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Wound Care Regulatory Roadmap: Navigating FDA Pathways with Confidence

Bringing a wound care product to market requires more than innovation—it demands a clear, strategic regulatory plan. Whether you're developing a medical device, biologic, or combination product, understanding the right FDA pathway is critical to avoiding costly delays and ensuring compliance.

This roadmap outlines the key regulatory pathways—510(k), PMA, BLA, IND, IDE, and NDA—and provides actionable guidance to help you choose the right route for your product.

Regulatory Classifications: Know Your Review Center

Wound care products may fall under different FDA centers depending on their primary mode of action (PMOA):

  • CDRH (Center for Devices and Radiological Health): Devices like dressings, NPWT systems, and wound imaging tools
  • CDER (Center for Drug Evaluation and Research): Topical drugs, antimicrobials, and combination products with drug components
  • CBER (Center for Biologics Evaluation and Research): Biologics such as cell-based therapies, skin substitutes, and tissue-engineered products

OCP Designation Process: Combination Product Strategy

If your product combines device, drug, or biologic elements, the Office of Combination Products (OCP) will determine the lead review center. This decision is based on the PMOA and can significantly impact your regulatory strategy and timeline.

Submission Types Explained

Submission Type

Best For

Key Requirements

510(k)

Low- to moderate-risk devices

Substantial equivalence to predicate

PMA

High-risk or novel devices

Clinical data, safety & effectiveness

BLA

Biologic wound therapies

Purity, potency, safety, CMC data

IND

Investigational biologics or drugs

Preclinical data, study protocol

IDE

Investigational devices

Required for significant risk device trials

NDA

New drug products

Full clinical and manufacturing data

Case Examples

  • 510(k): A hydrocolloid dressing with antimicrobial properties cleared based on a predicate dressing
  • PMA: A novel NPWT system with integrated sensors requiring clinical validation
  • BLA: A bioengineered skin substitute derived from neonatal fibroblasts
  • Combination Product: A wound gel with both drug and device components reviewed under CDER with CDRH consultation

Strategic Tips for Regulatory Success

  • Engage FDA early: Use pre-submission meetings to clarify expectations
  • Plan for scalability: Align regulatory strategy with long-term product pipeline
  • Document everything: Maintain detailed records of testing, manufacturing, and labeling
  • Partner with experts: Regulatory consultants can help you avoid missteps and accelerate timelines

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