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In 2025, a new variable has entered the equation for firms looking to use the 510(k) pathway: FDA staffing and review constraints. As device firms across the country gear up for new submissions or prepare for U.S. market entry, many are asking the same question:
“Should we move forward with our 510(k) submission or wait until things settle down at the FDA?”
The short answer, based on what we're seeing firsthand as a liaison between industry and regulators, is don't wait—move forward if you're sure your submission is as strong as it possibly can be.
Understanding the current FDA bottleneck
It’s no secret that the FDA—particularly its Center for Devices and Radiological Health (CDRH)—has faced staffing shortages and hiring challenges with the recent reduction in force. While the agency continues to operate, we're hearing a lot of concern that these internal pressures may lengthen review timelines and increase scrutiny across certain submission types. Although official guidance remains unchanged, medical device sponsors are beginning to worry about:
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Longer wait times for feedback on pre-submissions (Q-submissions)
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Slower response rates to clarification requests
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Extended review periods for certain 510(k) submissions, particularly those involving novel technologies or unclear predicates
While these developments have created uncertainty, prompting some device firms to pause or delay their submission timelines, we have not experienced delays with the teams whose 510(k) we're supporting. We're advising firms not to delay.
Why delaying your 510(k) submission may actually backfire
It’s understandable to want to wait for a “better” window to submit your 510(k)—but in most cases, waiting only increases risk. Here's why:
Review queues may only get longer.
As more companies delay submissions or push timelines into later quarters, the pileup of applications is growing. That means if you wait, you may be entering an even more crowded system. Simply put, the FDA is ready for your review now, but likely won't be in a few months.
Your competitors aren’t waiting.
The companies most likely to win market share in the coming year are those moving forward now—gaining early insights from pre-subs, addressing FDA feedback proactively, and maintaining momentum toward clearance.
You can’t control the FDA, but you can control your readiness.
While the FDA’s timeline may be outside your control, your internal preparation, documentation quality, and regulatory strategy are not. Companies that use this time to strengthen their submissions are better positioned to handle delays and respond swiftly to FDA queries.
What a proactive 510(k) strategy looks like in 2025
Instead of viewing the current regulatory environment as a reason to stall, high-performing teams are using it as a signal to start earlier and prepare smarter.
Here are three ways to do just that:
1. Align your regulatory strategy early
Before you build your submission, build your strategy. This includes identifying the correct predicate device, regulatory pathway, and classification—and ensuring these align with FDA's current expectations. A misaligned strategy is one of the most common reasons submissions get rejected or significantly delayed.
2. Engage in pre-sub dialogue
Even if review timelines are longer, a well-executed pre-submission (Q-sub) can help ensure you’re on the right path. It gives you the chance to ask key questions, confirm your predicate, and receive informal feedback from the FDA before you invest in a full submission. Getting alignment early saves weeks or months of revisions later.
3. Create submission-ready documentation now
Don’t wait to get your documentation in order. Preparing technical files, test summaries, labeling, and risk documentation in advance allows you to move fast when the time is right—and gives you time to fix any gaps before they become show-stoppers. Submission quality is a major factor in review time—especially under current constraints.
Final thoughts
It’s a complex time for 510(k) sponsors—but not a time to sit still. Proactivity, preparation, and the right guidance can make all the difference between a delayed product and a market-ready one. If you’re evaluating your regulatory path and want help navigating today’s challenges, now is the time to start the conversation.
Looking to prepare your 510(k) strategy with confidence?