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United States of America is
the biggest market of the world for medical instruments/
equipments but none of the company can export to USA unless
it has Device Listing and Establishment registered with
United States Food and Drug Administration (US FDA). Even
the American companies those intend to distribute any medical
instrument/equipment must have to register its establishment
with US FDA.
QS Pakistan has
full expertise for Device Listing, Establishment
Registration with US FDA as well as in Good Manufacturing
Practice (GMP).
More detail is as under:
What Is Medical Device
Listing
Most medical device
establishments are required to register with FDA must also
identify to FDA the devices they have in commercial
distribution including devices produced exclusively for
export. This process is known as medical device listing and
is a means of keeping FDA advised of the generic category(s)
of devices an establishment is manufacturing or marketing.
Each generic category is
represented by a separate classification regulation found in
Title 21 Code of Federal Regulations Parts 862-892 or FDA
assigned device name. Each regulation number or device name
is associated with one or more product codes. Regulation
numbers with more than one product code identifies the
product in further detail. For example, "Manual Surgical
Instruments for General Use," 21 CFR 878.4800, contains
several product codes including GAB (disposable suturing
needle), GDX (scalpel), HTD (forceps) and HRQ (hemostat).
Listing of
a medical device is not approval of the establishment or a
device by FDA. Unless exempt, premarketing clearance is
required before a device can be marketed (placed into
commercial distribution) in the U.S.
All device
types classified as exempt from the Premarket Notification
510(k) requirements are subject to the limitations of
exemptions. Limitations of device exemptions are found in
the device classification chapters in 21 CFR xxx.9, where
xxx is replaced with Parts 862-892 (e.g., 862.9, 864.9,
etc.). Please be aware that it is your responsibility to
ensure that you meet the exemption criteria and that your
device does not exceed the limitations of exemption. If your
device exceeds the limitations of exemption, you must submit
a 510(k) and receive a letter from FDA stating that your
device may be commercially distributed in the U.S. prior to
marketing your device.
While there is no separate
fee for listing your device, device listing is completed as
part of the annual registration process. Many device
establishment types are subject to an annual registration
fee.
Who Must List
An owner/operator of an
establishment not exempt under 21-CFR 807.65 who is engaged
in the manufacture, preparation, propagation, compounding,
assembly or processing of a medical device intended for
commercial distribution (marketing) is required to list its
device with FDA within 30 days of entering the device into
commercial distribution in the U.S. This includes
manufacturers, repackagers and relabelers, specification
developers, reprocessors of single-use devices,
remanufacturers, U.S. manufacturers of export only devices,
and manufacturers of accessories and components that are
ready to be used for any intended health-related purpose and
are packaged or labeled for commercial distribution for such
health-related purpose (that is, manufacturers of components
or accessories that are intended to be sold or leased
directly to the end user.). Foreign manufacturers and
foreign exporters must list their devices prior to importing
into the U.S.
Contract manufacturers and
contract sterilizers are required to register their
establishment and list their devices if they commercially
distribute the device. Initial importers located in the U.S.
are required to register their establishment; they are not,
at this time, required to list their devices.
An establishment is
required to list their device(s) if they are performing one
or more of the following activities:
CONTRACT
MANUFACTURER
Manufactures a finished device to another establishment's
specifications and places the device into commercial
distribution.
CONTRACT
STERILIZER
Provides a sterilization service for another
establishment's devices and places the device into
commercial distribution.
FOREIGN EXPORTER
Exports or offers for export to the United States, a
device manufactured or processed by another individual,
partnership, corporation or association in a foreign
country, including devices originally manufactured in the
U.S. A foreign exporter must have an establishment address
outside the U.S.
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.
REMANUFACTURER
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 in any way changes the intended use.
REPACKAGER AND/OR
RELABELER
Repackager:
Packages finished devices from bulk or repackages devices
made for the establishment 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.
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.
REPROCESSOR OF
SINGLE-USE DEVICES
Performs remanufacturing operations on a single-use
device.
U.S. MANUFACTURER
OF EXPORT ONLY DEVICES
Manufactures medical devices that are not sold in the U.S.
and are offered solely for export to foreign countries.
Please
note:
- Initial distributors (
importers) located in the U.S. are not required to list
their devices. However, they are required to register
their establishment.
- Refurbishers and
domestic distributors are not required to list their
devices or register their establishment.
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