FDA Regulatory Pathway

FDA 510(k), De Novo
& PMA Submissions

Navigating FDA pre-market submissions requires deep knowledge of both the regulatory framework and the technical evidence standards. We prepare submissions that are complete, well-documented, and built to clear — not just filed and hoped for.

510(k) Submissions De Novo Classification PMA Applications 21 CFR Part 820 QSR FDA Inspection Prep Class I · II · III
FDA Pathways

Which Pathway Is Right for Your Device?

FDA pathway selection is one of the most consequential early decisions in device development. Choosing wrong adds 12–18 months and significant cost. We get it right from the start.

510(k)

Premarket Notification

The most common pathway for Class II devices. Requires demonstrating substantial equivalence to a legally marketed predicate device. We identify the strongest predicate strategy, structure the SE argument, and manage the full submission lifecycle.

TYPICAL TIMELINE: 6–12 MONTHS FROM SUBMISSION
De Novo

Novel Classification

For novel Class II devices without an appropriate predicate. De Novo creates a new device classification and establishes the special controls future 510(k)s will reference. More rigorous than 510(k) but far less demanding than PMA.

TYPICAL TIMELINE: 12–18 MONTHS
PMA

Premarket Approval

Required for most Class III devices — implantable cardiac devices, neurological stimulators, high-risk diagnostics. Requires valid scientific evidence (typically clinical data) demonstrating safety and effectiveness. We build and manage the full PMA strategy.

TYPICAL TIMELINE: 18–36+ MONTHS
FDA Submission Services

End-to-End Submission Support

From device classification analysis through FDA response management, we handle every component of a complete, first-time-ready FDA submission.

Device Classification Analysis

Definitive classification determination under 21 CFR Parts 862–892, product code identification, and pathway recommendation before any resources are committed.

Predicate Strategy

Identification and analysis of the strongest predicate device(s) for a 510(k), including SE argument structure for intended use and technological characteristics.

Full Submission Preparation

Every section of the 510(k), De Novo, or PMA — device description, indications, substantial equivalence, performance testing, labeling, and eCopy — written and formatted to FDA standards.

FDA Response & Deficiency Management

If FDA issues an Additional Information (AI) request or deficiency letter, we respond fast and comprehensively — addressing each point with targeted technical evidence.

Quality System (21 CFR Part 820)

QMS design and implementation aligned to FDA's updated Part 820, which now incorporates ISO 13485. SOPs, design history files, CAPA, and complaint handling built submission-ready.

Timeline Reality Check

What Actually Delays Submissions

Most submission delays aren't caused by FDA review time — they're caused by incomplete or poorly structured submissions that trigger AI requests. We see the same issues repeatedly:

Weak predicate comparison — insufficient SE argument
Missing or incomplete performance testing data
Labeling that doesn't match the intended use statement
Biocompatibility gaps — wrong ISO 10993 evaluation
Electrical safety testing to wrong standard or edition
Software documentation (IEC 62304) missing or incomplete

Our submissions are structured to anticipate and pre-empt every one of these. The goal is a single review cycle — not a deficiency letter followed by months of back-and-forth.

Ready to start your FDA submission?

Book a free discovery call — we'll assess your device and recommend the right pathway and strategy.

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