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Replacement Reagent and Instrument Family Policy for In Vitro Diagnostic Devices: Guidance for Industry and FDA Staff

FinalCenter for Devices and Radiological Health08/17/2022

Description

In 2003, FDA issued an updated guidance on the "Replacement Reagent and Instrument Family Policy" for in vitro diagnostic (IVD) devices. The 2003 guidance described a mechanism for manufacturers to follow when applying an assay that was previously cleared based on performance characteristics when used with a specified instrument to an additional instrument that is either cleared or a member of an instrument family from which another instrument was previously cleared. Through the approach described in the 2003 guidance, manufacturers established sufficient control to maintain the level of safety and effectiveness demonstrated for the cleared device for these types of modified devices, when evaluated against predefined acceptance criteria using a proper validation protocol, without submission of a premarket notification (510(k)).

Scope & Applicability

Product Classes

7
In Vitro Diagnostic Devices

Validation of certain in vitro diagnostic devices (IVDs) for emerging pathogens; Validation of certain IVD devices for emerging pathogens

Class II devices

Proposed classification for NGS-based tests for germline diseases.

POC Test Systems

Point-of-care systems with specific environmental and use-error risks

IVD test systems

Pertains to IVD test systems regulated by CDRH; In vitro diagnostic test systems intended for use in CLIA-regulated laboratories

Class III devices

Subject to General Controls and Premarket Approval

CLIA-waived test systems

Devices excluded from certain policy applications

Combination devices

Assay/instrument systems considered combination devices

Stakeholders

2
Manufacturer

Entity responsible for submitting NDINs

Assay manufacturer

Entity responsible for assessing capabilities and performance of the new combination; Entity responsible for verifying and validating the modified test system

Regulatory Context

Attributes

3
Safety and effectiveness

Level demonstrated for the cleared device; Core regulatory standard for assay performance

Clinical Sensitivity

Clinical performance parameter that may require assessment for modifications

Open system

Instrument with general purpose features for use with wide array of assay types

Identified Hazards

Hazards

2
Cross-contamination

Risk associated with construction, traffic flow, and shared equipment.; Risk from raw food to RTE food or from insanitary objects; Personnel handling RTE foods touch contaminated surfaces

New Risks

Potential safety concerns identified during assessment

Related CFR Sections (3)

Related Warning Letters (10)

  • CGMP/QSR/Medical Devices/Adulterated

    Envoy Medical Inc.

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

    Hong Qiangxing Shenzhen Electronics Limited

    2025-11-25
  • CGMP/QSR/Medical Devices/Adulterated

    Contec Medical Systems Co., Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Royal Philips

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Qianjiang Kingphar Medical Material Co Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated

    LEVO AG

    2025-10-21
  • CGMP/QSR/Medical Devices/Adulterated

    Technological Medical Advancements LLC

    2025-10-07
  • Medical Device/Adulterated/Misbranded/Lacks PMA and/or 510(k)

    The Richline Group, Inc.

    2025-09-23
  • Investigational Device Exemptions (IDE)/Premarket Approval Application (PMA) Adulterated Device

    SeniorLife Technologies, Inc.

    2025-09-16
  • CGMP/QSR/Medical Devices/Adulterated

    Miach Orthopaedics

    2025-08-26

See Also (8)