Contains Nonbinding Recommendations 
 
Bundling Multiple Devices or 
Multiple Indications in a Single 
Submission 
Guidance for Industry and  
Food and Drug Administration 
Staff  
Document issued on June 22, 2007.  
This document supersedes Bundling Multiple Devices or Multiple 
Indications in a Single Submission issued November 26, 2003. 
 
 
For questions about this document regarding CDRH-regulated devices, contact the 510(k) 
Program at (301) 796-5640, or by email to 510k_program@fda.hhs.gov.  For devices 
reviewed by the Office of In Vitro Diagnostics and Radiological Health (OIR), contact 
DPOM at (301) 796-5640, or by email to 510k_program@fda.hhs.gov.  
For questions about this document regarding CBER-regulated devices, contact the Office 
of Communication, Outreach, and Development (OCOD) at 1-800-835-4709 or 240-402-
8010.  
 
 
     U.S. Department of Health and Human 
Services 
  Food and Drug Administration 
Center for Devices and Radiological Health 
Center for Biologics Evaluation and 
Research 
  1  Contains Nonbinding Recommendations 
 
Preface 
Public Comment 
 
You may submit electronic comments and suggestions at any time for Agency 
consideration to http://www.regulations.gov .  Submit written comments to the Dockets 
Management Staff, Food and Drug Administration, 5630 Fishers Lane, Room 1061, 
(HFA-305), Rockville, MD 20852.  Identify all comments with the docket number FDA-
2003-D-0376. Comments may not be acted upon by the Agency until the document is 
next revised or updated. 
Additional Copies 
 
CDRH 
Additional copies are available from the Internet. You may also send an e-mail request to 
CDRH-Guidance@fda.hhs.gov to receive a copy of the guidance.  Please use the 
document number 1215 to identify the guidance you are requesting. 
CBER 
Additional copies are available from the Center for Biologics Evaluation and Research 
(CBER), Office of Communication, Outreach, and Development (OCOD), 10903 New 
Hampshire Ave., WO71, Room 3128, Silver Spring, MD 20903, or by calling 1-800-835-
4709 or 240-402-8010, by email, ocod@fda.hhs.gov, or from the Internet at  
http://www.fda.gov/BiologicsBloodVaccines/GuidanceComplianceRegulatoryInformatio
n/Guidances/default.htm.  
 
  2  Contains Nonbinding Recommendations 
 
Table of Contents 
I.  Introduction...........................................................................................................................................4
A.  Background ............................................................................................................................................4
B.  Consultation with Stakeholders.............................................................................................................5
C.  The Least Burdensome Approach ..........................................................................................................6
II.  Frequently Asked Questions on Bundling of Multiple Devices or Multiple Indications in a Single 
Submission .....................................................................................................................................................6
A.  Overview of Bundling ...........................................................................................................................6
(1)  What is bundling?..........................................................................................................................6
(2)  What effect does MDUFMA have on bundling? ...............................................................................7
(3)  What are the general bundling principles applicants should follow?................................................7
B.  Bundling of Specific Types of Devices or Indications for Use ..............................................................8
(4)  Can I bundle multiple devices within a generic device type in a single510(k) or PMA submission?8
(5)  Can I bundle differing generic device types in a single 510(k) submission?....................................8
(6)  Can I bundle differing generic device types in a single PMA submission?......................................9
(7)  Can I bundle multiple indications for use for a device in one 510(k)? ..............................................9
(8)  Can I bundle multiple indications for use for a device in one PMA? ................................................9
(9)  Can I bundle a 510(k) device with a PMA device in a single submission? ..................................... 10
(10)  Can I bundle changes that affect multiple devices of the same or differing generic types? ........ 10
(11)  Can I bundle reprocessed single-use devices (SUDs) in a single submission? ........................... 11
(12)  Are there specific considerations for in vitro diagnostic devices? .............................................. 12
(13)  How do I bundle multiple devices or indications for use in a single submission? ...................... 15
(14)  What will FDA do if devices or indications are bundled inappropriately? ................................. 16
(15)  How can I appeal an FDA determination that it is not appropriate to bundle a device or 
indication for use in a single application? ................................................................................................ 16
(16)  Can I add more devices or indications for use to a submission once the review of that submission 
has begun? ................................................................................................................................................ 17 
(17)  Can I withdraw a device or indication for use from my premarket submission, for example, 
because the review of that device or indication for use is slowing down the review of the others? ......... 17
(18)  How can I get information on the appropriateness of bundling certain devices or indications for 
use before submitting a marketing application? ....................................................................................... 17
 
