FDA 510(k) · US market access · Substantial equivalence

FDA 510(k) premarket notification, done right.

For the US market we run the 510(k) pathway end to end: predicate selection, substantial-equivalence argumentation, performance and clinical data, and an FDA-ready submission, with EU MDR evidence re-used wherever it counts.

FDA 510(k)Substantial equivalencePredicate deviceUS market accessMILO EDC
Eclevar MedTech Platinum Award xShare EUCROF Amsterdam Platinum Award 2026

Eclevar MedTech and Milo took the Platinum Award at xShare & EUCROF.

Top prize in the xShare x European CRO Federation "EHDS & Clinical Research" Open Call, awarded to Eclevar MedTech and its Milo Health platform, presented at the EUCROF 2026 conference in Amsterdam.

Co-funded by the European Union

Horizon Europe · Grant Agreement No. 101136734 · Amsterdam, 2 Feb 2026

Social proof

Trusted by MedTech manufacturers.

Leading device manufacturers choose Eclevar for clinical evidence and real world evidence. Read all client success stories.

TERUMOMerilNIHON KOHDENVYGONColoplastSHOFUASAHI INTECCRegenLabTERUMOMerilNIHON KOHDENVYGONColoplastSHOFUASAHI INTECCRegenLab
Dr Mark Da Costa, COO Eclevar MedTech, former TUV SUD Notified Body reviewer
Dr Mark Da CostaCOO · Former Notified Body reviewer · Senior Consultant SurgeonFormer reviewer atTUV SUD
Regulatory leadership

A 510(k) that survives FDA review.

Dr Mark Da Costa, COO and former Notified Body reviewer, leads a team that knows regulatory submissions from the reviewer's side of the table. We structure the 510(k) so that the predicate comparison and the data package hold up under FDA scrutiny, and reuse EU MDR evidence to cut duplication.

Ex NBFormer TÜV SÜD reviewer
7Countries with in-house CRAs (UK, DE, FR, SE)
Chapter VIEU MDR Articles 62-82
Former NB reviewerFDA submissionISO 14155:2026
LinkedIn
Compliant withEU MDR 2017/745ISO 14155:2026GCPISO 13485GDPR
The US pathway

Substantial equivalence, argued properly.

A 510(k) demonstrates that a device is substantially equivalent to a legally marketed predicate. A weak or mismatched predicate comparison is the single most common cause of FDA Additional Information (AI) requests and lost months.

We select the right predicate, build a clean equivalence argument on intended use and technological characteristics, and add bench, biocompatibility or clinical data only where a genuine technological difference must be addressed.

Clinical data analysis and biometrics for medical devices
Building blocks

What makes a 510(k) defensible.

Every element is built to withstand FDA review from the first submission.

01
Predicate

Predicate & comparison

A suitable predicate and a clean substantial-equivalence comparison.

02
Data

Performance & clinical data

Bench, biocompatibility (ISO 10993) and, where needed, clinical data.

03
Dossier

Submission dossier

A structured 510(k) built to current FDA eSTAR requirements.

In-house CRAs

We do not outsource monitoring

Eclevar deploys in-house Clinical Research Associates in the United Kingdom, Germany, France and Sweden, ensuring smooth study initiation, ethics-committee submissions (for example CPP in France) and high-quality clinical data collection.

What we deliver

From strategy to FDA clearance.

01

Regulatory strategy

Predicate selection and pathway (Traditional, Special, Abbreviated).

02

Evidence generation

Performance and clinical data where the equivalence needs it.

03

Dossier & submission

Compilation and management of the 510(k) submission and AI responses.

Objectives of a 510(k)
01

Substantial equivalence

A clean demonstration of equivalence to the predicate.

02

Predicate choice

A suitable, defensible predicate device.

03

Close data gaps

Add performance or clinical data for technological differences.

04

FDA compliance

A submission built to current FDA guidance and eSTAR.

05

Fewer AI requests

Reduced Additional Information requests and faster review.

06

US market access

The route to marketing your device in the United States.

Our methodology

A five-step 510(k) methodology.

Data quality means completeness, consistency and accuracy across all investigational sites.

1

Feasibility assessment

Assessing data-source quality, completeness and consistency.

2

Protocol development

A robust protocol aligned with ISO 14155:2026 and GCP.

