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Kayra Patent · International markets

FDA Processes: Food, Cosmetics and Medical Device Distinctions

FDA-related market entry steps depend on product classification and the business's role. Facility registration, product listing and any required marketing authorisation are not interchangeable.

Questions for your situation

Can a product be called FDA-approved after obtaining a registration number?

Registration or listing alone is not product approval. FDA specifically does not issue compliance certificates for cosmetic registration and listing. Describe the actual process completed. A consultant's registration summary must not be presented as government product safety or marketing approval.

Is one registration enough for a company exporting both food and cosmetics?

Assess each category's registration systems and responsible roles separately. Check facility activities, product categories and applicable exemptions for each process. An account or number in one area does not complete another. Prepare separate product, site and US-party information at the outset.

Who is responsible for facility registration when cosmetics are contract-manufactured?

Distinguish the manufacturer or processor's facility duties from product listing by the responsible person named on the label. Assess exemptions separately. Data-sharing arrangements should cover formulas, facility identity and updates. A contract cannot arbitrarily redefine responsibilities established by law.

Does medical device registration replace 510(k) or another marketing process?

Determine the marketing route from intended use and classification. Where a premarket process is required, establishment registration and device listing do not complete it. Match the relevant decision with the listed device's identity. An EU CE file does not automatically produce the same US outcome.

Are registration costs the same for all product categories?

Separate official fees, representation where relevant, technical preparation and application support. Check current FDA device establishment fees and possible exemptions directly in the applicable schedule. Do not transfer another category's fee rules. Timing also depends on missing technical information and other required processes.

Can the old number still be used after a facility, formula or US representative changes?

Identify affected registrations and listings and follow category-specific update and renewal rules. An old number does not demonstrate current compliance. Plan handover of notifications and account access when representatives change. Assess sales effects separately where suspension or safety issues arise.

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