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  • 1.  Establishment registration & Listing post EUA approval

    This message was posted by a user wishing to remain anonymous
    Posted 12-May-2020 09:26
    This message was posted by a user wishing to remain anonymous

    Hello,

    My question is regarding Establishment registration & Listing post EUA approval.
    Is it required to have establishment registration and listing done to sell under a EUA.

    The FDA EUA template says ""FDA recommends that you consider registration and listing your EUA product once you have been issued an EUA."

    Is it a must? Does anyone has a practical experience with FDA expectations on this?

    Any insight is highly appreciated!


  • 2.  RE: Establishment registration & Listing post EUA approval

    Posted 13-May-2020 03:59
    I have not been on the last couple Town Hall meetings, but my only comment is if you are planning to continue selling after the emergency authorisation period has ended or achieving a 510(k) submission to continue selling, if would be recommended to register.  Just note, there is a fee involved for this and any registered facility is subject to FDA inspection.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 3.  RE: Establishment registration & Listing post EUA approval

    Posted 14-May-2020 10:39
    Edited by Christie Hughes 14-May-2020 10:39
    This exact topic was discussed during the May 13th town hall Q&A. FDA stated that they are exercising enforcement discretion with respect to manufacturers being registered and listing the device. However, if the manufacturer is foreign and using a domestic importer, the importer will need to be registered.

    The disclaimer I will put here is that the folks giving this answer were not 100% positive this was correct with respect to importers but believed this to be the case. They suggested to email them at CDRH-EUA-Templates@fda.hhs.gov to get the true answer once they can confer with others internally. Perhaps FDA will add this to their FAQ page once they get a clear answer. Otherwise, you can look for this discussion in the May 13 town hall transcript they will eventually post to their town hall page.

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    Christie Hughes MT(ASCP), MPH
    Consultant
    Austin, TX
    United States
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