3

Conduct

Site activation, in-house CRAs, high-quality data collection.

4

Data analysis

Rigorous statistical analysis of safety and performance.

5

Documentation

Comprehensive reports for Notified Body and authorities.

Selected experience

Programs we have delivered.

Vascular patch · Class III

Multicentre study on a Class III vascular patch

Knitted polyester vascular prosthesis · EU MDR Chapter VI

Multicentre study with retrospective and prospective record data from French university hospitals (CHU Valenciennes, Nantes, Brest), covering carotid and femoral locations up to 3 years post-op and meeting EU MDR requirements for CE certification.

250-300patients · 3-8 sites
3 yrsfollow-up
≥100per location
Class IIICHU networkChapter VI
RegenLab · Advanced wound care

Registry-based RWE-PMCF for wound care

Advanced wound care device · CE mark renewal

RegenLab needed PMCF data to renew its CE marking without disrupting clinical workflows. Eclevar designed a targeted RWE-PMCF registry study on the MILO EDC platform capturing wound-healing trajectories and adverse-event tracking.

160patients · 14 sites
5EU countries
MDRChapter VI
RWE registryMILO EDCWound care
Regulatory framework

From EU MDR to FDA: compliant on both sides.

EU
EU MDR

EU MDR 2017/745

  • Clinical evidence under Chapter VI (Articles 62-82)
  • PMCF plan mandatory for Class IIb and III
  • Clinical Evaluation Report and ISO 14155:2026
  • Notified Body review and competent authority reporting
FR
ANSM

France

  • EU MDR plus national requirements
  • Ethics committee (CPP) approval
  • Data collection across the French hospital network
  • Annual safety reports, French documentation
DE
BfArM

Germany

  • EU MDR plus national requirements
  • Protocols filed with BfArM
  • Ethics committee approval mandatory
  • Quarterly safety reports, German documentation
UK
MHRA

United Kingdom

  • UK MDR, aligned with the EU MDR
  • Plan for Class IIb and III
  • Research Ethics Committee (REC) approval
  • NHS hospital data, annual reports to the MHRA
Official content

Our content, signed Eclevar.

Whitepapers, client testimonials and publications produced by our teams and partners (BSI, TÜV SÜD, RegenLab).

Whitepaper by BSI and Eclevar on the EU MDR
Whitepaper · BSI × Eclevar

A BSI and Eclevar whitepaper on the EU MDR.

Written with Notified Body BSI: a practical reading of the clinical evidence expectations under EU MDR 2017/745, relevant to any clinical program.

PMCF Studies · Regenerative Medicine · 5 EU Countries

A client's live testimonial on Eclevar's capability to run complex trials.

Eclevar manages RegenLab's PMCF program on chronic wound devices: a randomized study of 160 patients across 14 sites in 5 EU countries, covering both diabetic foot ulcer (DFU) and venous leg ulcer (VLU) indications. The partnership combines Eclevar's ISO 14155 clinical expertise with the Milo Studio platform to deliver post-market clinical follow-up evidence that supports both Notified Body scrutiny and reimbursement endpoints.

« Eclevar, with its tailor-made approach and advanced Milo Studio platform, represents a major strategic asset. »
Antoine Turzi, CEO, RegenLab
160patients · 14 sites
5EU countries
RegenLab video testimonial on the PMCF programme managed by Eclevar
FAQ

510(k) premarket notification, answered.

What is a 510(k) premarket notification?

A submission to the FDA that demonstrates a device is substantially equivalent to a legally marketed predicate device.

When is a 510(k) the right pathway?

For most Class II devices in the US where a suitable predicate exists; higher-risk or novel devices may require De Novo or PMA.

Are clinical data required for a 510(k)?

Not always, but frequently, to address technological differences from the predicate.

How do EU MDR and 510(k) relate?

Existing EU MDR evidence (clinical evaluation, biocompatibility, performance testing) can often be reused for the FDA submission; we align the strategy to both markets.

What is the most common reason for FDA questions?

A weak or unsuitable predicate comparison and insufficient data on technological differences.

Guaranteed response within 24 hours

Enter the US market with a solid 510(k).

Talk to our team about predicate selection, data strategy and the fastest compliant route to FDA clearance.

Book a free call

Reforming Clinical Evaluation of Medical Devices in Europe