History & Major Events

Regulatory Pathways (510k) for Test Strips

The regulatory pathway for diabetic test strips in the US is governed by the FDA 510(k) Premarket Notification process for Class II devices. A critical evolution in this pathway occurred with the 2020 Final Guidance, which bifurcated the market into two distinct product codes: NBW for Over-the-Counter Self-Monitoring (SMBG) and PZI for Professional Point-of-Care use (BGMS).

This split was driven by the need for stricter infection control in professional settings and distinct usability requirements for lay users. To achieve clearance, manufacturers must demonstrate substantial equivalence to a predicate device through rigorous performance testing. This includes adhering to accuracy standards (95% of readings within ±15% of reference), validating performance across wide hematocrit ranges, and proving specificity against a mandated list of chemical interferents (e.g., Vitamin C, Maltose). Furthermore, professional systems often require a concurrent CLIA Waiver to allow use in near-patient settings, while modern connected systems must now also satisfy strict cybersecurity and data integrity mandates.

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Regulatory Pathways for [Diabetic Test Strips](/sell-diabetic-supplies)

The FDA regulates diabetic test strips through the 510(k) Premarket Notification process.

This process applies to Class II devices.

The 2020 Final Guidance splits the market into two product codes:

  • NBW for Over-the-Counter Self-Monitoring (SMBG)
  • PZI for Professional Point-of-Care use (BGMS).

Manufacturers must demonstrate substantial equivalence to a predicate device.

They must also pass rigorous performance testing, including:

  • Meeting accuracy standards (95% of readings within ±15% of reference)
  • Validating performance across wide hematocrit ranges
  • Proving specificity against chemical interferents (e.g., Vitamin C, Maltose)

The FDA requires a CLIA Waiver for professional systems in near-patient settings.

Connected systems must satisfy cybersecurity and data integrity mandates.

The 2020 Final Guidance drives these regulatory pathways [[fda2020]](#fda2020).

References

  1. Self-Monitoring Blood Glucose Test Systems for Over-the-Counter Use - Guidance for Industry and Food and Drug Administration StaffSource
  2. Blood Glucose Monitoring Test Systems for Prescription Point-of-Care Use - Guidance for Industry and Food and Drug Administration StaffSource
  3. Recommendations for Clinical Laboratory Improvement Amendments of 1988 (CLIA) Waiver Applications for Manufacturers of In Vitro Diagnostic DevicesSource

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