  3  Contains Nonbinding Recommendations 
 
Bundling Multiple Devices or 
Multiple Indications in a Single 
Submission 
Guidance for Industry and  
Food and Drug Administration 
Staff  
This guidance represents the current thinking of the Food and Drug Administration 
(FDA or Agency) on this topic.  It does not establish any rights for any person and is 
not binding on FDA or the public.  You can use an alternative approach if it satisfies 
the requirements of the applicable statutes and regulations.  To discuss an alternative 
approach, contact the FDA staff or Office responsible for this guidance as listed on the 
title page.  
I.  Introduction 
A.  Background 
The Medical Device User Fee and Modernization Act of 2002 (MDUFMA), P.L. 107-
250, amended the Federal Food, Drug, and Cosmetic Act (the act) by authorizing FDA to 
collect user fees for certain premarket submissions received on or after October 1, 2002.  
A letter from the Secretary of Health and Human Services to Congress that accompanies 
the user fee legislation sets forth performance goals and policy and procedural provisions.  
One of these provisions is entitled, Bundling Policy, and states that FDA will consider, 
in consultation with its stakeholders, when bundling multiple devices in a single 
submission may be appropriate. 
Prior to MDUFMA, submitting separate applications for devices that could have been 
bundled in a single submission, or bundling of devices that should have been submitted in 
separate applications, was primarily an administrative issue related to the efficiency of 
the review process.  Under MDUFMA, bundling within a single premarket submission 
takes on additional importance because of the fees that are now associated with 
premarket submissions as well as the performance goals that the agency has committed to 
meet.  This guidance is intended to assist industry and FDA staff in understanding when 
bundling may be appropriate.  This guidance will be used by both the Center for Devices 
  4  Contains Nonbinding Recommendations 
 
and Radiological Health (CDRH) and the Center for Biologics Evaluation and Research 
(CBER) when reviewing bundled premarket submissions. 
FDA's guidance documents, including this guidance, do not establish legally enforceable 
responsibilities.  Instead, guidance documents describe the Agency's current thinking on a 
topic and should be viewed only as recommendations, unless specific regulatory or 
statutory requirements are cited.  The use of the word should in Agency guidances means 
that something is suggested or recommended, but not required. 
B.  Consultation with Stakeholders 
As discussed above, FDA has committed to considering the issue of bundling in 
consultation with its stakeholders.  In developing this guidance, the Agency has 
considered comments on bundling that were submitted to the Public Docket on 
MDUFMA Implementation, Docket No. 02N-0534.  FDA also received comments on the 
topic before and after issuing the guidance entitled, Assessing User Fees: PMA 
Supplement Definitions, Modular PMA Fees, BLA and Efficacy Supplement Definitions, 
Bundling Multiple Devices in a Single Application, and Fees for Combination Products; 
Guidance for Industry and FDA.1  In that guidance, FDA asked for comments on 
bundling in general as well as specific comments on the concepts presented in the 
document. 
Most of the comments supported the concept of bundling, and some stakeholders 
provided examples of when bundling should be considered appropriate.  FDA included 
many of these examples in this document.  One stakeholder expressed concern that the 
practice of bundling was not well known and asked that the agency clearly identify 
criteria for both industry and FDA staff.  The agency has attempted to be as specific as 
possible in defining when bundling should be appropriate.  Because not all situations can 
be anticipated, there may be bundling issues that are not addressed in this guidance.  
Finally, one commentor was concerned that the misuse of bundling could lead to higher 
user fees in subsequent years.  FDA believes that the concepts and examples of when 
bundling should be appropriate that are provided in this document will help to alleviate 
that concern. 
The agency recognizes that bundling is a complicated topic and continues to invite 
comments. In addition, the agency intends to include bundling as a topic for discussion 
at future stakeholder meetings. 
                                                           
