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U.S. Department of Health and Human Services

Medical Device Exemptions 510(k) and GMP Requirements

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Following is a breakdown of 510(k) exempt and Good Manufacturing Practice (GMP)/Quality System exemptions listed by device class. All devices in this list are 510(k) exempt unless further qualified by a footnote. Only devices annotated by (*) are also exempt from GMP except for general recordkeeping requirements and compliant files.

Class I Devices

FDA has exempted almost all class I devices (with the exception of Reserved Devices from the premarket notification requirement, including those devices that were exempted by final regulation published in the Federal Registers of December 7, 1994, and January 16, 1996. Some 510(k) exemptions annotated with "\#\" are with certain limitations as noted in the footnotes. It is important to confirm the exempt status and any limitations that apply with 21 CFR Parts 862-892. Limitations of device exemptions are covered under 21 CFR xxx.9, where xxx refers to Parts 862-892.

If a manufacturer's device falls into a generic category of exempted class I devices as defined in 21 CFR Parts 862-892, a premarket notification application and FDA clearance is not required before marketing the device in the U.S. However, these manufacturers are required to register their establishment and list the generic category or classification name. Registration and listing information is submitted by using FDA’s Unified Registration and Listing System (FURLS)/ Device Registration and Listing Module (DRLM) at: https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/HowtoMarketYourDevice/RegistrationandListing/ucm053185.htm

IMPORTANT NOTE: Only the class I devices with an asterisk (*) are also exempted from the GMP regulation, except for general requirements concerning records (820.180) and complaint files (820.198), as long as the device is not labeled or otherwise represented as sterile.

Class II Devices

The Food and Drug Administration (FDA) has also published a list of class II (special controls) devices (those devices are annotated as "(II)"), subject to certain limitations, that are exempt from premarket notification requirements under the Food and Drug Administration Modernization Act of 1997 (FDAMA) or the 21st Century Cures Act of 2016 (Cures Act). FDA believes that these exemptions will relieve manufacturers from the need to submit premarket notification submissions for these devices and will enable FDA to redirect the resources that would be spent on reviewing such submissions to more significant public health issues. FDA is taking this action in order to meet requirements of FDAMA and the Cures Act. Class II devices are annotated "(II)". Please note that class II devices are NOT exempt from GMP requirements.

888.1100 arthroscope. 70  
888.1240 ac-powered dynamometer. (II)  
888.1250 nonpowered dynamometer.  
888.1500 goniometer. (II)  
888.1500 goniometer.  
888.1520 nonpowered goniometer.  
888.3000 bone cap.  
888.4150 calipers for clinical use.  
888.4200 cement dispenser.  
888.4210 cement mixer for clinical use.  
888.4220 cement monomer vapor evacuator.  
888.4230 cement ventilation tube.  
888.4300 depth gauge for clinical use.  
888.4505 orthopedic surgical instrumentation designed for osteochondral implants with press-fit fixation. (II)  
888.4540 orthopedic manual surgical instrument.  
888.4580 sonic surgical instrument and accessories/attachments. (II)  
888.4600 protractor for clinical use.  
888.4800 template for clinical use.  
888.5850 nonpowered orthopedic traction apparatus and accessories.  *
888.5890 noninvasive traction component.  *
888.5940 cast component.  *
888.5960 cast removal instrument.  
888.5980 manual cast application and removal instrument.  *


70 Only the following manual arthroscopic instruments: cannulas, currettes, drill guides, forceps, gouges, graspers, knives, obturators, osteotomes, probes, punches, rasps, retractors, rongeurs, suture passers, suture knotpushers, suture punches, switching rods, and trocars, are 510(k) exempt.