FDA Denies CAD/CADt Device 510(k) Exemption Petition

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FDA has denied a 2025 petition that asked the agency to exempt specific radiology computer-aided detection and/or diagnosis (CAD) devices and computer-aided triage and notification devices (CADt) from 510(k) requirements. The agency denial letter says the petition asked for exemption from the premarket notification requirements for the specified devices when:

  • the manufacturer previously obtained a 510(k);
  • for subject CAD devices, the manufacturer must have at least one clearance under the same classification regulation;
  • for subject CADt devices, the manufacturer must have at least one clearance under any of the three classification regulations;
  • the manufacturer implements a “robust post-market plan, transparency, and training measures” as described in the petition; and
  • all existing “special controls, quality systems, establishment registration, and device listing requirements remain in force.”

FDA says it received more than 45 comments on the petition, with a majority opposing the proposed partial exemption, while others supported it. The denial cites a 1/21/1998 Federal Register notice listing factors FDA may consider in determining that a 510(k) is not necessary to assure the safety and effectiveness of a Class 2 device.

The denial concludes that based on the agency’s review of the petition, the pro and con comments received on the petition, and FDA’s assessment of each of the factors for exemption in the Federal Register notice, FDA has determined that the information in the petition does not demonstrate that premarket notification is not necessary to assure the safety and effectiveness of the subject devices that may be covered by the proposed partial exemption.

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