1 This guidance can be found at 
https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm089726.ht
m.  
  5  Contains Nonbinding Recommendations 
 
C.  The Least Burdensome Approach 
We believe we should consider the least burdensome approach in all areas of medical 
device regulation.  This guidance reflects our careful review of the relevant scientific and 
legal requirements and what we believe is the least burdensome way for you to comply 
with those requirements.  However, if you believe that an alternative approach would be 
less burdensome, please contact us so we can consider your point of view.  You may send 
your written comments to the contact person listed in the preface to this guidance or to 
the CDRH or CBER Ombudsman.  Comprehensive information on CDRH's 
Ombudsman, including ways to contact him, can be found on the Internet at 
https://www.fda.gov/aboutfda/centersoffices/officeofmedicalproductsandtobacco/cdrh/cd
rhombudsman/default.htm.  CBERs Ombudsman can be reached at (301) 827-0379. 
II.  Frequently Asked Questions on Bundling of 
Multiple Devices or Multiple Indications in a Single 
Submission 
A.  Overview of Bundling 
(1)  What is bundling? 
Bundling refers to the inclusion of multiple devices or multiple indications for use for a 
device in a single premarket submission, including products subject to the device and 
biologics license application (BLA) authorities, for purposes of review and user fee 
payment. In CBER, the term may also include the designation of separate submissions as 
one premarket submission for review and user fee payment.  Multiple devices may 
include different models within a generic type of device2 or devices that are of differing 
generic types. 
Under current review practices, CDRH and CBER have accepted submissions in which 
multiple devices or indications for use were bundled when the devices or indications 
presented issues that could be addressed during one review.3   An applicant is not 
required to bundle multiple devices or indications, but may choose to do so when 
                                                           
2 Generic type of device is defined in 21 CFR  860.3(i) as a grouping of devices that do not differ 
significantly in purpose, design, materials, energy source, function, or any other feature related to safety 
and effectiveness, and for which similar regulatory controls are sufficient to provide reasonable assurance 
of safety and effectiveness. 
3 The classification letter for a bundled submission generally will identify the classification regulation for 
the device with the highest regulatory class within the bundle (e.g., if the submission bundles a Class I 
device and a Class II device, the letter will refer to the Class II classification).  This letter does not impose 
any additional regulatory requirements on devices within the bundle beyond those associated with their 
individual classification. Unless devices within the bundle are subject to their own classification 
regulations, they are subject to the regulatory requirements applicable to the device with which they are 
intended to be used. 
  6  Contains Nonbinding Recommendations 
 
appropriate.  Each device or indication in a bundled submission must satisfy the 
applicable statutory and regulatory premarket requirements. 
Prior to MDUFMA, bundling was primarily an administrative issue.  The Agencys 
primary consideration in determining what devices, or indications for use, could be 
bundled in one premarket submission was the Agencys ability to conduct efficient 
reviews and render timely decisions.  The total review time for an application in which 
multiple devices presenting disparate scientific and regulatory issues were bundled was 
determined by the device that took the longest time to review. 
(2)  What effect does MDUFMA have on bundling? 
Under MDUFMA, bundling within a single premarket submission takes on additional 
importance because of the fees4 that are now associated with certain submissions as well 
as the performance goals that the agency has committed to meet.5   According to the new 
law, there is one user fee per submission.  In addition, as specified in the Secretarys 
letter to Congress, the agency has committed to improving its premarket review times by 
meeting both cycle and decision goals for 510(k)s and PMAs. Thus, if devices or 
indications for use are bundled when they should have been submitted in separate 
applications, the user fee revenues for that year will be affected and subsequent fees for 
all regulatory submissions 
may require adjustment.  Premarket review times may also suffer if devices or indications 
are bundled inappropriately. 
Appropriate bundling, however, will help ensure that user fees revenues are not adversely 
affected and that the agency meets its cycle and decision goals.  The agency is providing 
this guidance to help its own staff and industry determine when it may be appropriate to 
bundle multiple devices or indications for use in a single submission. 
(3)  What are the general bundling principles applicants 
should follow? 
The general principles are: 
  Bundling is appropriate for devices that present scientific and regulatory issues 
that can most efficiently be addressed during one review.  In determining whether it can 
review a bundled submission during the course of one review, FDA may consider 
whether: (i) the supporting data are similar; (ii) primarily one review division/group will 
be involved; and (iii) the devices or indications for use are similar. 
                                                           
