Method·August 26, 2026 · 3 min read

Exempt from GMP. Not from complaints.

FDA's classification database marks a product code gmp_exempt_flag: Y and stops there. The regulation behind that single letter carves the exemption back out for exactly two things — records and complaint files — for the codes that carry it.

By Connor Griggs — Regulatory & Quality Strategist

Look up a product code in FDA’s own classification database and one field answers a single yes-or-no question: gmp_exempt_flag. Y means, in openFDA’s own words, exempt due to Good Manufacturing Practice or Quality System requirements under Part 820. Read that as exempt from the quality system, full stop, and the regulation itself disagrees with you — on exactly two things it never let go of.

What the flag is actually shorthand for

The Y is not FDA’s invention for the API; it republishes a designation that predates openFDA by decades — the asterisk FDA’s own classification listings have long used to mark a Class I device as exempt from the manufacturing-controls portion of the quality system regulation, provided it is not labeled or represented as sterile. Most of Part 820’s design, production, and process controls simply do not apply to a code carrying that mark. That is a real, substantial exemption, and for most of what a quality system regulation asks a manufacturer to do, it holds.

The two things the exemption was never written to reach

FDA’s own exemption language has always carried a carve-back, not a footnote: even a GMP-exempt Class I device stays bound by the regulation’s requirements for records and for complaint files. Before the 2026 Quality Management System Regulation, those two obligations sat in 21 CFR 820.180 and 820.198 by name, sitting outside the exemption while everything around them fell inside it. The QMSR’s own technical-amendments notice, effective the same February 2, 2026 date as the rule itself, updated that cross-reference rather than retiring it — the non-exempt activity for these codes now points to 21 CFR 820.35, Control of records, the QMSR’s home for the same two duties. The number moved. The carve-back did not.

“Exempt” was never one boolean underneath the boolean the database actually stores. It was always exempt from most of the regulation and bound by a specific, named piece of it — the flag just doesn’t say which piece.

Why that specific carve-back, and not some other one

The logic is not arbitrary. A complaint file is where a manufacturer’s first knowledge of a problem with a marketed device has to land, investigated and recorded, whether or not that device was ever subject to design controls or process validation in the first place. Exempting a low-risk device from proving how it was built was never the same question as exempting it from listening when something goes wrong after it ships. FDA drew that line decades ago and the QMSR’s technical amendments preserved it on purpose, moving the citation without touching the substance.

The practice

A product profile built from a single flag is accurate exactly as far as the flag goes, and no further. Reading gmp_exempt_flag: Y as “no quality-system obligation on this code” overstates what FDA’s own database claims. The honest reading is narrower and more specific: most of Part 820 does not reach this code, and 820.35’s records and complaint-file requirements still do, regardless of the flag. Confirming which of a portfolio’s product codes carry that mark, and treating the mark as a partial exemption rather than a complete one, is a five-minute check against FDA’s own classification record.

FDA Radar’s own onboarding lookup reads this same field — the one that turns a product code into the profile a portfolio is built from — and renders it as a single “GMP exempt” tag, exactly as specific as the flag itself and no more. Which obligations survive a specific exemption for a specific device is a question for the regulatory professional reading the full record, never a determination this product makes for you; see our editorial standards for the line between what a field states and what a person concludes from it.

Regulatory intelligence, not regulatory advice. This post describes method and published FDA records as of its date; decisions about a specific device belong with your regulatory professional.

