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Does Tissue Bank have to register as device repackager for a combination product?

  • 1.  Does Tissue Bank have to register as device repackager for a combination product?

    This message was posted by a user wishing to remain anonymous
    Posted 07-Jan-2019 17:16
    This message was posted by a user wishing to remain anonymous

    Looking for some clarification on whether or not a tissue bank would have to register with the FDA as a medical device repackager and relabeler for a combination product.  To summarize: we would be sending a packaged finished good medical device to them and then they take their packaged finished good tissue and package them together in a new box and label it.  To clarify: my device company is not touching the tissue and the tissue company is not opening the packaged medical device we send to them.  It's essentially 2 finished goods (one medical device, one tissue) in a box.  My device company would be legal manufacturer.  

    I believe they would have to register as a medical device repackager and relabeler since they are responsible for the final packaging and labeling.  Moreover, the combination product would be registered as a device and, to my knowledge, a facility that packages and labels a device would have to be registered as device repackager and relabeler.  However, the tissue bank is pushing back since they believe they only have to register as a device repackager/relabeler.

    I hope I'm making sense.  Any opinions are welcome.  Thank you!


  • 2.  RE: Does Tissue Bank have to register as device repackager for a combination product?

    This message was posted by a user wishing to remain anonymous
    Posted 08-Jan-2019 09:45
    This message was posted by a user wishing to remain anonymous

    Correction to the last sentence of the second paragraph from my post above: the tissue bank believes they do NOT have to register as a device repackager/relabeler.