4 For fiscal year 2004, see  http://www.fda.gov/OHRMS/DOCKETS/98fr/03-19655.htm or 
http://www.fda.gov/OHRMS/DOCKETS/98fr/03-19655.pdf.  
5 The performance goals can be found at 
https://www.fda.gov/forindustry/userfees/medicaldeviceuserfee/default.htm.  
  7  Contains Nonbinding Recommendations 
 
  FDA should not cull out a device or an indication for use from a premarket 
submission for the purpose of collecting additional user fees. 
  Applicants should not inappropriately combine devices in a premarket submission 
for the purpose of avoiding user fees. 
B.  Bundling of Specific Types of Devices or Indications 
for Use 
(4)  Can I bundle multiple devices within a generic device 
type in a single510(k) or PMA submission? 
You generally may bundle multiple devices within the same generic device type for both 
510(k)s and PMAs.  You should consider whether the devices have similar indications, 
rely on similar data, and/or whether primarily one review division/group will review the 
devices. If the devices have these characteristics in common, bundling is typically 
appropriate. 
Examples include: 
  Bundling of catheters or single lumen hypodermic needles with various 
dimensions and configurations in a single 510(k) submission. 
  Bundling of soft contact lenses of various materials and lens designs in a single 
510(k) submission when the lens designs and indications for use of each lens material are 
generally the same.  (This example may also illustrate the bundling of changes 
discussed following question 10 below.) 
  Bundling of class I (or II) spinal implants made of multiple metallic alloys 
(stainless steel and titanium versions) into one 510(k) submission, if the indications for 
use are generally the same for the two materials. 
  Bundling of several sizes of aortic heart valves in a single PMA submission. 
(5)  Can I bundle differing generic device types in a single 
510(k) submission? 
In some cases, you may bundle differing generic device types in a single 510(k) 
submission. In determining whether bundling differing generic device types in a single 
510(k) is appropriate, you should consider the general principles outlined above and also 
whether the bundled devices are used together during a therapeutic or diagnostic 
  8  Contains Nonbinding Recommendations 
 
procedure.  You generally may bundle the devices if one device is an accessory to 
another.  Examples of differing generic device types that may be bundled include a 
device with its ancillary components or peripherals, and devices generally included in 
convenience kits and device systems. 
(6)  Can I bundle differing generic device types in a single 
PMA submission? 
Generally, you should not bundle differing generic device types in a single PMA 
submission because of the substantially different pre-clinical and clinical data needed to 
support each of the devices. 
(7)  Can I bundle multiple indications for use for a device 
in one 510(k)? 
In many cases, you may bundle multiple related indications for use in a single 510(k) 
submission.  An example is a spinal implant system intended for both anterior and 
posterior spinal fixation for fracture, scoliosis, tumor, and grade 3 and 4 
spondylolisthesis. 
If one of the indications for use is new (i.e., a use that has not been cleared), the applicant 
should consider submitting a separate 510(k) for the new use because it will likely 
include clinical data and the review may take longer than the review for the other 
indications for use. Additionally, devices with different indications for use in multiple 
medical specialties, which would require reviews by different divisions, should have 
separate submissions. 
(8)  Can I bundle multiple indications for use for a device 
in one PMA? 
You generally should not bundle multiple indications for use in one PMA because each 
indication is usually supported by a clinical study that requires significant review 
resources. Bundling multiple indications in one PMA might be appropriate, however, if 
much of the data needed to support approval of the indications would be the same (e.g., 
the same clinical data).  For example, CDRH has permitted bundling of multiple 
indications for use in a single PMA for cardiac ablation catheters when all the indications 
were supported by the same clinical data.6 
                                                           
