Yes. The U.S. FDA UDI Rule terminates the use of NHRICs and NDCs for medical devices on the date
a device must be labeled with a UDI. (The NDC/NHRIC for any device that is not required to bear a UDI
will be rescinded no later than September 24, 2018.) Therefore, on the date that your device must be
labeled with a UDI, you may no longer continue to label it with an NHRIC number. However, in the interim,
you may label your device with both a UDI and an NHRIC. In the GUDID, we suggest that you enter the
UDI as the primary DI and the NHRIC as the secondary DI, and then remove the secondary DI (i.e., the
NHRIC code) by the applicable compliance date.
