Title
New Procedure for Variations in Medical Device CPR
Law
Fda Circular No. 2017-014
Decision Date
Jun 8, 2018
FDA Circular No. 2017-014 streamlines the application process for variations in the Certificate of Product Registration for medical devices, allowing companies to submit a single variation application for multiple changes while enhancing regulatory efficiency.

Scope of the Circular

  • The Circular applies specifically to all entities within the medical device industry.
  • It covers all variations, amendments, or changes made to the CPR issued by the Center for Device Regulation, Radiation Health, and Research (CDRRHR).

Procedures for Filing Variation Applications

  • The application for variation of medical device product registration follows guidelines in FDA Circular No. 2016-010 but introduces new procedures under CDRRHR's Licensing and Registration Division.
  • Only one variation application per transaction is permitted irrespective of the number of CPRs held by the applicant.
  • Acceptable variations include:
    • Change of legal manufacturer, exporter, and manufacturer if the name and address remain consistent across all CPRs.
    • Change of importer and distributor.
    • Change of location/address of importer and distributor.
    • Change of manufacturer’s address.
    • Change or addition of sterilization sites.
    • Change of label design.
    • Change of Instruction for Use (IFU).
    • Other changes uniform across all CPRs.
  • Fees and charges are computed based on the number of CPRs affected by the amendment.
  • The applicant must submit a comprehensive list of all CPRs to be amended in both PDF and Word formats, including exact product descriptions and registration numbers.
  • Notification of approval of changes will be provided via letter.
  • These procedures apply to all variation applications received from July 22, 2016, onward.

Post-Approval and Re-Issuance

  • All approved changes will be incorporated into the CPR during the product registration renewal.
  • Companies may request re-issuance of the CPR to reflect changes immediately, subject to payment of a re-issuance fee.

Repealing Clause

  • Any prior issuances conflicting with this Circular are repealed, rescinded, or modified accordingly.

Separability Clause

  • If any provision or its application is declared invalid, the rest of the Circular’s provisions will remain effective and enforceable.

Effectivity

  • The Circular becomes effective fifteen (15) days after approval, ensuring timely implementation of the new procedures.

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