6 Please refer to the guidance entitled, Cardiac Ablation Catheters Generic Arrhythmia Indications for 
Use; Guidance for Industry, which may be found on CDRHs website at: 
https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm072860.ht
m.   
  9  Contains Nonbinding Recommendations 
 
(9)  Can I bundle a 510(k) device with a PMA device in a 
single submission? 
You generally should not bundle PMA and 510(k) devices in a PMA.  There are some 
exceptions, however, for devices that are used together in a single procedure or that are 
part of a system.  In those instances, bundling the PMA and 510(k) devices in a single 
PMA submission might be appropriate.  For instance, if a Class II special surgical 
instrument is used to implant a Class III device subject to premarket approval, such as a 
pacing lead, it may be appropriate to bundle both devices in a PMA.  Additionally, a 
digital mammography system is frequently bundled with its printer.  If a 510(k) device 
and a PMA device are bundled in a single submission, the PMA user fee and review 
timeframe will apply. 
(10)  Can I bundle changes that affect multiple devices of 
the same or differing generic types? 
You may submit one application when a change affects multiple devices of the same or 
differing generic types if the impact of the change on each of the devices can be 
efficiently assessed during one review.  You should consider the complexity of device 
design, technological characteristics, and the modifications/changes being made to the 
existing devices. 
Examples of when bundling might be appropriate for changes affecting multiple devices 
of the same generic type include: 
  Bundling a change from one polyethelene (material) in various hip acetabular 
cups to another highly crosslinked polyethelene (material) in a single 510(k) submission. 
  Bundling when a contact lens manufacturer proposes the addition of a color 
additive to a line of its contact lenses (i.e., lenses of differing materials and/or 
configurations), where the color additive has been listed or certified for that use. 
  Bundling a change to a pacemaker programmer where the programmer is used for 
several types of pacemakers.  Even though the change would affect several PMAs, only 
one PMA submission need be made. 
Examples of when bundling might be appropriate for changes affecting multiple devices 
of 
differing generic types include: 
  Bundling in a single 510(k) submission a change that involves the addition of a 
heparin coating to various cardiopulmonary bypass devices, such as an arterial line blood 
filter and pump tubing. 
  10  Contains Nonbinding Recommendations 
 
  Bundling in a single PMA submission changes that involve a manufacturing 
facility or a manufacturing process where the same equipment and closely related 
processes are used for all the devices in the submission.  For example, if a manufacturer 
makes a material for two products using the same equipment and closely related 
processes, one PMA supplement may be submitted in support of the process change 
affecting both products. 
  Bundling in a single PMA submission changes in sterilization (e.g., a change from 
ethylene oxide sterilization to radiation sterilization or a change in sterilization release 
method), where the scientific evidence provided is valid for all devices referenced. 
  Bundling certain labeling changes in either a 510(k) or PMA submission.  For 
example, a labeling change to multiple devices of differing generic types may be bundled 
in a single 510(k) or PMA submission when the labeling change involves a change to the 
packaging of the devices, such as new instructions for opening the package. 
A change that affects multiple devices that are reviewed by different divisions may be 
appropriate for bundling if the change can be reviewed during one review.  For example, 
a software change to a stimulator that has gastric and neural indications could be bundled 
even though the original PMAs were reviewed by different divisions. 
Finally, there are some instances when you may bundle a change that affects a device that 
has both a 510(k) and a PMA indication.  For example, it may be appropriate to bundle a 
software change to a lithotripter that has a 510(k) indication (kidney stones) and a PMA 
indication (tennis elbow) if the change can be assessed during one review. 
(11)  Can I bundle reprocessed single-use devices (SUDs) in 
a single submission? 
MDUFMA amended the act to provide new regulatory requirements for reprocessed 
SUDs 
(MDUFMA  302).  One of these requirements is the submission of validation data in 
510(k)s for certain reprocessed SUDs.  The validation data submitted must demonstrate 
that these SUDs will remain substantially equivalent to their predicate devices after the 
maximum number of times the device is reprocessed as intended by the person 
submitting the 
premarket notification (MDUFMA  302(b), the act  510(o)).  The validation data to be 
submitted include cleaning, sterilization, and functional performance data. 
Although some aspects of the validation process may be common to various reprocessed 
SUDs (e.g., SUDs of the same generic type), the designs of these SUDs may be unique 
(e.g., different original equipment manufacturers (OEMs)).  If the SUDs are within the 
same generic type and have the same OEM, the validation data may apply equally to each 
of the SUDs, and a single 510(k) would likely be appropriate.  If the SUDs were 
produced by different OEMs, however, the reprocessor should explain how the submitted 
  11  Contains Nonbinding Recommendations 
 
