Nonconformance process flow chart: NCR, disposition and CAPA

For manufacturing and lab teams: contain nonconforming product, raise an NCR, choose a disposition, and decide when CAPA and root cause analysis are needed.

Nonconformance process flow chart: NCR, disposition and CAPAInspectorQualityEngineeringCONTAINDISPOSITIONCORRECTIVE ACTIONVERIFY AND CLOSEYesNoUse as isYesReworkYesRepairReturn to supplierScrapNo, isolated and low riskYes, risk or repeatNoYesNoYesUS medical deviceOther regulated sectorNoNoNoNot sureNonconforming productfoundFor manufacturing and lab teams:handle a nonconformance fromcontainment to disposition, thendecide if it needs corrective action(CAPA).A nonconformity is thenon-fulfilment of a requirement. InISO 9001:2015 this sits in clause 8.7(nonconforming outputs) and clause10.2 (corrective action). A new edition,ISO 9001:2026, came out inSeptember 2026, so check clausenumbers against the edition you use.Stop and tag the affecteditemsMark them clearly, for example with ared tag or hold label, so nobody usesor ships them by mistake.Move them to a quarantineor hold areaCheck for more of the same: otherlots made with the same material,machine, operator or method, andany stock already shipped.Has any affectedproduct left yourcontrol?Alert Quality about apossible customer noticeYour customer contract or regulatormay require notice. Medical devicemakers in the US must check FDAreporting duties, such as correctionsand removals.Contained on siteRaise a nonconformancereport (NCR)Record the part and lot numbers,quantity, the requirement not met,how it was found, photos andmeasurements.Review the NCR and decidethe dispositionYour procedure should say who canapprove each option. TypicallyQuality and Engineering signtogether. Customer approval may beneeded.What dispositionfits?Request a concessionA concession is written permissionto use or release product that doesnot meet a requirement. Record thetechnical justification.Concessionapproved?Release with the concessionon fileRework to meet the originalrequirementRework brings the item fully back tospecification. Re-inspect itafterwards.Passesre-inspection?Release the reworked itemsRepair to an acceptable butdifferent stateRepair makes the item usable but notto the original specification, so ittypically needs a concession as well.Return to the supplier withthe NCRAsk the supplier for their own rootcause and corrective action if thefault is theirs.Scrap and record thedestructionMake sure scrapped items cannotre-enter stock, for example bymarking or destroying them.Close the containmentactions on the NCRIs corrective action needed?Not every NCR needs a full CAPA.Consider the risk to safety and thecustomer, whether it has happenedbefore, and whether the cause lookssystemic.ISO's auditing guidance notes that aone-off accidental nonconformitywith low chance of recurrence mayneed correction only.Record why no CAPA isneeded and close the NCROpen a CAPA and assign anownerScale the investigation to thesignificance and risk of the problem.Find the root causeUse 5 whys or a fishbone (Ishikawa)diagram. Look across people,machine, material, method,measurement and environment.List the possible causes and markeach as confirmed, possible or notable to confirm. Do not stop at thefirst cause you find.Is the root causeconfirmed?Gather more data and testthe likely causesWrite the corrective actionplanFor each action: what will change, theowner, and the due date. Check if thesame cause could affect otherproducts or lines.Implement the actionsCheck that the change does notcreate new problems with productquality or the quality system.Verify effectivenessCollect objective evidence that theactions were done as described andthat the problem has not come back,for example over several lots or a setperiod.Did the actionswork?Reopen the investigationClose the CAPA and the NCRRecord the evidence, dates andapprovals. Feed the results intomanagement review.Is this a regulatedproduct?Check QMSR requirementswith your regulatory leadSince 2 February 2026, FDA's QualityManagement System Regulation (21CFR 820) incorporates ISO13485:2016 by reference.ISO 13485 has its own requirementsfor nonconforming product andcorrective action. Check yourprocedures against it.Check your sector's ruleswith your regulatory leadNonconformance closed andcorrective action verified

Contain

  1. Nonconforming product foundInspector

    For manufacturing and lab teams: handle a nonconformance from containment to disposition, then decide if it needs corrective action (CAPA).

    A nonconformity is the non-fulfilment of a requirement. In ISO 9001:2015 this sits in clause 8.7 (nonconforming outputs) and clause 10.2 (corrective action). A new edition, ISO 9001:2026, came out in September 2026, so check clause numbers against the edition you use.

