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Refuse to Accept Policy for 510(k)s: Guidance for Industry and Food and Drug Administration Staff

FinalCenter for Devices and Radiological Health Center for Biologics Evaluation and Research04/21/2022

Description

The purpose of this document is to explain the procedures and criteria FDA intends to use in assessing whether a premarket notification (510(k)) submission meets a minimum threshold of acceptability and should be accepted for substantive review.  Focusing FDA’s review resources on complete submissions will provide a more efficient approach to ensuring that safe and effective medical devices reach patients as quickly as possible.

Scope & Applicability

Product Classes

5
Medical Device

FDA intends to assess device cybersecurity based on a number of factors; demonstrate or maintain its safety and effectiveness; ensuring cybersecurity has become essential to FDA’s ability to protect the public health; Cyber-resiliency capabilities for medical devices

In Vitro Diagnostic

IVD device clinical studies conducted on de-identified specimens

in vitro diagnostic device

Specific category of medical device mentioned for EUA.

Combination Product

Products combining drug, device, or biological constituents; Generally recommended for Enhanced Documentation; Requires 14971-based framework incorporating ICH Q9; A drug-device combination where the device constituent part detects ingestion.

Class III Device

Generally recommended for Enhanced Documentation; Regulatory classification mentioned for implantable sensors and HPV tests; Mentioned in the context of an in vitro nucleic acid test for CMV DNA.

Stakeholders

5
510(k) Lead Reviewer

FDA staff member responsible for initial screening

Designated Individual

A signed statement by the manufacturer's designated individual(s)

Manufacturer

Entity responsible for submitting NDINs

Official Contact

Person to whom the RTA checklist and Addendum are sent

Submitter

The entity providing information for the AFIC process.

Regulatory Context

Attributes

10
Administratively Complete

Threshold for a submission to be accepted for review; Requirement for a submission to be accepted for review

Sterility Assurance Level

Quality parameter that must remain unchanged for the policy

Analytical specificity

Performance characteristics including Analytical specificity

Sensitivity

Analysis by sex of clinical performance measures such as sensitivity

Accuracy

Performance characteristic assessed via linearity experiment

Precision

Closeness of agreement between a series of measurements from multiple samplings.; Performance characteristic measured by intermediate precision; Performance characteristic to be validated

Level of Concern

Categorization (minor, moderate, major) for software risk.

Expiration Date

Property of a device that may be changed via established protocols

Shelf-Life

Premarket submission recommendation section; Device property; increase may not require new 510(k)

Non-pyrogenic

Labeling claim for medical devices

Identified Hazards

Hazards

4
microbial transmission

Device types identified in the Reprocessing FR Notice devices posing a greater likelihood of microbial transmission

Risks

Summary of the known and potential risks and benefits, if any, to human participants.

Cybersecurity

Risk of device functionality being compromised

infection

represent a high risk of infection

Related CFR Sections (14)

Related Warning Letters (10)

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    Envoy Medical Inc.

    2025-12-09
  • CGMP/QSR/Medical Devices/Adulterated

    Hong Qiangxing Shenzhen Electronics Limited

    2025-11-25
  • Clinical Investigator

    Shirish M. Gadgeel, M.D.

    2025-09-09
  • Good Laboratory Practice (GLP) for Nonclinical Laboratory Studies

    CCIC Huatongwei International Inspection Co., Ltd.

    2025-08-26
  • Good Laboratory Practice (GLP) for Nonclinical Laboratory Studies

    Jiangsu Kerbio Medical Technology Group Co.

    2025-08-26
  • CGMP/QSR/Medical Devices/Adulterated

    Spectra Therapy, LLC

    2025-08-12
  • CGMP/QSR/Medical Devices/Adulterated

    Mectronic Medicale S.R.L.

    2025-08-05
  • Clinical Investigator

    Mark J. Savant, M.D

    2025-07-15
  • CGMP/QSR/Medical Devices/Adulterated

    Aju Pharm Co., Ltd.

    2025-06-24
  • CGMP/QSR/Medical Devices/Adulterated

    Sedecal S.A.

    2025-05-27

See Also (8)