Medical device manufacturers face various regulatory hurdles when bringing their products to market. One significant aspect is the device user fees, which are crucial for maintaining facility registrations and submitting pre-market and post-market reports. As we move into the fiscal year 2025, starting October 1, 2024, through September 30, 2025, it’s essential to understand the new fee structure and its implications for your business.
Understanding Device User Fees FY 2025
Medical device user fees are payments that manufacturers and distributors must make to the FDA for the registration of their facilities and the review of their submissions. These fees are critical for ensuring that the FDA can effectively review and monitor medical devices, ensuring their safety and efficacy for public use.
User Fee Type | FY 2024 Fees | FY 2025 Fees |
Establishment Registration | $7,653 for all establishments | $9,280 for all establishments |
PMA submission for high-risk devices | $483,560 / $120,890 for small businesses | $540,783 / $135,196 for small businesses |
De Novo submissions for moderate-risk devices | $145,068 / $36,267 for small businesses | $162,235 / $40,559 for small businesses |
510(k) submissions for low- and moderate-risk devices | $21,760 / $5,440 for small businesses | $24,335 / $6,084 for small businesses |
The Significance of Device User Fees
Device user fees play a pivotal role in the regulatory process. These fees fund the FDA’s pre-market review, post-market surveillance, and other critical activities. Understanding these fees is essential for budgeting and planning, especially for new manufacturers who may be surprised by these additional costs.
Establishment Registration Fees
FY 2025 Fee: $9,280
All medical device establishments must pay this annual fee to register their facilities with the FDA. This fee has increased from $7,653 in FY 2024, reflecting the growing costs associated with regulatory oversight.
PMA Submissions for High-Risk Devices
FY 2025 Fee: $540,783
Small Business Fee: $135,196
Pre-market Approval (PMA) submissions are required for high-risk medical devices. These devices undergo a rigorous review process to ensure their safety and effectiveness. The fee for PMA submissions has increased significantly from FY 2024, impacting both large and small businesses.
De Novo Submissions for Moderate-Risk Devices
FY 2025 Fee: $162,235
Small Business Fee: $40,559
De Novo submissions are for moderate-risk devices that do not have a predicate device. This process allows manufacturers to establish new device classifications. The fees for De Novo submissions have also seen an increase, reflecting the extensive review process required.
510(k) Submissions for Low- and Moderate-Risk Devices
FY 2025 Fee: $24,335
Small Business Fee: $6,084
The 510(k) submission process is for devices that are substantially equivalent to a legally marketed device. This is the most common submission route for medical devices. The fees for 510(k) submissions have risen, affecting both large and small businesses.
The Impact on New Device Manufacturers
Many new device manufacturers are often taken aback by the user fees required for bringing a product to market. These fees are in addition to the substantial investments needed for research and development, manufacturing, and preparing regulatory submissions. Understanding and planning for these fees are crucial for the financial health and regulatory compliance of any medical device company.
Strategies for Managing Device User Fees
- Budgeting and Financial Planning: Incorporate user fees into your financial planning from the outset. This helps in avoiding unexpected financial strain.
- Utilize FDA Resources: The FDA provides resources and guidance to help manufacturers understand and navigate the fee structure and submission processes.
- Consider Small Business Designation: If eligible, apply for small business designation to benefit from reduced fees.
The Future of Device User Fees
The trend of increasing user fees is likely to continue as the FDA seeks to enhance its capabilities and keep pace with advancements in medical technology. Staying informed about these changes and planning accordingly is essential for all medical device manufacturers.
Understanding and managing device user fees is a critical aspect of bringing a medical device to market. With the new fee structure for FY 2025, manufacturers must plan accordingly to ensure compliance and financial stability. Staying informed about these changes and utilizing available resources can help navigate the regulatory landscape effectively. To read more about user fees click here. Contact us to get help with facility registration or anything else user-fee-related.