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  • 1.  accessory vs. parts/components

    This message was posted by a user wishing to remain anonymous
    Posted 03-Mar-2020 08:59
    This message was posted by a user wishing to remain anonymous

    Hi all, 
    although I read several definitions, posts, and the FDA guidance regarding accessories, I still struggle with the fine line between accessory vs. parts.
    Can somebody provide some practical guidance regarding the difference between the two? Initially I thought that if something is "optional", then it is an accessory, otherwise it is a component. However, in the guidance there is the following sentence that dismantles my theory:
    "Thus, if the device is intended to support, supplement, and/or augment the performance of one or more parent devices, we intend to consider the device to be an accessory whether it is required or optional."

    Also, what about mobile tablets or smartphones etc. completely dedicated to the parent device? Are these considered accessories? 
    Thanks in advance


  • 2.  RE: accessory vs. parts/components

    Posted 03-Mar-2020 11:37
    Sometimes the line is fine, sometimes more clear.
    The FDA guidance is good, but necessarily general.
    It's hard to apply it to your products without knowing what kind of thing they are.
    Here's a distinction you might try on your product... If it's physically separate from the parent device, it's not a component of it.

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    Anne LeBlanc
    Manager, Regulatory Affairs
    United States
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  • 3.  RE: accessory vs. parts/components

    Posted 04-Mar-2020 09:08
    Accessories can be required or optional for use with the device.  Parts or components are integral parts of the main device.  I am not sure there is a clear definition anywhere, even for non-medical products but generally an accessory is something that can be detached used with the device or not.  A part or component is something integral to the device meaning the device will not operate without the part or component.  The device can still operate and perform with or without the accessory.  But even that there is some question whether an accessory is required or not in order to make the device work.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: accessory vs. parts/components

    Posted 09-Mar-2020 11:37
    Thank you both for your kind answer.
    How would you consider accessories like mobile devices (smartphones or tablets) or battery chargers? which type of regulatory requirements apply to this type of products?
    Thanks again

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    Maria Ida Iacono
    Paris
    France
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  • 5.  RE: accessory vs. parts/components

    Posted 10-Mar-2020 03:42
    I think a thin fine line between accessories on the one hand and parts/components on the other hand is almost impossible to decide. The way Richard tries to explain it appeals to me, he makes the difference in 'to operate' to 'perform the intended use'.

    A medical device may need a keyboard to operate, the keyboard in itself is not assisting in performing the intended use.
    A mobile device and the operating system are needed to operate with a medical device and are parts/components; an specific app is assisting the medical device to achieve the intended use and is an accessory.

    From a long time ago I remember a discussion about a infrared lamp for heat treatment and pain relief. The device was nothing more than the somewhat bulky lamp,a lamp socket, a holder and some wiring and a wall plug. The manufacturer argued that the lamp was to be considered as the medical device and the rest were parts/components, whereas the regulator argued that the whole 'system' was a medical device, since that is how the 'system was sold to the users. The issue remained unresolved, unfortunately.

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    Peter Reijntjes
    Principal Consultant Regulatory & Quality Affairs
    Arnhem
    Netherlands
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