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The manufacturer who owns no factory
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GLP covers the safety study, not the device
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Part 11 governs the copy, not the duty.
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A K-number isn't always a 510(k)
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Approved once. Reported every year.
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A discussion paper isn't guidance
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The sponsor proposes risk. The IRB decides.
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The flag marks the reviewer, not the result
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Call it fifteen. File it in thirty.
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The recognition number isn't the list number
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The letter to file isn't in the guidance
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The PMA preempts. The 510(k) doesn't.
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Cleared doesn't code. Coded doesn't cover.
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Exempt from 510(k). Restricted anyway.
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Exempt from registration. Not from 510(k).
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Right to try reaches drugs, not devices
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The 510(k) clears the range, not the fit
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The hospital's duty runs to the maker, not FDA.
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The predicate study isn't the waiver study.
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No clinical hold for an IDE. Only disapproval.
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A CFG can cover a device that never came here.
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The symbol skips text. The glossary can't.
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The label clears 812.5. The flyer doesn't.
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A 510(k) can change hands. No rule says how.
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A missed renewal is two violations, not one
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Drugs expire by rule. Devices by choice.
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Denied the petition. Not the outcome.
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Starting a committee is public. Renewing isn't.
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A recall closes. A radiation refund doesn't.
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The trial is public. The IDE isn't.
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A PMA withdrawal pays back. A 510(k) doesn't.
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Interoperable is a design term, not a class.
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The category is new. The 510(k) record isn't.
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The device is cleared. Not the room.
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Classified in 2011. Excluded in 2016.
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The law reached devices. The guidance hasn't.
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The label says RUO. FDA reads intent.
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Humanitarian. Not always nonprofit.
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The certification has a one-year tail
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The code changed. The failure didn't.
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Skip has a ceiling. Search after doesn't.
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Reviewed together. Decided separately.
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Class III. Not called for PMA.
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The standard for the wire, not the device
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A reference device isn't a predicate
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A predicate checklist nobody has to follow
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The pathway that skips the predicate
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A network FDA funds, not FDA runs
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Panel-recommended. Not yet classified.
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The pilot that needed a statute
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A committee no clearance ever names
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Never cleared here. Exported anyway.
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Built for drugs. Silent on devices.
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A significant decision carries its own clock
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The guidance that went back to draft
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Breakthrough crosses centers. TAP does not.
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Two lists decide who reviews your 510(k)
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The reprocessor holds the 510(k)
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The Rx symbol never reaches the record
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The disqualification list names no device
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The summary FDA writes, not the sponsor
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A missed MDR is misbranding, not a defect
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Two names on one registration, two jobs
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A K-number is public. The other isn't.
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Exempt covers the type, not the use
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Recognized. Not published.
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The supplement got eSTAR. The PMA did not.
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Congress ordered a guidance, not a rule
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AI-enabled is a list. Not a field.
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The companion diagnostic list changed its name
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The master file neither of you can read
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The condition inside the approval order
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The repair FDA calls manufacturing
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Vacated in March. Filed in September.
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Classified. Not waived.
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Emergency use isn't defined in Part 812
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The two-year inspection clock is gone
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The PMA clock starts at the last module
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The Q-Sub that doesn't buy you more time
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Lapsed and revoked end an EUA differently
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A recall strategy has a grade. openFDA doesn't.
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A granted De Novo becomes a predicate.
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The lab is accredited. Not the device.
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Breakthrough is law. STeP is a guidance.
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MDSAP replaces routine. Not for-cause.
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No field on a 510(k) says what it treats
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Discretion is a policy. Exclusion is a statute.
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Designated by one office. Approved by another.
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MedSun sits beside MAUDE, not inside it
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The five-unit device never gets a K-number
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Meeting the criteria isn't a tracking order
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The PMA clock doesn't stop at approval
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The K-number doesn't track today's device
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A MAUDE report proves it was filed
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Not every MDR starts with the manufacturer
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Completed. Not terminated.
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The device-ban list has three entries
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The UDI exception has its own deadline
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MDUFA VI is being negotiated in public
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The inspection manual changed, not the rule
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The count Congress had to legislate
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The small-business rate isn't retroactive
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A detention order has no docket to read
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PMA approvals moved off the Federal Register
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A citizen petition names names
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A market withdrawal isn't a recall
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Not every device letter comes from CDRH
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Closed on one device. Open on the rest.
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No IDE is confirmed until the PMA is
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The remedial-action call sets the clock
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Jurisdiction is a letter, not a field
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An address is not a footprint
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The final rule that isn't final yet
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The special controls aren't in the record
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The notify list isn't the shortage list
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A constraint can't be skipped. A script can.
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No cron sends this. A person does.
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Corrected, not rewritten
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Quiet is a finding, not a default
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The summary is public. The statement isn't.
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A competitor's 513(g) leaves no trace
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An empty response field proves nothing
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A petition is public. Its outcome isn't.
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The panel is a category, not a meeting
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An accessory carries its own classification
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A TPLC report is a category, not a device
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A 522 order is a question, not a verdict
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A PCCP change leaves no new record
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Not every signal becomes a recall
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eSTAR did not remove the acceptance check
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An early alert has no recall number yet
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A consent decree isn't a database row
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The record has no cybersecurity field
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Classification Change is not one event
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Publication date is not effective date
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One event. Many recall numbers.
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Quantity is a sentence, not a number
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How a firm told you is a field too
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A RIN outlives the document number
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The docket ID is not the comments
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The 510(k) record doesn't name the predicate
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The 510(k) FDA didn't review first
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The letter FDA doesn't have to post
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Cleared doesn't say which track it took
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The clock stops. The calendar doesn't.
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Why a guessed match never reaches you
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The standards list never names a device
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The guidance isn't in the Federal Register.
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Filtered. Not discarded.
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There are two recall databases, not one
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Breakthrough status is confidential by law
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One MAUDE report is not one malfunction
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A supplement number is not a track
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Cleared is not approved
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Nationwide doesn't mean your building
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Not every correction reaches FDA
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Registered. Not reviewed.
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Contact ODE is not a pathway
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Almost no recall is FDA-mandated
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openFDA is free. It is not unlimited.
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GUDID stores the model. Not the box.
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Detention doesn't need a warning letter
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A Class I device, a Class I recall
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21 CFR 820 didn't move. Its contents did.
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The product code that doesn't exist yet
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The classification posts. The 483 behind it doesn't.
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A recall has three dates, and the pipeline had to pick one
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The count is real. The rate is not.
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The firm on the record is not the firm on the box
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Low confidence is an instruction, not a hedge
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The same company, spelled three ways
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A device that was never a medical device
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Your regulation has a decimal. FDA's watch doesn't.
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Three letters is too short to search for
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Most warning letters never close
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The guidance that skipped the draft
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Ongoing, as of when?
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The least interesting fact in a 510(k)
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No recall arrives with a product code attached
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The warning letter has two dates
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