Guide on Microneedling Product Regulatory Considerations
FDA has issued a final guidance on Regulatory Considerations for Microneedling Products. The document is intended to assist industry in understanding when a microneedling product is a device for regulatory purposes. It also provides information on the regulatory pathway to market for microneedling devices for esthetic use. According to the agency, microneedling products are regulated as devices if they are intended to diagnose disease or other conditions, or cure, mitigate, treat, or prevent disease, or to affect the structure or function of the body. For example, a manual microneedling product with short, blunt needles is a device requiring a 510(k) if the firm makes claims that the product s intended to exfoliate, give skin a luminous look, stimulate collagen production, and treat wrinkles, FDA says.
The guidance also gives examples of a microneedling product that is not a device, such as one with short, blunt needles or “micro-protrusion” tips that do not penetrate living layers of skin and for which the firm claims that the product is intended to facilitate skin exfoliation. A microneedling product with short, densely packed needles that are not designed to penetrate living layers of skin and for which the firm claims that the product is intended to give skin a smoother look and feel would also not be considered a device, FDA says.