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  6. Adverse Event Reporting for Medical Devices Under Emergency Use Authorization (EUA)
  1. Coronavirus (COVID-19) and Medical Devices

Adverse Event Reporting for Medical Devices Under Emergency Use Authorization (EUA)

May 12, 2023 – The COVID-19 public health emergency (PHE) declared under section 319 of the Public Health Service (PHS) Act expired on May 11, 2023.

The end of the PHE under section 319 of the PHS Act does not impact the FDA’s ability to authorize devices, including tests, for emergency use. Existing emergency use authorizations (EUAs) for devices remain in effect and the FDA may continue to issue new EUAs going forward while the EUA declarations under section 564 of the Federal Food, Drug, and Cosmetic Act are in effect and when the criteria for issuance of an EUA are met. Additional information is provided on the page FAQs: What happens to EUAs when a public health emergency ends?

This page answers questions about adverse event reporting for medical devices distributed under Emergency Use Authorizations (EUAs) and points out a number of adverse event reporting-related resources.


Q: What are the adverse event reporting requirements for manufacturers of medical devices under an EUA?

A: Each Emergency Use Authorization (EUA) includes Conditions of Authorization that specify the adverse event reporting requirements for authorized devices. Generally, each EUA includes a condition that the EUA holder follow the reporting requirements in 21 CFR Part 803. Manufacturers should refer to their EUA letter for a given authorized device for the particular reporting requirements.  MDRs for EUA devices can be submitted via the same mechanisms used for non-EUA devices.

Medical device reporting under 21 CFR Part 803 generally requires reporting of deaths, serious injuries, and malfunctions that have, may have, or would be likely to cause or contribute to a death or serious injury. For more information regarding adverse event reporting for authorized medical devices, please refer to Section III.E.2 of the FDA guidance document, Emergency Use Authorization of Medical Products and Related Authorities. General information about reporting MDRs under 21 CFR Part 803 can be found on FDA’s webpage: Mandatory Reporting Requirements: Manufacturers, Importers and Device User Facilities.

Q: How do manufacturers submit an MDR for their medical devices?

A: FDA has established an Electronic Medical Device Reporting (eMDR) system, as described in FDA’s guidance document, Questions and Answers about eMDR - Electronic Medical Device Reporting. Submission of MDRs using the eMDR system involves creating an account capable of submitting reports to the FDA-wide Electronic Submissions Gateway and the completion of FDA Form 3500A in electronic format to capture the event information.

As part of creating an eMDR gateway account for submitting MDRs, a device establishment typically provides the FDA Establishment Identifier (FEI) number received as part of the Registration and Listing process. In some instances, FEI numbers are created outside of the Registration and Listing process. To retrieve an FEI number assigned to your device establishment, you may visit the FEI Search Portal. If an FEI has not been previously assigned, you can request an FEI number by email (see below).

Also see the question below, Q: What product codes should be used when preparing adverse event reports for these products?, for more information on what to include in the MDR.

Q: How does a device establishment create an eMDR account if it is not required to register and list?

A: If your device establishment is not required to register and list, but you are seeking to submit MDRs for a device available, you can request an FEI number by email to [email protected] by including the following information:

  • Device establishment name and address
  • Device Owner Operator number (if known)
  • Establishment type
  • Device panel
  • Official correspondent name, email, and telephone number
  • U.S. Agent name, email, and telephone number (for foreign device establishments)

There is no cost associated with requesting an FEI number. Before requesting an FEI number, device establishments should check the FEI Search Portal to ensure a number has not already been assigned to them.

Creating an FEI number in this way is not a substitute for Registration and Listing and does not satisfy any Registration and Listing requirements.  Device establishments wishing to register and list should follow the Registration and Listing process listed on the FDA website.

For more information regarding the electronic submission of MDRs, please refer to the FDA guidance document, Questions and Answers about eMDR - Electronic Medical Device Reporting. In addition, see eMDR – Electronic Medical Device Reporting for details on how to set up an account for submitting these reports.

Q: What are the specified time frames for submitting MDRs?

A: According to the Code of Federal Regulations, 21 CFR Part 803, manufacturers must submit MDRs to the FDA no later than 30 calendar days after becoming aware of the reportable event, or within 5 calendar days for events necessitating remedial action to prevent a risk of substantial harm to the public health.

Q: The FDA issued a guidance document, Guidance for Industry: Postmarketing Adverse Event Reporting for Medical Products and Dietary Supplements During a Pandemic. Do the adverse event reporting recommendations in this guidance document apply to medical devices under EUA?

A: The guidance does not apply to medical devices under EUA. Page 2 of the guidance states that, “… this guidance does not address monitoring and reporting of adverse events that might be imposed as a condition for medical products authorized for emergency use under section 564 of the Federal Food, Drug, and Cosmetic Act (FD&C Act) (21 U.S.C. 360bbb-3).” The EUAs issued for medical devices related to COVID-19 all include Conditions of Authorization for adverse event reporting.

Q: What are the reporting expectations for patients, health care professionals, and consumers using medical devices under EUA?

A: Patients, health care professionals, and consumers who experience a problem with a medical device under an EUA are encouraged to report these problems to the FDA. These reports can provide important safety information that complements information submitted by manufacturers. Such reports can be submitted to the FDA through MedWatch, the FDA Safety Information and Adverse Event Reporting Program, using the following methods:

Q: What product codes are to be used when preparing adverse event reports for devices authorized under an EUA?

A: When submitting MDRs, the product code is used to ensure the MDR can be appropriately analyzed and reduce the need for follow-up from the FDA.  Medical devices for COVID-19 that have been granted an EUA and their respective product codes are listed on the Coronavirus Disease 2019 (COVID-19) Emergency Use Authorizations for Medical Devices web page.

The list below includes product codes for some of the medical devices that are currently authorized under EUAs:

Device Types

Q: Whom should I contact if I have any questions about adverse event reporting for my medical device?

A: If you have a general question related to adverse event reporting for medical devices under EUA, send an email to [email protected].

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