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Regulatory Framework

The competent authority is the Food and Drug Administration (FDA).

Device Classification:

  • Class I: Low risk (e.g., basic surgical instruments)
  • Class II: Moderate risk (e.g., syringes, non-invasive diagnostic devices)
  • Class III: High risk (e.g., pacemakers, cardiovascular implants)

Main Regulatory Pathways

  • 510(k): For devices substantially equivalent to products already on the market.
  • PMA (Premarket Approval): For high-risk Class III devices, requiring comprehensive clinical data.
  • De Novo: For innovative devices without existing approved equivalents.
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Specific Local Requirements

Language  Documentation in English.
Local Representative (US Agent) Required for non-U.S. manufacturers.
Audits FDA may inspect both U.S. and foreign manufacturing facilities.

 

Quality System Regulation (QSR) U.S.-specific quality management regulations, similar to ISO 13485 but with distinct requirements.
Establishment Registration and Device Listing Mandatory for importing medical devices into the U.S.

Challenges and Operational Advice

  • Market structure: Highly competitive; product differentiation is essential.
  • Strict compliance: Must meet FDA regulations, including QSR, specific labeling, and post-market surveillance.
  • Timelines: PMA procedures can take up to 18 months; even 510(k) submissions often require additional information.
  • Importance of Clinical Trials: For high-risk devices, planning FDA-compliant clinical studies is crucial.
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Why Choose ISEMED

  • FDA Expertise
    Consulting on 510(k), PMA, De Novo, and FDA registrations.
  • Regulatory Support
    Assistance with audits, documentation, and managing FDA inquiries.
  • Clinical Trial Management
    Support for planning and conducting clinical studies for Class III devices.
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FAQ

  • Is a local representative required? Yes, a US Agent for foreign manufacturers.
  • Documentation language? English.
  • Authorization duration? Unlimited, subject to post-market surveillance.
  • How does 510(k) work? Demonstrates substantial equivalence to a previously approved device to avoid PMA.
  • What is De Novo? A streamlined pathway for novel devices without an equivalent, less burdensome than PMA.
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