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Product Codes & Regulation Numbers

US-unique

The FDA product code system is a US-specific classification mechanism. Every regulated device type has a unique three-character product code that links it to a specific regulation, panel, class, and submission type.


What is a product code?โ€‹

A product code is a three-character alphanumeric identifier (e.g., FRN, DQO, IYO) assigned by FDA to a specific device type. It appears in:

  • FDA's Product Classification Database
  • 510(k) and PMA submission databases
  • GUDID device records
  • FDA's MAUDE adverse event database

What information a product code tells youโ€‹

For each product code, FDA's database provides:

FieldWhat it means
Device nameThe formal name of the device type
Device classI, II, or III
21 CFR PartThe applicable classification regulation
Submission typeExempt, 510(k), PMA, or De Novo
Review panelThe advisory panel (e.g., Cardiovascular, Radiology)
Regulation numberSpecific section within the 21 CFR Part
GMP exemptWhether QMS (QMSR) applies
Third party reviewWhether abbreviated third-party 510(k) review applies

How to find your product codeโ€‹

  1. Go to FDA Product Classification Database
  2. Search by:
    • Device name โ€” use descriptive terms, not brand names
    • Product code โ€” if you already know it
    • 21 CFR section โ€” if you know the regulation
    • Review panel โ€” browse all devices in a specialty
  3. Review the results and identify the most applicable product type

Using product codes in submissionsโ€‹

When filing a 510(k) or PMA, you must correctly identify the product code. FDA uses it to:

  • Route the submission to the correct review team
  • Apply the appropriate performance standards and special controls
  • Determine applicable MDUFA review timelines

Selecting an incorrect product code is a common technical deficiency that can delay acceptance of a 510(k).


When no product code existsโ€‹

If your device type has no existing product code, you have two main options:

  1. De Novo classification request โ€” creates a new product code, device type, and classification order
  2. Contact CDRH via a Q-submission (pre-sub meeting) to discuss classification before submitting

Official resourcesโ€‹