The standard's recognized. One clause isn't.
FDA's Recognition List 066 folded the newest edition of its most-cited biocompatibility standard into the recognized consensus standards database in August 2026 — then named two clauses it would not recognize, one of them in full, because FDA's own risk-management standard already claims that ground.
By Connor Griggs — Regulatory & Quality Strategist
FDA recognizing the current edition of its most-cited biocompatibility standard reads, at a glance, like a clean adoption — the agency catching up to where the standards body already is. The record it actually published says something narrower: recognized, except for two named clauses, one of them in full.
What recognition number 2-313 actually covers
Recognition List Number: 066, the Federal Register notice FDA published August 24, 2026, assigned ISO 10993-1:2025 — the sixth edition of Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process — its own entry in FDA’s Recognized Consensus Standards Database: recognition number 2-313, succeeding the fifth edition’s 2-258. Nothing about that notice recognizes the new edition as a single document. The database entry it created lists exclusions by clause number, and a Declaration of Conformity citing the standard inherits the exclusions along with it.
The clause FDA already owns
Clause 6.9, “Biological risk estimation,” is excluded in full. FDA’s stated reason is specific: the clause’s own risk-scoring method conflicts with ISO 14971:2019, the device risk-management standard FDA separately recognizes and that this product’s own posts have already covered as the governing risk-management text. Where two recognized standards disagree about the same job, FDA did not split the difference — it subtracted the newer clause and left the standard it already relies on untouched. A narrower exclusion sits beside it: the phrase “consumer products” in Clause 6.5.11.3 doesn’t carry FDA’s recognition either, word-level, inside a clause that is otherwise recognized.
FDA recognizes a standard by clause, not by title page. A Declaration of Conformity that cites the document and skips the database entry is citing more than FDA actually recognized.
The old edition still works
This is a transition, not a cutover. FDA will keep accepting a Declaration of Conformity built on the 2018 fifth edition — recognition 2-258 — through July 1, 2029. A submission in front of a sponsor today has a real choice of edition, not a forced migration, for close to three more years.
The practice
Recognition doesn’t retire FDA’s own guidance layered on top of either edition. Use of International Standard ISO 10993-1, FDA’s current guidance on applying the standard, still asks for material-mediated pyrogenicity testing on devices with prolonged or permanent mucosal or breached-surface contact — an endpoint the standard’s own test-selection tables don’t carry, in either edition. Checking the recognition database’s own exclusions before a submission cites a standard is a mechanical step; whether a specific device’s biocompatibility file still needs something the standard doesn’t ask for is a judgment for the toxicologist or regulatory professional on that file, never a determination this post makes for them.
FDA Radar doesn’t monitor the Recognized Consensus Standards database today — see what we monitor and what we deliberately don’t. Until a reliable feed exists for it, reading the live database entry, clause by clause, stays a manual step ahead of every submission that cites one.
Primary sources
- Federal Register — Modifications to the List of Recognized Standards, Recognition List Number: 066
- FDA — Recognized Consensus Standards Database
- FDA — Use of International Standard ISO 10993-1, "Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process" (guidance)
- FDA Radar — the recognition number isn't the list number
- FDA Radar — what we monitor and how often
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.