Medical device warehouse software: lots, holds and the records a recall needs

Manufacturers, importers and distributors covered by Medical Devices Regulations ss. 52–56 keep distribution records sufficient for a rapid recall, for the longer of the device’s projected useful life or two years after shipment. Plan the required recipient reporting with the licence holder before accepting stock.

Health Canada exempts a warehouse that only stores devices from its own MDEL when it does not buy, sell or take them on consignment; the licence holder identifies buildings where its procedures apply. WarePulse records lots and expiry on every plan but does not provide end-to-end unit-level serial inventory tracking.

Connect workflow fit to rollout context earlier.

Health Canada exempts a warehouse that only stores devices from its own MDEL when it does not buy, sell or take them on consignment; the licence holder identifies buildings where its procedures apply. WarePulse records lots and expiry on every plan but does not provide end-to-end unit-level serial inventory tracking.

Third-party warehouses on every plan storing Class I to IV devices for MDEL holders.

Distributors whose recalls are traced by lot rather than by individual serial number.

Warehouses that want receipts checked against the expected quantity and suspect stock held with a recorded reason.

WarePulse picking workspace with active pick tasks, warehouse filters, and execution actions

Compare related WarePulse options

Compare the next topics buyers usually review: implementation, pricing, trust, field evidence, and operating fit.

Plan the next warehouse step

Bring one client’s device list with its lot formats and retention periods, and we will show what WarePulse records per lot and what a recall list would still need.

Workflow steps

  • Ship one lot to three customers, check that each pick line records the lot, then ask how the recipient list would be produced.
  • Place a lot on hold for a complaint and confirm it drops out of available stock.
  • Check with each client which of its devices, if any, must be traced by serial number.

Implementation planning

  • SOR/2026-110 was registered June 4, 2026 and takes effect December 1, 2026. It makes documented-procedure duties explicit, including applicable handling and storage procedures for Class II to IV devices. Confirm each licence holder’s preparation.
  • Items import from CSV with their lot and expiry tracking settings, and opening stock imports with lot numbers and expiry dates.
  • Agree with each licence holder how a recipient list will be produced, since there is no built-in recall report.

Security and purchasing context

  • Holds and releases are limited to managers; roles run from owner and admin to manager, operator and picker.
  • On every plan, each licence holder’s portal login sees only its own inventory and receipts.
  • Validate each required record type and its retention against the device’s useful life, including records held outside WarePulse.

Questions to resolve

  • Does our warehouse need its own MDEL? Not if it only stores; the licence holder may list your building.
  • Can WarePulse trace individual serial numbers? No; it traces lots.

Expected business impact

  • Recorded lot references can support a recipient-report project; test that report against the licence holder’s required recipients, quantities, dates and retention before use.
  • Quantity holds exclude the held available stock from new allocation; existing reservations and other locations require separate review.

The sector rules your WMS has to respect

The operating rules that create the most risk in this sector — and hurt the most when the software gets them wrong.

1

Distribution records (MDR ss. 52–56): kept by manufacturers, importers and distributors, sufficient for a complete and rapid recall, retained for the longer of the device’s useful life or two years after shipment and retrievable in a timely way.

2

For a manufacturer- or importer-initiated recall not ordered by the Minister, MDR s. 64 requires the prescribed written information by the start of the recall, including affected quantities and recipients.

3

Complaints (ss. 57–58): records of reported problems and the actions taken, with documented procedures for investigation and recall.

4

Establishment licensing (s. 44 and GUI-0016): importers and distributors need an MDEL; a storage-only warehouse is exempt but may be listed as a building where the licence holder’s procedures are in place.

5

Health Canada consulted on Canadian UDI in 2021; verify current device-specific requirements. US UDI applies to most devices with exceptions and alternatives; required production identifiers vary by device.

Where WarePulse fits this sector

How WarePulse handles the sector rules that actually matter on your floor.

All plans store lot and expiry references in receiving, stock, picking and transfers. These are inputs to a trace investigation; there is no built-in recipient or recall report, and its completeness must be validated separately.

Receiving rejects quantities above an established expected receipt. Direct receipt into quarantine depends on the supported authorized workflow; confirm that flow separately from mobile receiving.

Authorized managers can hold available quantity by item, lot and location with a recall or investigation reason. Review other locations, reservations and shipments separately; this is not a global recall stop.

Inventory CSV exports include quantities by SKU and location. Audit records support review of recorded operations; validate record coverage and retention against the device’s useful life rather than treating a log policy as regulatory compliance.

On every plan, the licence holder gets a client portal with its own inventory, receipts and proof of delivery.

WarePulse tracks lots, not individual serial numbers; devices that must be traced unit by unit need a serial-capable system.

Built for warehouses in this industry

Operators and customer profiles where sector-specific rules shape the decision.

Third-party warehouses on every plan storing Class I to IV devices for MDEL holders.

Distributors whose recalls are traced by lot rather than by individual serial number.

Warehouses that want receipts checked against the expected quantity and suspect stock held with a recorded reason.

Not a fit where implants or other devices must be tracked by unique serial number.

The recall report decides the warehouse record

Section 64 asks for quantities and recipients on the day a recall begins. Work backwards from that: every shipment needs the lot, the customer, the date and the quantity attached when it leaves, and the record has to survive as long as the device’s useful life. Decide how the recipient list will be produced before the first recall, not during it.

Record lot, customer, date and quantity on every outbound shipment.

Confirm the retention period each client sets from its devices’ projected useful life.

Decide who can release a lot from hold and how that is recorded.

Ask each vendor to produce a recipient list by lot from a real week of shipments.

Frequently asked questions

How long must medical device distribution records be kept in Canada?+
For the longer of the device’s projected useful life or two years after the device is shipped, under section 55 of the Medical Devices Regulations.
Does a third-party warehouse need an MDEL?+
Health Canada’s guidance says a warehouse that only stores devices, and does not buy, take consignment or sell them, is exempt. The licence holder lists the buildings where its procedures are in place.
Does Canada require UDI barcodes on medical devices?+
Health Canada held a Canadian UDI consultation in 2021; that historical consultation does not establish the current requirement for every device. Check the current Canadian rule and any applicable US UDI exceptions before configuring records.
Can WarePulse track device serial numbers?+
WarePulse does not provide end-to-end unit-level serial inventory tracking. Return inspections can record a serial reference, which is not a serial inventory ledger or complete device trace.
Can WarePulse produce the recall recipient list?+
There is no built-in recall recipient report. Receipt, pick and shipment references can be inputs to scoped reporting, whose completeness and retention must be validated before go-live.
What does a recall report to Health Canada include?+
For a manufacturer or importer recall not ordered by the Minister, section 64 requires the prescribed information by the start of the recall, including affected quantities, recipients, distribution period and strategy.

Anchor the evaluation to the hardest rule on your floor.

Start with the licence holder’s reporting requirements, then validate the records and extraction needed to meet them before stock arrives.

Plan the next evaluation step