Manufacturer A is transferring several class 3 products to another Manufacturer (B). Is Manufacturer A under obligation to load the GUDID with these products during or before the transfer? Does the FDA have a timeframe for Manufacturer B remarking and entering into the GUDID?

Under 21 CFR 830.330, the labeler of a device shall submit to FDA an update to the information required
by 21 CFR 830.310 whenever the information changes. The updated information must be submitted no
later than the date a device is first labeled with the changed information. If the information does not appear
on the label of a device, the updated information must be submitted within 10 business days of the change.