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De Novo Submission

De Novo Submission

De Novo Submission allows FDA to establish new product classifications for low to moderate-risk medical devices that meet existing device classifications, thereby significantly easing the regulatory authorization pathway.


The program provides a means route for a new medical device to market. The eligibility for a de novo is based on several factors, such as FDA precedent, level of risk, and the ability to characterize and mitigate risks of the device.


The De Novo submission request provides a marketing pathway to classify novel medical devices for which general controls alone, or general and special controls, provide reasonable assurance of safety and effectiveness for the intended use, but for which there is no legally marketed predicate device.


Devices that are categorized as class I or class II through a De Novo classification request (request) may be sold and, where appropriate, utilized predicates for upcoming premarket notification FDA 510k filings.

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Regulatory Pathway for De Novo Submission

The FDA has two alternatives for submitting a De Novo request for a risk-based assessment of the device’s categorization into class I or class II.

Route 1
In response to a 510(k) filing, after getting a high-level not substantially equivalent (NSE) judgement (i.e., no predicate, new intended use, or different technological attributes that pose separate problems of safety and effectiveness).
Route 2
Upon the requester's conclusion that no legally marketed device exists upon which to establish a finding of significant equivalence (and consequently without first submitting a 510(k) and receiving a high-level NSE determination).

De Novo Classification Request

The applicant will be charged for De Novo requests. Please visit MDUFA User Fees to view the current user fee amounts. Prepare e- copy through e-star and send de novo submission through CDRH Customer Collaboration Portal.


  • When your device is a novel medical device
  • When your device is risk classified from low (Class I) to moderate (Class II) to which no suitable predicates are identified.
  • Otherwise your device is risk classified as Class III
de nova submission

Content and Format of the De Novo Request

The De Novo submission document is the same as the traditional and abbreviated 510(k) submission, but some contents are not required in the de novo document.


  • Section 5: 510k Summary or 510k Statement is not required, because this is not a 510k submission
  • Section 12: Substantial Equivalence Comparison, because a De Novo does not claim equivalence to a predicate.

The I3CGLOBAL team specializes in navigating the FDA De-Novo classification process to ensure clearance for innovative medical devices. Our extensive knowledge of the requirements guarantees a swift De Novo submission, enhancing your prospects for a favourable device classification.

De Novo Submission Process and Timeline

The de novo is the same as 510(k) submission, the electronic copy of the technical file is converted to DVD, and CD and the file should be in PDF format. The FDA receives and reviews the submission and either grants or declines the submission.


On day 1, the FDA receives the submission and assigns the submission number, the number begins with “DEN” followed by a six-digit. This will be included in the acknowledgement letter which will be provided to the submitter.


On day 15, the FDA conducts an acceptance review, where to check if it meets all the acceptability. If the document is not accepted, then it will be put on RTA hold and when the mission information is received FDA will accept it for substantive review.


On day 60, the FDA conducts a substantive review of whether any marketed device of the same type exists, during this review the FDA may identify deficiencies that can be addressed in the interactive review. These deficiencies are mentioned in the additional information request letter that will be sent to the requester. The submitter has to solve the issue within 180 days and respond to the FDA. If failed to respond, the submission will be deleted.


The final action of De Novo’s request: The FDA makes a final decision of either grant or decline,


Grant: The device can be marketed and can be used as a predicate device for 510(k) future submission devices.

Decline: The data provided in the request may be insufficient to determine the risk of the device then the device remains in class III and cannot be legally marketed the device,


Withdrawal of De Novo request: The FDA considering withdrawing the de novo request based on two conditions,

  • The submitter submits a written notice to the FDA to withdraw the de novo request.
  • If the submitter fails to provide additional information response within 180 days, then the de novo submission will be withdrawn.
de novo submission
  • The FDA aims to make a decision on a De Novo request within 150 review days.
  • The number of review days is calculated as the number of calendar days between the date the FDA received the De Novo request and the date of the FDA’s decision, excluding the days a request was on hold for an Additional Information request.

Securing the FDA De Novo classification is essential for innovative medical devices. The I3CGLOBAL team, comprised of strong QARA professionals, excels in steering the De Novo classification journey. We prepare essential documentation, identify comprehensive device test requirements, and manage the entire document management during FDA review and updation. We are committed to guiding you through the complexities of the FDA De Novo submission process.

Frequently Asked Questions

De Novo Standard fee Structure

De Novo classification Request would be $132,464 whereas for small business the fee would be $33,116.

Are any data bases search helps us finalize De Novo is the only choice?

Certainly, you can utilize the FDA database to research before your submission to ensure that your device is not substantially equivalent to an existing device.


  • The Center for Devices and Radiological Health (CDRH)
  • U.S. FDA Device Classification Database
  • Device Classification Under Section 513(f)(2) (De Novo)