data apply to all the devices in the submission and only bundle those SUDs that can be 
reviewed together. 
In addition, reprocessors generally should not bundle differing generic device types in 
one submission because different data requirements will typically apply.  For example, a 
reprocessor should not bundle catheters and compression limb sleeves in a single 510(k). 
For additional information on MDUFMAs validation data requirements for reprocessed 
SUDs requiring 510(k) clearance, please refer to the guidance entitled, Medical Device 
User Fee and Modernization Act of 2002, Validation Data in Premarket Notification 
Submissions [510(k)s] for Reprocessed Single-Use Medical Devices.7 
MDUFMA also requires the submission of validation data for reprocessed SUDs subject 
to PMA requirements.  The data must demonstrate that the reasonable assurance of the 
safety and effectiveness of the reprocessed SUD will remain after the maximum number 
of times the device is reprocessed as intended by the person making the premarket 
submission 
(MDUFMA  302(c)(2)), the act  515(c)(2)).  The validation data and other data 
required to support the premarket submission or, in this case, a premarket report, 
requires significant review.  Thus, it may be inappropriate to bundle reprocessed SUDs 
across multiple OEMs because the design, etc., of each of the SUDs may be unique and 
require significant review resources.  If, however, multiple individual submissions would 
contain substantially the same pre-clinical and clinical information, then it may be 
appropriate to submit a single premarket report for these reprocessed SUDs across 
multiple OEMs.  The reprocessor may contact the relevant review division to discuss 
whether bundling in a specific situation might be appropriate. 
B.  In Vitro Diagnostic Devices 
(12)  Are there specific considerations for in vitro 
diagnostic devices? 
Yes.  For in vitro diagnostic devices, FDA recommends that you consider the points 
below. If, after reading this guidance, you are still unsure as to whether it is appropriate 
to bundle, we encourage you to discuss the issue with the responsible review division. 
Multiple Analytes 
You generally may bundle in a single submission multiple analytes or instruments when 
the same analytical and clinical data can be used for all the analytes/instruments 
                                                           
7 This guidance may be found on CDRHs website at: 
https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm071434.ht
m  
  12  Contains Nonbinding Recommendations 
 
referenced.  You should not bundle multiple analytes, or across test panels or profiles, if 
they present disparate scientific and clinical issues. 
Examples of panels that could be bundled into one submission include: 
(1) Certain population specific respiratory viruses measured simultaneously in one 
system (e.g., Flu A/B and RSV) 
(2) Drugs of abuse (cocaine, THC, opiates, methamphetamine, and amphetamine) panel 
Submissions for antimicrobial susceptibility testing (AST) systems should include only 
one drug, and one method of reading or inoculation. However, you may bundle gram-
negative and gram positive claims (if the same methods of reading and inoculation are 
used for both). 
For any type of premarket submission, assayed controls and/or calibrators may be 
bundled with an assay.  Also, controls or calibrators used for multiple assays (and/or 
multiple platforms) may be bundled to cover their use in all of the assays. 
Multiple Reagents 
You may bundle multiple reagents that are intended to be used together to obtain a profile 
(e.g., to obtain a donor or patient blood group phenotype, or a cardiac panel (troponin, 
CK MB, and myoglobin)) into a single submission.  Whereas a single reagent could be 
submitted as a single submission, there are situations where multiple reagents have many 
commonalities, and the additional information to support each of the reagents is minor 
and does not require substantial review resources.  These multiple reagents may be 
bundled.  Reagents generally should not be bundled if the reagents require separate 
preclinical data, clinical data, or separate statistical analyses of such data sets that would 
preclude efficient review of the submission.  Although CBER accepts separate 
submissions for individual reagents, CBER would consider the applicants designation of 
these separate submissions meeting the above criteria as a bundle for purposes of review 
and user fee payment. 
Multiple Intended Uses 
You generally should not bundle multiple intended uses of a single test system (or 
indications for use such as professional and over-the-counter (OTC) use), because it is 
unlikely that such multiple uses would be supported by the same data sets. 
There may be cases, however, when you could bundle different intended uses.  For 
example, you may not bundle assays intended for the detection of Neisseria menigitidis, 
and Neisseria gonorrhoea, but you may bundle a combination assay in which N. 
gonorrhoea and Chlamydia trachomatis are measured in a single reaction and when the 
same clinical trial using the same specimen type and same population are used. 
  13  Contains Nonbinding Recommendations 
 
