Medical Devices

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 Payment Process page for additional details.


Domestic establishments

Activity Register List Pay Fee
Manufacturer
(including Kit Assemblers)
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)(6)
YES
807.20(a)(6)
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)
YES
Contract manufacturer
(including contract packagers)
YES
807.20(a)(2),
YES
807.20(a)(2),
YES
Contract sterilizer YES
807.20(a)(2),
YES
807.20(a)(2),
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 Importer YES
807.40(a)
NO
Identify manufacturers
per 807.20(a)(5)
YES
Import agent, broker, and other parties who do not take first possession of a device imported into the United States NO NO 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 YES
Maintains complaint files as required under 21 CFR 820.198 YES YES YES
Establishments located in foreign trade zone YES YES YES
Refurbishers NO NO NO

Foreign Establishments

Activity Register List Pay Fee
Foreign Manufacturers
(including Kit Assemblers)
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)
YES
Contract Manufacturer
(including contract packagers)
YES
807.40(a)
YES
807.40(a)
YES
Contract Sterilizer 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)
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 YES
Manufacturer of components that are distributed only to a finished device manufacturer NO
807.65(a)
NO NO
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
Maintains complaint files as required under 21 CFR 820.198 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, prepared, propagated, compounded, or processed 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 Importer - Takes first title to devices imported into the U.S. An Initial Importer 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.

Remanufacturer - Any person who processes, conditions, renovates, repackages, restores, or does any other act to a finished device that significantly changes the finished device's performance or safety specifications, or intended use.

Reprocessor of Single Use Device - 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.

Page Last Updated: 06/12/2014
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