FDA Registration and Listing Requirements

Source: http://www.fda.gov/cdrh/devadvice

This chart gives a broad outline for foreign establishments

Operation

Register

List

1.

Foreign Manufacturers (including remanufacturers and all foreign establishments

YES
807.40(a)

YES
807.40(a)

2.

Foreign Exporter of devices located in a foreign country

YES
807.40 (a)

YES
807.40 (a)

3.

Contract Manufacturer who exports devices to U.S.

YES
807.40(a)

YES
807.40(a)

4.

Contract Sterilizer who exports devices to U.S.

YES
807.40(a)

YES
807.40(a)

5.

Reprocessor of Single-use Device

YES
807.20(a)

YES
807.20(a)

6.

Custom Device Manufacturers

YES
807.20(a)(2)

YES
807.20(a)(2)

7.

Relabeler or Repackager

YES
807.20(a)(3)

YES
807.20(a)(3)

8.

Kit Assembler

YES
807.20(a)

YES
807.20(a)

9.

Device Being Investigated under IDE

NO
812.1 (a)

 NO
812.1(a),
807.40(c)

This chart gives a broad outline for domestic establishments

Operation

Register

List

1.

Contract manufacturer who commercially distributes device for the specifications developer

YES
807.20(a)(2)

YES
807.20(a)(2),
 

2.

Contract manufacturer who does NOT commercially distribute device for the specifications developer

NO
807.20(c)(1)

NO
807.20(c)(1)

3.

Manufacturer

YES
807.20(a)

YES
807.20(a)

4

Domestic Distributor

NO
807.20(c)(3)

NO 

5

Specification Developer

YES
807.20(a)(1)
 

YES
807.20(a)(1)

6

Specification Consultant Only; No Distribution

NO
 

NO

7

Relabeler or Repackager

YES
807.20(a)(3)

YES
807.20(a)(3)
 

8

Kit Assembler

YES
807.20(a)

YES
807.20(a)

9

Remanufacturer

YES
807.20(a)

YES
807.20(a)

10

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)

11

Manufacturer of components and distribute only to finished device manufacturer

NO
807.65(a)

NO

12

Contract manufacturer of subassembly or component (see #12, Accessory)

NO

NO

13

Contract Packager or Labeler

NO

NO

14

Contract sterilizer who commercially distributes the device

YES
807.20(a)(2),
 

YES
807.20(a)(2),
 

15

Contract sterilizer who does NOT commercially distribute the device

NO
807.20(c)(2)

NO
807.20(c)(2)

16

Manufactures a custom device

YES
807.20(a)(2)

YES
807.20(a)(2)

17

U.S. Manufacturer of export only devices

YES
807.20(a)(2)

YES
807.20(a)(2)

18

Initial Distributor / Importer

YES
807.40(a)

NO
Enforcement Discretion Used for 807.22(c)

19

Device being investigated under IDE

NO

NO
807.40(c)

20

Reprocessor of single use devices

YES
807.20

YES
807.20

Definitions of Establishment Types

Contract Manufacturer - Manufactures a finished device to another establishment's specifications and puts the device in commercial distribution. 

Contract Sterilizer - Provides a sterilization service for another establishment's devices and puts the devices in commercial distribution.         

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/Importer - 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.     

Remanufacturer - Processes, conditions, renovates, 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 - 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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