When FDA Holds Your Entry: Common Causes and How to Respond
Why FDA places medical device entries on hold, what the response window looks like, and how to prevent the same hold on the next shipment.
An FDA entry hold is not a refusal. It is a request for information, and it is resolved with documentation. The difference between a two-day hold and a two-week hold is usually how quickly and completely the importer can answer, which is decided long before the container arrives.
How entry review works
FDA receives entry data electronically from Customs and Border Protection and screens it against registration, listing and clearance records. Entries that match proceed. Entries that raise a question are flagged as may proceed with comment, held for further review, or referred for examination. Each outcome has a different response path and a different clock.
The four most common hold reasons
- Registration or listing mismatch: the establishment number on the entry does not match an active registration, or the device is not listed under that product code.
- Product code or classification error: the code on the entry does not correspond to the device described on the invoice.
- Labeling deficiency: missing manufacturer or distributor information, missing UDI, or claims that do not match the cleared indication.
- Missing U.S. Agent or importer identification: no designated domestic contact, or an importer of record inconsistent with the entry.
What a good response looks like
A response should answer the specific question asked, attach the record that proves it, and correct the underlying entry if needed. Sending a general letter about the quality of the device rarely helps; sending the listing confirmation that matches the product code usually ends the hold. Where a correction is impossible, reconditioning, re-export or destruction may be the remaining paths, and each requires its own documentation.
Preventing the next hold
Keep the entry package assembled from the same source of truth as your registration record, and re-verify it before each shipment where anything has changed: a new product code, a new label revision, a revised clearance, a new distributor. Most repeat holds are not new problems; they are the previous problem still present in a template.
Need this applied to your device?
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