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What changes force a retest

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A specification, a blend uniformity result and a potency assay all describe one configuration. The useful discipline is knowing what invalidates them.

The rule

If it changes what is in a serving, or how evenly it is distributed, or how long it survives, retest. Everything below is a consequence of that sentence.

Always

A new supplier for any component. Different particle size, moisture content and impurity profile all change blending behavior and potency, and a certificate from a new supplier is not a substitute for qualifying them.

A formula change, including a change in the amount of an existing component.

A process change: different mixer, different blend time, different order of addition.

A batch size change, because blend time and mixing energy do not scale linearly and a larger batch is not simply more of a smaller one.

A packaging change, because for a hygroscopic powder the moisture barrier is part of the stability case.

The ones people think are safe

A flavor change. Flavor systems are several percent of the blend and they alter particle size distribution and flow.

A sweetener change. Usually a very small component with very different properties from the bulk, which makes it a segregation risk out of proportion to its percentage.

A different grade of the same ingredient. Grade frequently means particle size, and particle size is what drives segregation.

A scoop change. A different scoop is a different serving unless recalibrated.

Building it in

Record the configuration each result belongs to: formula version, supplier lots, batch size, process parameters, packaging. Attach the test results to that record rather than filing them separately.

Then make a retest a required step in any change. The failure mode is never a decision to skip testing; it is six small changes over two years, each individually reasonable, after which nothing in the market matches anything that was tested.

References

21 CFR Part 111, Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary Supplements. In force for all manufacturers regardless of size since June 2010. ecfr.gov
Written from published regulation and peer-reviewed work, not from a laboratory of our own. Your own certificates of analysis, your blend uniformity results and your own written specifications override anything general said here. Nothing on this site is a substitute for the records 21 CFR 111 requires you to keep.