§ COMPARE REGULATORS

FDA vs MHRA: Medical Device Regulatory Comparison

Compare the medical device registration pathways, classification, and regulatory requirements of FDA (United States) vs MHRA (United Kingdom).

FDA

U.S. Food and Drug Administration

United States

The FDA is the primary regulatory authority for medical devices in the United States. Its Center for Devices and Radiological Health (CDRH) oversees premarket review, postmarket surveillance, and enfo

CLASSES

Class I, II, III

PATHWAY

510(k), PMA, De Novo, HDE

KEY FUNCTIONS
  • 510(k) clearance and PMA approval
  • MAUDE adverse event database
  • FDA Enforcement Reports and recalls
  • De Novo classification
  • Breakthrough Device Designation

MHRA

Medicines and Healthcare products Regulatory Agency

United Kingdom

Post-Brexit, the MHRA operates an independent regulatory framework for medical devices in the UK. The UK Conformity Assessed (UKCA) marking is replacing CE marking for the UK market. The MHRA is devel

CLASSES

Class I, IIa, IIb, III

PATHWAY

UKCA marking via UK Approved Body

KEY FUNCTIONS
  • UKCA marking
  • UK device registration
  • Yellow Card adverse event reporting
  • UK Approved Body oversight

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§ OTHER COMPARISONS