| Regulatory Authority | Food and Drug Administration (FDA) | Decentralized: Notified Bodies, supervised by national authorities |
| Risk Classes | Class I, II, III | Class I, IIa, IIb, III |
| Class I Approval Process | Registration + General Controls (GMP per 21 CFR 820 / QMSR) | Self-certification by the manufacturer (except for sterile products and measuring devices) |
| Class II Approval Process | 510(k) Premarket Notification: Demonstration of substantial equivalence | Conformity assessment by a Notified Body (Classes IIa and IIb) |
| Class III Approval Process | Premarket Approval (PMA): full clinical trial required | Conformity Assessment by a Notified Body + consultation with the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) |
| Clinical Data | Class I: not required Class II: usually based on published literature Class III: clinical trial | Clinical evaluation mandatory for all classes (MDR Annex XIV, MEDDEV 2.7/1 Rev. 4) |
| Quality Management System | QMSR (21 CFR 820) to be aligned with ISO 13485 starting in 2026 | ISO 13485 (not legally required, but de facto standard) |
| Post-Market Surveillance | Medical Device Reporting, 21 CFR 803/806 | PMS plan, PSUR/PMSR, PMCF; mandatory for all classes (MDR Articles 83–86) |
| Registration Database | FDA 510(k) Database, GUDID | EUDAMED (mandatory as of May 26, 2026) |
| Authorized Representative | US Agent) (for foreign manufacturers) 21 CFR 807.40 | EU Authorized Representative (for non-EU manufacturers) MDR Art. 11 |
| Typical Processing Time | 510(k): 3–12 months PMA: 1–3 years | Class I: 3–6 months Class IIa–III: 12–36 months (depending on the Notified Body) |
| Validity of Approval & Recertification | Indefinite (provided there are no product changes) | Certificates are generally valid for 5 years |
| Innovation Support | Breakthrough Devices Program | No structured fast-track system |
| Labeling | FDA registration number, UDI (21 CFR 801) | CE Marking, UDI, EUDAMED registration (MDR Art. 10, Annex I) |