Method·August 5, 2026 · 3 min read

Registered. Not reviewed.

FDA's device registration and listing record can carry a 510(k) or PMA number — typed in by the company itself, once a year, on a filing FDA's own rule says does not double as a review of that number.

By Connor Griggs — Regulatory & Quality Strategist

A device’s entry in FDA’s establishment registration and listing database can carry a 510(k) number, a PMA number, or a De Novo number right there in the record. It reads like confirmation — FDA has this device, FDA cleared it this way. What’s actually in that field is whatever the owner or operator typed into the form, once a year, and FDA’s own rule says the registration process that field lives inside does not check it.

What Part 807 actually asks for

21 CFR Part 807requires every device manufacturer and initial importer to register its establishment and list its devices with FDA, renewed every year in the same window — October 1 through December 31. 21 CFR 807.25spells out what the listing has to include, and for a device that needs marketing authorization before sale, that’s a premarket submission number: a 510(k), De Novo, PMA, PDP, or HDE number, supplied by the owner or operator itself. Nothing in Part 807 has FDA cross-check that number against its own clearance or approval records at the moment the listing is filed. The listing process is a filing requirement, not a review.

The rule that says so, in FDA’s own words

FDA doesn’t leave this to inference. 21 CFR 807.39, titled Misbranding by reference to establishment registration or to registration number, states plainly that registering an establishment or holding a registration number does not in any way denote approvalof the establishment or its products, and that any representation creating the impression of official approval because of registration is misleading and constitutes misbranding. The rule exists because the confusion it corrects is common enough to need its own section — a registration number looks exactly like the kind of thing an agency issues after checking something.

What a listing record is actually good for

None of this makes the registration and listing database useless — it is often the fastest public confirmation that a given firm makes a given device at all, and which product code and regulation number the firm itself associates with it. It is a lead, not a verified fact. The premarket number in a listing is exactly as current as the last annual filing, entered by the company describing its own device, and a lookup that treats it as equivalent to the decision record in FDA’s 510(k) or PMA database is trusting a self-report where a primary source exists a search away.

The practice

Treat a premarket number found in a registration and listing record as a pointer, not a citation. Confirm it against FDA’s own clearance or approval database before it goes into a predicate list, a competitive teardown, or anything else that will be read as fact. That one extra lookup is the difference between citing FDA and citing what a company told FDA about itself — regulatory intelligence and method, never regulatory advice, and the distinction matters most exactly where the two records might disagree.

Practice
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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Least burdensome changes the ask, not the bar.
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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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Exempt from GMP. Not from complaints.
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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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Contact ODE is not a pathway
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Almost no recall is FDA-mandated
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FDA's device names read like a card catalog
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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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FDA's warning letters, addressed by column number
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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 deadline that doesn't email you
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The warning letter has two dates
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How to monitor FDA without drowning
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Your predicate was recalled. Now what?
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Why no item reaches you without a human