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Medical Device Accessories: Classification and Risk-Based Approach

This guidance describes FDA's policy concerning the classification of accessories to medical devices. It explains what FDA considers an accessory and outlines the processes under Section 513(f)(6) of the FD&C Act to allow requests for risk- and regulatory control-based classification of accessories. The guidance applies to all articles that meet the definition of an accessory device, including software products that may also meet the definition of Software as a Medical Device (SaMD).

  1. Determine if product meets accessory definition by evaluating:
    • Intended use with parent device(s)
    • How it supports, supplements, or augments parent device performance
  2. Assess risk profile:
    • Evaluate risks when used with parent device
    • Identify unique risks independent of parent device
    • Determine appropriate regulatory controls
  3. Choose appropriate classification pathway:
    • New Accessory Request for accessories included in PMA/510(k)
    • Existing Accessory Request for already marketed accessories
    • De Novo process for new accessory types
  4. Prepare submission documentation:
    • Clear identification of request type
    • Device information and compatibility data
    • Risk assessment and mitigation measures
    • Proposed controls
    • Performance data
    • Labeling with compatibility information
  5. Consider Pre-Submission meeting with FDA for feedback before formal submission
  6. Ensure compliance with applicable regulatory controls based on classification

Key Considerations

Software

  • Software products that meet the definition of an accessory will be subject to the same risk- and regulatory control-based classification paradigm
  • SaMD that uses data from a medical device does not automatically become an accessory
  • SaMD may be considered an accessory if it supports, supplements, and/or augments the performance of parent devices

Labelling

  • Labeling and promotional materials should determine whether an article is intended for use with a parent device
  • Labeling must include adequate instructions for use with parent device(s)
  • Include compatibility information and relevant technical characteristics

Safety

  • Risk assessment should consider:
    • Risks imposed by accessory’s impact on parent device
    • Unique risks of accessory independent of parent device
    • Risk profile when used as intended with parent device

Other considerations

  • 21 CFR 820.3: Quality System Regulation - Definitions
  • 21 CFR 820.3(c): Component definition
  • 21 CFR 820.3(l): Finished Device definition

Original guidance

  • Medical Device Accessories: Classification and Risk-Based Approach
  • HTML / PDF
  • Issue date: 2017-12-20
  • Last changed date: 2022-10-03
  • Status: FINAL
  • Official FDA topics: Medical Devices, Digital Health, Premarket, Biologics, Administrative / Procedural
  • ReguVirta summary file ID: c0347a162d8d0fa7f6b0e18d429ee8d8
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