contract manufacturing Organization (CMO) Facility Fee: $17,435. The annual fee...

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