As one of the world’s most authoritative product safety regulators, compliance with the FDA (U.S. Food and Drug Administration) serves as the market access passport for products entering the United States. Many enterprises misunderstand “FDA testing”. It is not a single universal certificate, but a riskbased compliance system.
The industry term “FDA certification” essentially means a product meets FDA regulatory requirements and completes certain procedures among registration, testing and approval to obtain U.S. market access. The FDA does not issue a unified certificate; it only provides registration confirmation numbers or approval documentation.
01 What is FDA Testing?
FDA testing follows standards and regulations issued by the FDA and is a mandatory prerequisite for commercialising products in the U.S. market. It enables oversight of the safety of regulated goods circulating in the United States. Enterprises exporting goods to the U.S. must perform FDA testing to demonstrate compliance with FDA regulations.
All goods imported into the U.S. fall under FDA jurisdiction if they are: food, drugs, medical devices, cosmetics, biological products, animal and veterinary products (including animal pharmaceuticals and feed), food additives, tobacco products, and foodcontact materials (such as kitchenware and tableware, classified within food additives).
02 Three Core Forms of FDA Compliance
Commonly referenced “FDA certification” falls into three main categories: FDA Registration, FDA Testing and FDA Approval.
① FDA Registration: Mandatory requirement. Company and product details are filed, forming the foundation for customs clearance. Applies to most products including food, drugs, medical devices and cosmetics.
② FDA Testing: Refers primarily to product safety assessment, e.g. material safety for foodcontact articles, biocompatibility testing for medical devices.
③ FDA Approval: Reserved for highrisk products. Clinical data or technical files must be submitted to prove safety and efficacy. Examples include NDA applications for pharmaceuticals and PMA clearance for Class III medical devices.
03 Products Subject to FDA Testing
- Food & dietary supplements: Food, beverages, dietary supplements, etc.
- Cosmetics: Cosmetic colour additives, skin moisturisers and cleansers, nail polish, perfumes and other cosmetic items.
- Medical devices: Masks and protective equipment, prescription and overthecounter medicines, human vaccines and biological products, dental devices and materials, surgical implants and artificial organs, prosthetics and assistive devices.
- Laser radiation products: Microwave ovens and microwave equipment, Xray devices, sunlamps and tanning equipment.
- Veterinary products: Veterinary pharmaceuticals, pet food, livestock feed and animal drugs.
- Tobacco products: Cigarette tobacco, rollyourown tobacco, cigar tobacco, smokeless tobacco.
For medical devices, the FDA classifies them into three risk classes (Class I, II, III). Class III carries the highest risk level and the strictest oversight. The FDA defines the classification and regulatory requirements for each type of medical device, with more than 1,700 product types listed in the FDA medical device database.
04 FDA Testing Workflow
- Determine product classificationThe FDA broadly categorises products as drugs, medical devices, or food/cosmetics. Different categories follow distinct certification and inspection procedures and must satisfy separate standards and regulations.
- Develop a plan and timelineThe plan covers laboratory testing, demonstrations, manufacturing and production authorisation. It ensures smooth execution of the full compliance procedure and guarantees all test and demonstration materials comply with FDA standards and rules.
- Prepare and submit application for reviewThe application package must contain all required information and materials to prove the product meets FDA criteria. Required documentation includes:
- Product description (intended use, composition, manufacturing process, etc.)
- Representative product samples for FDA testing and evaluation
- Laboratory test reports (chemical, physical and biological test results)
- Clinical trial results (required for pharmaceuticals and medical devices)
- Manufacturing and quality control plan
- Manufacturing certification
After submission, the FDA conducts an initial review to verify compliance with its standards. If the initial review passes, the FDA may schedule an onsite inspection of the manufacturer. Successful inspection leads to product marketing authorisation and issuance of FDA approval documentation.
