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Medical Devices

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Who Must Register, List and Pay the Fee

Establishments that are involved in the production and distribution of medical devices intended for commercial distribution in the United States (U.S.) are required to register annually with the FDA. Most establishments that are required to register are also required to list the devices and the activities performed on those devices at that establishment.

The following charts detail the requirements for registration and listing based on the type of activity performed at that establishment. The chart also includes a column showing which types of activities require payment of the establishment registration fee. See the Fee page for additional details.

 Domestic establishments

Activity Register List Pay Fee
Manufacturer YES
807.20(a)
YES
807.20(a)
YES
Manufactures a custom device YES
807.20(a)(2)
YES
807.20(a)(2)
YES
Manufacturer of accessories or components that are packaged or labeled for commercial distribution for health-related purposes to an end user YES
807.20(a)(5)
 
YES
807.20(a)(5)
YES
Manufacturer of components that are distributed only to a finished device manufacturer NO
807.65(a)
NO NO
U.S. Manufacturer of export only devices YES
807.20(a)(2)
YES
807.20(a)(2)
YES
Relabeler or Repackager YES
807.20(a)(3)
YES
807.20(a)(3)
 
NO
Contract manufacturer who commercially distributes the device for the specifications developer YES
807.20(a)(2),
 
YES
807.20(a)(2),
 
YES
Contract manufacturer who does NOT commercially distribute the device for the specifications developer NO NO NO
Contract manufacturer of subassembly or component, Contract Packager or Labeler NO NO NO
Contract sterilizer who commercially distributes the device YES
807.20(a)(2),
 
YES
807.20(a)(2),
 
YES
Contract sterilizer who does NOT commercially distribute the device NO NO NO
Kit Assembler YES
807.20(a)
YES
807.20(a)
YES
Domestic Distributor NO
807.20(c)(3)
NO   NO
Specification Developer YES
807.20(a)(1)
 
YES
807.20(a)(1)
YES
Specification Consultant Only NO
 
NO NO
Initial Distributor/Importer YES
807.40(a)
NO
Enforcement Discretion Used for 807.22(c)
NO
Device being investigated under IDE NO NO
807.40(c)
NO
Reprocessor of single use devices YES
807.20
YES
807.20
YES
Remanufacturer YES YES NO
Maintains compliant files as required under 21 CFR 820.198
(Note: register as a manufacturer if physical manufacturing taking place at site, otherwise register as a specification developer)
YES YES YES


Foreign Establishments

 Activity

Register

List

Pay Fee
Foreign Manufacturers YES
807.40(a)
YES
807.40(a)
YES
Foreign Exporter of devices located in a foreign country YES
807.40 (a)
YES
807.40 (a)
NO
Contract Manufacturer whose device is shipped to U.S. by the contract manufacturer or by any other firm YES
807.40(a)
YES
807.40(a)
YES
Contract Sterilizer whose sterilized device is shipped to U.S. by the sterilizer or by any other firm. YES
807.40(a)
YES
807.40(a)
YES
Reprocessor of Single-use Device YES
807.20(a)
YES
807.20(a)
YES
Custom Device Manufacturers YES
807.20(a)(2)
YES
807.20(a)(2)
YES
Relabeler or Repackager YES
807.20(a)(3)
YES
807.20(a)(3)
NO
Kit Assembler YES
807.20(a)
YES
807.20(a)
YES
Device Being Investigated under IDE NO
812.1 (a)
  NO
812.1(a),
807.40(c)
NO
Specification Developer YES YES YES
Remanufacturer YES YES NO
Manufacturer of components that are distributed only to a finished device manufacturer NO
807.65(a)
NO NO
Maintains compliant files as required under 21 CFR 820.198
(Note: register as a manufacturer if physical manufacturing taking place at site, otherwise register as a specification developer)
YES YES YES


Definitions of Establishment Activities

 Contract Manufacturer - Manufactures a finished device to another establishment's specifications. 

 Contract Sterilizer - Provides a sterilization service for another establishment's devices.

 Foreign Exporter - Exports or offers for export to the United States (U.S.), a device manufactured or processed by another individual, partnership, corporation or association in a foreign country, including devices originally manufactured in the United States.  A foreign exporter must have an establishment address outside the U.S.

 Initial Distributor - Takes first title to devices imported into the U.S.  An Initial Distributor must have a U.S. address. 

 Manufacturer - Makes by chemical, physical, biological, or other procedures, any article that meets the definition of "device" in Section 201(h) of the Federal Food, Drug, and Cosmetic (FD&C) Act.

 Repackager - Packages finished devices from bulk or repackages devices made by a manufacturer into different containers (excluding shipping containers).

 Relabeler - Changes the content of the labeling from that supplied from the original manufacturer for distribution under the establishment's own name.  A relabeler does not include establishments that do not change the original labeling but merely add their own name.

 Reprocessor of Single Use Devices – Performs remanufacturing operations on a single use device.  

 Specification Developer - Develops specifications for a device that is distributed under the establishment's own name but performs no manufacturing. This includes establishments that, in addition to developing specifications, also arrange for the manufacturing of devices labeled with another establishment’s name by a contract manufacturer.

 U. S. manufacturer of export only devices – Manufactures medical devices that are not sold in the U.S. and are manufactured solely for export to foreign countries.

    
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