Warning Letters: An Untapped Source for Understanding When Device Changes Require a New 510(k)
FDA Law Blog
FEBRUARY 23, 2025
Manufacturers must evaluate device changes in the first instance to determine whether a new 510(k) is needed or, instead, whether documentation of the change and rationale for not seeking 510(k) clearance is sufficient. Such assessments are highly individualized and difficult to map onto the few examples provided by FDA in its guidance.
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