Sample Matrix 
Bundling when similar matrices (e.g., serum and plasma) are used generally should be 
appropriate.  You should not bundle dissimilar sample matrices (e.g., hair and/or saliva 
with serum and/or plasma), because the information for review would be expected to be 
substantially different.  For example, a Helicobacter pylori assay indicated for use with 
serum, plasma, and/or finger-stick capillary blood may be bundled.  However, a H. pylori 
breath test, a saliva test, or a stool antigen may not be bundled with a H. pylori assay 
using plasma or serum. 
Replacement Reagent 
The replacement reagent policy entitled, Data for Commercialization of Original 
Equipment Manufacturer, Secondary and Generic Reagents for Automatic Analyzers 
(see www.fda.gov/cdrh/ode/odecl950.html) will continue to apply and those 
associated changes may be made without incurring a fee. 
In Vitro Diagnostic Devices Regulated by CBER 
As with devices reviewed by CDRH, some devices reviewed at CBER are marketed as 
510(k) products, while others are marketed as PMA products.  These products are subject 
to the procedures discussed in this document. Instruments used to test the blood supply 
are regulated as either 510(k) devices or PMA devices.  Reagents and test kits used to test 
the blood supply are regulated as licensed biological products. When the reagents and 
instruments can be used together and significant portions of multiple individual 
submissions would contain the same information, you may bundle the submission for the 
different articles, even though one article is regulated under the device authorities and the 
other under the BLA authorities.  The BLA user fee and review time would apply when 
making such a submission.  Please identify the submissions to be bundled in the cover 
letter submitted with the applications. 
In cases involving a BLA or efficacy supplement where one submission in a bundle is 
delaying approval of the others, CBER may discuss mechanisms for de-linking the 
problem submission so that the others can be finalized.  The remaining portion of the 
bundle would be handled at a later date and the labeling would be revised to include the 
additional reagent.  These cases primarily involve immunohematology reagents. For 
example, ABO/Rh blood grouping reagents that use the same clinical data set and the 
same labeling can be considered for bundling.  If the ABO reagents are ready for 
approval, but the Anti-D reagent has a few issues remaining, CBER would consider 
allowing the applicant to revise the labeling to delete the references to Anti-D and 
approve only the ABO reagents.  Upon subsequent approval of the Anti-D reagent, 
the labeling could be revised to include the references to Anti-D. 
C.  Bundling Procedures 
  14  Contains Nonbinding Recommendations 
 
