Pure Global
๐Ÿ‡บ๐Ÿ‡ธ

United States Medical Device Registration

Food and Drug Administration (FDA) approval timelines and requirements

6-12 months
Typical Timeline
3
Device Classes
Yes
MDSAP Accepted
Required
US Agent

United States Medical Device Registration Overview

United States medical device registration through FDA typically takes 6-12 months for 510(k) devices. The official FDA target is 3 months, but realistic timelines include preparation, documentation review, and potential questions from regulators.United States uses a 3-class with pathways (I, II, III) risk-based classification system. Foreign manufacturers must appoint a US Agent to register devices in United States. FDA accepts MDSAP certification, which substitutes routine fda inspections. Registration is valid for Annual registration renewal.

Registration Timeline by Device Class

United States uses a 3-class with pathways (I, II, III) risk-based classification system.

510(k)

Premarket Notification

Medium Risk
Official
3 months
Realistic
6-12 months
With Prior Approval
6-8 months

Accelerated with: Prior 510(k) as predicate, Pre-Sub meeting

โ€ข MDUFA V goal: 90 FDA days

โ€ข Average actual: 160-176 calendar days

GMP/QMS Required

De Novo

De Novo Classification

Medium Risk
Official
5 months
Realistic
8-15 months

โ€ข For novel devices without predicate

โ€ข Only 23.8% reviewed within 150 days

GMP/QMS Required

PMA

Premarket Approval

Highest Risk
Official
6 months
Realistic
4-8 years
With Prior Approval
4-6 years

Accelerated with: Breakthrough Device Designation

โ€ข Includes clinical trial development

โ€ข FDA review: 9-12 months after trials

Clinical Trial RequiredGMP/QMS Required
Expedited Pathways

Breakthrough Device Designation

Priority review for innovative devices addressing unmet needs

1-2 years faster than standard PMA
Eligibility: Life-threatening condition, Irreversibly debilitating disease, Breakthrough technology

Pre-Submission (Q-Sub)

FDA meeting to align requirements before submission

2-3 months saved by avoiding rejections
Eligibility: All device classes, Recommended for complex devices
Prior Approval Recognition

Existing approvals from other regulatory authorities can accelerate your United States registration.

EU CE Mark
Clinical data can be leveraged
Indirect
Prior 510(k)
Use as predicate device
3-6 months
MDSAP
Substitutes routine FDA inspections
1-2 months
Key Requirements
  • US Agent (for foreign manufacturers)
  • Establishment Registration
  • Device Listing
  • QSR/21 CFR 820 compliance
  • eSTAR submission (mandatory Oct 2025)
Registration Validity:

Annual registration renewal

MDSAP Benefit:

Substitutes routine FDA inspections

Registration Process Flowchart

United States Medical Device Registration Process

Step-by-step FDA registration process. Total estimated timeline: 6-12 months.

Step 1: Device Classification

2-4 weeks

Determine FDA device class (I, II, or III) and identify predicate device for 510(k) submissions.

Step 2: Pre-Submission Meeting

2-3 months

Optional Q-Sub meeting with FDA to discuss testing strategy and submission requirements.

Step 3: Testing & Documentation

3-6 months

Complete biocompatibility, EMC, performance testing. Prepare technical file and 510(k) summary.

Step 4: 510(k) Submission

1 day

Submit 510(k) application to FDA via eCopy or eSTAR. Pay user fee (currently $22,381 for small business).

Step 5: FDA Review

90-180 days

FDA conducts substantive review. Average 160-176 calendar days. May issue Additional Information requests.

Step 6: 510(k) Clearance

1 day

FDA issues clearance letter (SE = Substantially Equivalent). Device can be marketed in the USA.

Summary: The United States medical device registration process through Food and Drug Administration (FDA) consists of 6 main steps: Device Classification โ†’ Pre-Submission Meeting โ†’ Testing & Documentation โ†’ 510(k) Submission โ†’ FDA Review โ†’ 510(k) Clearance.

Timelines are estimates based on 2024-2025 data. Last updated: 2025-12-01.