Regulatory Open Forum

 View Only
  • 1.  Sunglass Products - Registration & Listing

    Posted 19-Nov-2014 13:57
    Our company manufactures finished sunglasses for multiple companies and stores.  Each order is for multiple styles and many are custom styles.  This is a new company and we are getting ready to register and list for the first time.  However, we are not sure how to file the device listing as the models, styles, etc. change with each new order.

    Any suggestions?

    -------------------------------------------
    Christine Posin RAC
    Walnut CA
    United States
    -------------------------------------------


  • 2.  RE: Sunglass Products - Registration & Listing

    Posted 20-Nov-2014 08:16
    Christine - It appears that most (if not all) opthalmic "spectacle" devices (including sunglasses) are Class I, 510(k)-exempt under 21 CFR 886. You would really only need to create a listing for the appropriate Class I product code(s) under which you determine that your devices would fall. There may only be one (HQY, for example?). Regardless, the listings would be created by Class I, exempt product code in this case and would be independent of the varieties, styles, etc.

    -------------------------------------------
    Karl Nittinger
    Reading PA
    United States
    -------------------------------------------




  • 3.  RE: Sunglass Products - Registration & Listing

    Posted 20-Nov-2014 08:32
    Karl is correct. However, if you manufacture for a private label customer you would need to list the brand names as well.

    -------------------------------------------
    Paula Bojsen
    Global Regulatory Compliance Manager
    Holland MI
    United States
    -------------------------------------------




  • 4.  RE: Sunglass Products - Registration & Listing

    Posted 20-Nov-2014 11:08

    Hi Christine,
    For the device listing, you would only one need to do a single device listing as long as all of your models/styles fell within the same broad category description.  I hope this helps.

    -------------------------------------------
    Steven Dowdley RAC
    Atlanta, GA
    United States
    -------------------------------------------