(13)  How do I bundle multiple devices or indications for 
use in a single submission? 
FDA recommends the following when: 
  Bundling in a 510(k) the same or differing generic device types or 
multiple indications for use for a single device 
As is true for any 510(k), you must provide all the information required by 21 CFR  
807.87.  Therefore, the submission should include the appropriate supporting information 
for each of the different devices or indications for use.  You should also include an 
Indications for Use form for each device in the submission, if individual devices will 
have differing indications for use. 
  Bundling in one 510(k) a change that affects more than one previously 
cleared device 
When submitting one 510(k) for a change that affects multiple devices, you should refer 
to the other previously cleared 510(k)s.  Like all 510(k)s, the 510(k) must provide all the 
information required under 21 CFR  807.87.  You should also provide updated 
Indications for Use forms that address all the devices in the submission, if individual 
devices will have differing indications for use. 
  Bundling in one PMA multiple devices of the same generic device type or 
multiple indications for use for a single device 
When bundling devices of the same generic type in a PMA, you should ensure that you 
provide all the information required by 21 CFR  814.20 to support approval for each of 
the devices, including labeling that addresses all of the devices. 
As stated earlier in this guidance, bundling multiple indications for use in one PMA is 
generally not appropriate.  If, however, much of the data needed to support approval 
of the devices would be the same (e.g., clinical data), you may submit one PMA for 
multiple indications.  You should ensure that the supporting information and the labeling 
address all the indications. 
  Bundling in one PMA supplement a change that affects multiple PMAs 
When bundling a change(s) that affects more than one PMA, you may submit all the 
required information to support approval of the modification, including any associated 
labeling changes that result from the modification, in one PMA supplement. In the cover 
letter for the supplement, you should identify the other affected PMA(s). 
If the affected PMAs are reviewed by different divisions, you may still be able to bundle 
the change(s) in one PMA supplement.  In this situation, you should submit a complete 
  15  Contains Nonbinding Recommendations 
 
copy of the supplement to each PMA, so that each division has its own copy.  The same 
cover letter should be used for each copy and should clearly indicate that the same 
change(s) is being made to each of the affected PMA(s).  The cover letter should identify 
all of the affected PMA(s). 
  Bundling a change that affects a device with 510(k) and PMA indications 
When submitting a change to a device that affects both a previously cleared 510(k) and 
an approved PMA, you should submit a PMA supplement and reference the cleared 
510(k).  In this situation, the PMA review time and user fee would apply for the 
submission. 
  Bundling a 510(k) device and a PMA device in one PMA 
As stated above, in general, a 510(k) device should not be bundled with a PMA device.  
If, however, you have devices that are used together in a procedure or that are part of a 
system, bundling may be appropriate.  In such a case, the PMA should include all the 
information needed to support both approval and clearance of the devices when used as 
indicated.  As above, the PMA review time and user fee would apply for the submission. 
(14)  What will FDA do if devices or indications are 
bundled inappropriately? 
If a submission includes a device or indication that should not be bundled because it 
presents disparate scientific/clinical or regulatory issues (from the other devices or 
indications in the submission), the agency will notify the applicant in writing and request 
that the applicant withdraw the device or indication from the bundled submission.  Upon 
issuance of this letter, the application will be placed on hold.  The applicant may resubmit 
the device or indication for use in a separate submission, withdraw the device or 
indication for use (the review of the rest of the submission will continue), withdraw the 
entire application, or appeal the decision. See related information in question 15. 
(15)  How can I appeal an FDA determination that it is not 
appropriate to bundle a device or indication for use in a 
single application? 
You should refer to 21 CFR  10.75, which outlines the framework for internal review of 
decisions.  Additionally, FDA intends to provide specific recommendations and 
procedures regarding appeals related to user fees in a future guidance document.  While 
the appeal is under review, the submission will remain on hold (to ensure appropriate 
review of the submission and efficient use of resources). 
  16  Contains Nonbinding Recommendations 
 
(16)  Can I add more devices or indications for use to a 
submission once the review of that submission has begun? 
FDA strongly recommends that bundling occur before the application is submitted to the 
agency. 
(17)  Can I withdraw a device or indication for use from 
my premarket submission, for example, because the review 
of that device or indication for use is slowing down the 
review of the others? 
Yes.  Submitters may withdraw a device(s) (or indication for use) from a bundled 
submission for any reason.  You may resubmit the device(s) or indication for use in a 
new application.  Resubmission of a premarket submission for a withdrawn device or 
indication for use will require payment of the fee applicable to the type of submission. 
(18)  How can I get information on the appropriateness of 
bundling certain devices or indications for use before 
submitting a marketing application? 
The persons listed below can assist you with general bundling questions.  For specific 
questions about bundling certain types of devices or indications for use, you should 
contact the branch chief in the appropriate review division. 
Program Operations Staff 
ODE/OIR, CDRH 
(301) 796-5640or by email: 510k_program@fda.hhs.gov 
For devices reviewed by CBER, contact the Office of Communication, Outreach and 
Development at 1-800-335-4709 or 240-402-8010 
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