510(k) is 向FDA提交的上市前申请,用于证明医疗器械与合法上市的对比器械实质等效。
Complete Guide to 510(k)
A 510(k) is a premarket submission made to the U.S. Food and Drug Administration (FDA) to demonstrate that a new medical device is "substantially equivalent" to a legally marketed predicate device. Named after Section 510(k) of the Federal Food, Drug, and Cosmetic Act, this pathway is the most common route to market for Class II medical devices in the United States.
Key requirements for 510(k) clearance:
- The device must have the same intended use as the predicate
- The device must have the same or similar technological characteristics
- If different, the submission must demonstrate equivalent safety and effectiveness
Types of 510(k) submissions:
1. Traditional 510(k) - Standard submission comparing to a predicate device
2. Abbreviated 510(k) - References FDA guidance documents or special controls
3. Special 510(k) - For modifications to your own cleared device
Average FDA review time: 90-180 days depending on complexity.
Most Class II devices require 510(k) clearance, while most Class I devices are exempt. Class III devices typically require the more rigorous Premarket Approval (PMA) pathway.
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