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    De Novo Classification Request

    Pathway to classify novel low- to moderate-risk devices that lack a predicate.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed May 5, 2026

    Definition

    The De Novo classification process provides a marketing pathway to classify novel medical devices for which general controls alone, or general and special controls, provide a reasonable assurance of safety and effectiveness for the intended use, but for which there is no legally marketed predicate device.

    What this means in practice

    Granting a De Novo creates a new device classification and can serve as a predicate for future 510(k) submissions, shaping the regulatory framework for an entire device category.

    Use cases

    1 scenario
    1

    First-of-kind continuous glucose-trend wearable

    Regulatory strategist

    A wearable measures interstitial glucose trends but doesn't fit any existing product code. The sponsor receives a Not Substantially Equivalent decision on a 510(k), then files a De Novo with risk-based special controls.

    OutcomeFDA grants De Novo classification as Class II and creates a new product code, which becomes a predicate for future entrants.

    Cross-references

    Often confused with

    Distinct concept frequently mistaken for this one.

    Primary references

    3 sources
    Link health: 3 verified· last checked 2026-05-09
    FDA·1IMDRF·1RAPS·1
    1. 1
      De Novo Classification Request
      Verified
      FDAfda.gov
    2. 2
      IMDRF Documents
      Verified
      IMDRFimdrf.org
    3. 3
      RAPS Regulatory Focus
      Verified
      RAPSraps.org

    Inline markers like [1] jump to the matching reference above.