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  • 1.  Can I change a proprietary name for a device listed with FDA ?

    This message was posted by a user wishing to remain anonymous
    Posted 16-May-2023 08:41
    This message was posted by a user wishing to remain anonymous

    For my company's device listing, can we change the proprietary name of a device listed with FDA ? 
    Thanks,



  • 2.  RE: Can I change a proprietary name for a device listed with FDA ?

    Posted 16-May-2023 09:10

    Yes, you can change the proprietary name of a device listed with the FDA. According to 21 CFR 807.25(e), the information required for each device listed includes the proprietary or brand name(s) under which each device is marketed. If you need to update the proprietary name of a device, you can do so using the FDA electronic device registration and listing system as mentioned in 21 CFR 807.28(e). Any changes to the listing information, such as a new proprietary name, must be made using the electronic device registration and listing system at the time the listing is updated or reactivated.



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    O.
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  • 3.  RE: Can I change a proprietary name for a device listed with FDA ?

    Posted 16-May-2023 09:20

     

     

    I think the below is correct for a 510(k) cleared device, but for a device approved under PMA a submission is required...

     

    https://www.fda.gov/medical-devices/premarket-approval-pma/pma-frequently-asked-questions#5

     

     

     

     






  • 4.  RE: Can I change a proprietary name for a device listed with FDA ?

    This message was posted by a user wishing to remain anonymous
    Posted 16-May-2023 13:10
    This message was posted by a user wishing to remain anonymous

    Thank you Michaela.
    21 CFR 807.28(e) refers to a discontinued device being resumed. 
    For an active device (510(k) cleared) that is active, can we change the proprietary name?
    Will the system ask for a new product code / new UDI ? 
    Thanks, 





  • 5.  RE: Can I change a proprietary name for a device listed with FDA ?

    Posted 16-May-2023 13:11

    A name change for a medical device does not automatically trigger the assignment of a new product code or a new Unique Device Identifier (UDI). However, if the FDA determines that the name change is substantial and requires a new submission, they may assign a new product code or request updates to the UDI database



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    Raje Devanathan
    Amerisource Bergen
    TPIreg, Innomar Strategies
    Senior Manager - Regulatory Affairs, Medical Devices
    rdevanathan@tpireg.com
    3470 Superior Court
    Oakville ON L6L0C4
    Canada
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  • 6.  RE: Can I change a proprietary name for a device listed with FDA ?

    Posted 16-May-2023 13:50

    Before you make the change, it's a good idea to write a plan defining all the things that need to be done and in what order.

    Review the guidance on deciding when to submit a new 510(k) for a change.

    You'll need to assign a new UDI, update all the labeling, possibly complete a trademark review, consider any other jurisdictions that may be affected, and so on.



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    Anne LeBlanc
    United States
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