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Regulatory [Regulated Pathways](/ecosystems/regulated-pathways)[Global Markets](/ecosystems/global-markets)3P 510(k) 

# Third-Party Review of 510(k)

Program in which FDA-accredited third parties conduct the initial 510(k) review for eligible device types.

Reviewed by [Christian Espinosa, Founder, Blue Goat Cyber](/authors/christian-espinosa) Last reviewed May 5, 2026 

## Definition

Eligible Class I and Class II device  [510(k)](/terms/510k)s can be reviewed by an FDA-accredited Third Party Review Organization, which submits a recommendation to FDA. Final clearance still rests with FDA. 

What the regulation says

The FDA Modernization Act of 1997 authorized the third-party review program for 510(k) submissions, as outlined in FDA guidance documents like "Guidance for Industry and FDA Staff Third Party Review Programs" (2018). This program allows accredited third parties to conduct the primary review of certain low-to-moderate risk medical devices, aiming to expedite the regulatory process while the FDA retains final clearance authority. The scope and eligibility criteria for devices are specified by the FDA, with only a subset of Class I and Class II devices qualifying. 

## What this means in practice

Used to compress timelines for well-established product types; not all product codes are eligible. 

## Examples

-   A manufacturer of a new, conventional blood glucose meter opts for third-party review to potentially accelerate its 510(k) clearance process.
-   A company developing a surgical tool with a well-established predicate device chooses a Third-Party Review Organization to handle the initial technical review of their 510(k) submission.
-   A medical device startup with limited internal regulatory resources uses a third-party reviewer to leverage their expertise and streamline the 510(k) submission for a Class II diagnostic imaging accessory.

Common pitfalls

-   • A common pitfall is submitting an eligible 510(k) to a Third-Party Review Organization without ensuring the device falls within the specific product codes and limitations accepted by that particular organization. 
-   • Another mistake is assuming that third-party review guarantees faster clearance, as the FDA still performs an administrative review and can request additional information, impacting the overall timeline. 
-   • Companies sometimes fail to perform due diligence on the accreditation and experience of a Third-Party Review Organization, potentially leading to incomplete reviews or delays. 
-   • Misunderstanding that the third-party reviewer acts on behalf of the manufacturer, not as a representative of the FDA, can lead to compliance issues. 
-   • Failing to prepare the 510(k) submission to the same standard as a direct FDA submission is a pitfall, as third-party reviewers adhere to FDA requirements and expectations. 

## Frequently asked questions

What types of devices are eligible for third-party 510(k) review? 

Generally, certain Class I and Class II devices that are well-understood and have established predicate devices are eligible, as defined by FDA product codes and program guidance documents. 

Does third-party review replace the FDA's role in 510(k) clearance? 

What are the benefits of using a Third-Party Review Organization? 

Are all Third-Party Review Organizations the same? 

## Related terms

Grouped by theme 

### Editor's picks

· Hand-selected related concepts 

[

Regulatory

510(k) Premarket Notification(510(k)) 

FDA submission demonstrating a device is substantially equivalent to a legally marketed predicate.





](/terms/510k)[

Regulatory

Abbreviated 510(k)

510(k) variant that relies on FDA guidance, special controls, or recognized consensus standards.





](/terms/abbreviated-510k)

### More in Regulatory

· Same category 

[

Regulatory

510(k) Summary vs 510(k) Statement

Two alternative disclosure mechanisms in a 510(k) submission, a Summary is public on FDA's website; a Statement promises to share Safety & Effectiveness info on request.





](/terms/510k-summary-vs-statement)[

Regulatory

513(g) Request for Information(513(g)) 

Formal mechanism to ask FDA whether a product is a device and, if so, its likely classification.





](/terms/513g)[

Regulatory

Accreditation Scheme for Conformity Assessment(ASCA) 

FDA voluntary program in which accredited testing labs perform standards-based testing accepted with reduced FDA scrutiny.





](/terms/asca)[

Regulatory

Additional Condition for Nonprescription Use(ACNU) 

FDA's 2024 final rule creating a pathway for nonprescription drug products that rely on additional conditions (e.g., self-selection tools, drug-device combinations) to ensure safe use without a healthcare provider.





](/terms/acnu)

Cited by

Where this term appears across MedTech Terms.

Ecosystems (2)

-   [Regulated Pathways](/ecosystems/regulated-pathways)
-   [Global Markets](/ecosystems/global-markets)

## Primary references

3 sources 

Link health:  3 verified · last checked 2026-06-20 

FDA· 1 European Commission· 1 IMDRF· 1 

1.  [1 
    
    FDA - Medical Devices
    
    Verified 
    
    FDA · fda.gov 
    
    
    
    ](https://www.fda.gov/medical-devices)
2.  [2 
    
    European Commission - Medical Devices
    
    Verified 
    
    European Commission · health.ec.europa.eu 
    
    
    
    ](https://health.ec.europa.eu/medical-devices-sector_en)
3.  [3 
    
    IMDRF Documents
    
    Verified 
    
    IMDRF · imdrf.org 
    
    
    
    ](https://www.imdrf.org/documents)

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

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On this term

Category

Regulatory

Acronym

3P 510(k)

Sources

3

Updated

5/5/2026

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Card Lesson Quiz

Program in which FDA-accredited third parties conduct the initial 510(k) review for eligible device types.

-   · Used to compress timelines for well-established product types; not all product codes are eligible. 
-   · Final clearance still rests with FDA. 

Remember this

Watch out: A common pitfall is submitting an eligible 510(k) to a Third-Party Review Organization without ensuring the device falls within the specific product codes and limitations accepted by that particular organization.

Related terms

-   [510(k) Premarket Notification(510(k)) ](/terms/510k)
-   [Abbreviated 510(k) ](/terms/abbreviated-510k)

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