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  • 1.  FDA registrations as Contract manufacturer and Legal Manufacturer

    This message was posted by a user wishing to remain anonymous
    Posted 03-Apr-2024 09:09
    This message was posted by a user wishing to remain anonymous

    Is it possible for a 510(k) cleared device to only have a registration done by its contract manufacturer (where the FDA website lists the company as Contract manufacturer) while the Legal manufacturer (510(k) holder) is not registered with the product?



  • 2.  RE: FDA registrations as Contract manufacturer and Legal Manufacturer

    This message was posted by a user wishing to remain anonymous
    Posted 03-Apr-2024 16:26
    This message was posted by a user wishing to remain anonymous

    The manufacturer or specification developer has to list it first, then the contract manufacturer can add it. I don't know what happens to the CM's listing if the manufacturer de-lists it.

    https://www.fda.gov/medical-devices/device-registration-and-listing/frequently-asked-questions-about-new-device-registration-and-listing-requirements#foreign




  • 3.  RE: FDA registrations as Contract manufacturer and Legal Manufacturer

    Posted 04-Apr-2024 03:55

    Hello Anon,

    In a simple answer no, because a Contract Manufacturer has different roles as defined by the FDA, being an entity which is only manufacturing a medical device for another company.  There needs to be a company with their establishment registered as the Manufacturer.  The Manufacturer then needs to list the product(s) on the Medical Device Listing.  As the previous poster provided, then the Contract Manufacturer can add to their listing.  These are not publicly available to be seen on the FDA's website, but on the "backside" of the FDA's database these are linked together.  The Contract Manufacturer also need to have their establishment registered, because when the Manufacturer lists their medical device, there is a selection of who makes the device where then the Contract Manufacturer can be searched and then selected.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Principal Strategy Consultant
    NAMSA
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