  2. Stop and tag the affected itemsInspector

    Mark them clearly, for example with a red tag or hold label, so nobody uses or ships them by mistake.

  3. Move them to a quarantine or hold areaInspector

    Check for more of the same: other lots made with the same material, machine, operator or method, and any stock already shipped.

  4. Has any affected product left your control?Inspector
  5. Alert Quality about a possible customer noticeInspector

    Your customer contract or regulator may require notice. Medical device makers in the US must check FDA reporting duties, such as corrections and removals.

    Then go to step 7, Raise a nonconformance report (NCR)

  6. Contained on siteInspector
  7. Raise a nonconformance report (NCR)Inspector

    Record the part and lot numbers, quantity, the requirement not met, how it was found, photos and measurements.

Disposition

  1. Review the NCR and decide the dispositionQuality

    Your procedure should say who can approve each option. Typically Quality and Engineering sign together. Customer approval may be needed.

  2. What disposition fits?Quality
  3. Request a concessionEngineering

    A concession is written permission to use or release product that does not meet a requirement. Record the technical justification.

  4. Concession approved?Engineering
  5. Release with the concession on fileEngineering

    Then go to step 19, Close the containment actions on the NCR

  6. Rework to meet the original requirementQuality

    Rework brings the item fully back to specification. Re-inspect it afterwards.

  7. Passes re-inspection?Quality
  8. Release the reworked itemsQuality

    Then go to step 19, Close the containment actions on the NCR

  9. Repair to an acceptable but different stateEngineering

    Repair makes the item usable but not to the original specification, so it typically needs a concession as well.

    Then go to step 10, Request a concession

  10. Return to the supplier with the NCRQuality

    Ask the supplier for their own root cause and corrective action if the fault is theirs.

    Then go to step 19, Close the containment actions on the NCR

  11. Scrap and record the destructionQuality

    Make sure scrapped items cannot re-enter stock, for example by marking or destroying them.

  12. Close the containment actions on the NCRQuality

Corrective action

  1. Is corrective action needed?Quality

    Not every NCR needs a full CAPA. Consider the risk to safety and the customer, whether it has happened before, and whether the cause looks systemic.

    ISO's auditing guidance notes that a one-off accidental nonconformity with low chance of recurrence may need correction only.

  2. Record why no CAPA is needed and close the NCRQuality
  3. Open a CAPA and assign an ownerQuality

    Scale the investigation to the significance and risk of the problem.

  4. Find the root causeEngineering

    Use 5 whys or a fishbone (Ishikawa) diagram. Look across people, machine, material, method, measurement and environment.

    List the possible causes and mark each as confirmed, possible or not able to confirm. Do not stop at the first cause you find.

  5. Is the root cause confirmed?Engineering
  6. Gather more data and test the likely causesEngineering

    Then go to step 23, Find the root cause

  7. Write the corrective action planEngineering

    For each action: what will change, the owner, and the due date. Check if the same cause could affect other products or lines.

  8. Implement the actionsEngineering

    Check that the change does not create new problems with product quality or the quality system.

Verify and close

  1. Verify effectivenessQuality

    Collect objective evidence that the actions were done as described and that the problem has not come back, for example over several lots or a set period.

  2. Did the actions work?Quality
  3. Reopen the investigationQuality

    Then go to step 23, Find the root cause

  4. Close the CAPA and the NCRQuality

    Record the evidence, dates and approvals. Feed the results into management review.

  5. Is this a regulated product?Quality
  6. Check QMSR requirements with your regulatory leadQuality

    Since 2 February 2026, FDA's Quality Management System Regulation (21 CFR 820) incorporates ISO 13485:2016 by reference.

    ISO 13485 has its own requirements for nonconforming product and corrective action. Check your procedures against it.

  7. Check your sector's rules with your regulatory leadQuality
  8. Nonconformance closed and corrective action verifiedQuality

Outcomes

Record why no CAPA is needed and close the NCR

You get here from step 20, Is corrective action needed? (No, isolated and low risk).

Check QMSR requirements with your regulatory lead

Since 2 February 2026, FDA's Quality Management System Regulation (21 CFR 820) incorporates ISO 13485:2016 by reference.

ISO 13485 has its own requirements for nonconforming product and corrective action. Check your procedures against it.

You get here from step 32, Is this a regulated product? (US medical device).

Check your sector's rules with your regulatory lead

You get here from step 32, Is this a regulated product? (Other regulated sector).

Nonconformance closed and corrective action verified

You get here from step 32, Is this a regulated product? (No).