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  5. Voluntary eSTAR Program
  1. How to Study and Market Your Device

Voluntary eSTAR Program

 

Person using eSTAR to guide them through maze of medical device submissions.

 

The eSTAR is an interactive PDF form that guides applicants through the process of preparing a comprehensive medical device submission. This template contains:

  • Automation (for example, form construction and autofill)
  • Content and structure that is complementary to CDRH internal review templates
  • Integration of multiple resources (for example, guidances and databases)
  • Guided construction for each submission section
  • Automatic verification

The eSTAR is free and available for voluntary use by all medical device applicants wishing to submit 510(k)s and De Novos to CDRH. The eSTAR is not currently for use with combination products.

The voluntary eSTAR is intended to enhance the incoming quality of submissions for a wide range of medical devices by helping to ensure submitters provide quality, comprehensive data for the CDRH’s premarket review. With a standardized format, submitters can ensure their submissions are complete, and CDRH can conduct premarket reviews more efficiently to help promote timely access to safe, effective, and high-quality medical devices. Due to the use of automatic verification, the CDRH does not intend to conduct a Refuse to Accept (RTA) review for submissions submitted as an eSTAR.


On this page:


How to prepare a submission using eSTAR

  1. Download the proper eSTAR PDF template from the table below and save it before you open it in Adobe Acrobat Pro.

    Using Windows: In Microsoft Edge, right-click the link and select “Save Link As.”

    Using Mac OS: In Safari, press “control” + click the link and select “Download Linked File."

  2. Read, understand, and follow the directions in the Introduction, Key, FAQ, and Version History sections of the eSTAR PDF template.
  3. Fill in the template accordingly.  The template is only used for constructing, not submitting, your submission. The directions at the end of the template provide instructions on how to submit.

File Size: Processing of the submission may be delayed if the eSTAR PDF exceeds 1 GB in size. Please ensure any attached images and videos are compressed in a Microsoft Windows compatible format viewable in native Windows OS applications (for example, JPEG, MP4). Ultra-High-Definition videos should only be provided if high resolution is necessary to support the review of the device. Take care when determining the proper resolution to display features of interest in images and videos.

File Count: Please combine attachments of similar content (for example, Software Requirements Specifications) when possible so that only one attachment needs to be provided to each attachment type question in the eSTAR. Attachments may be combined in Adobe Acrobat Pro by choosing “Tools” then “Combine Files.” We recommend that combined documents have bookmarks or contain a Table of Contents for easier review.

File Version: Although content in the Updated Version of eSTAR, located in the table below, will only be expected when the previous version is retired, you may choose to submit using the Updated Version of eSTAR immediately. Please be sure to use the Updated Version when preparing a new submission if you intend to submit after the retirement date of the previous version. The previous version can be submitted until the retirement date. Although we will not reject retired eSTAR versions if submitted, you may receive additional information requests related to the differences that exist between the submitted version and current version of eSTAR. Changes can be found in the “Version History” section on page one of the eSTAR.

Current eSTAR Versions1:

eSTAR PDF Template (you MUST right-click and download) This eSTAR template may be used to voluntarily submit to CDRH: Content is approved for collection under OMB numbers2:
Updated Version:
Non-In Vitro Diagnostic eSTAR Version 2
510(k) and De Novo medical device submissions for Non-In Vitro Diagnostic devices 0910-0120, 0910-0844

This eSTAR will be retired on August 5, 2022:
Non-in Vitro Diagnostic eSTAR Version 1

510(k) and De Novo medical device submissions for In Vitro Diagnostic devices 0910-0120, 0910-0844
In Vitro Diagnostics eSTAR Version 1 510(k) and De Novo medical device submissions for In Vitro Diagnostic devices 0910-0120, 0910-0844

1Minor version changes would not cause retirement of a prior eSTAR version. Therefore, only the major version numbers of eSTAR are reflected in the table above.

2An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless a currently valid OMB number is provided.

How to submit an eSTAR

Your submission should include:

  • The eSTAR PDF with embedded attachments on a CD, DVD, or USB Drive (SD cards are not accepted)
  • A printed cover letter to the Document Control Center (DCC). For the current mailing address for CDRH's Document Control Center, see eCopy Program for Medical Device Submissions

For example, an acceptable submission package would consist of a printed cover letter accompanying a USB drive containing the eSTAR PDF.

Important: The eSTAR does not need to comply with the eCopy Guidance document and it does not need to be zipped and placed in a MISC FILES folder. Any additional files provided alongside the eSTAR PDF need to comply with the eCopy Guidance document, although we strongly recommend not providing additional files alongside the eSTAR PDF. You do not need to provide an Indications for Use page (FDA Form 3881), the Premarket Review Submission Cover Sheet (FDA Form 3514), or a Declaration of Conformity (if applicable) with your eSTAR since all are built into the eSTAR PDF. In addition, if you choose to use eSTAR to create your 510(k) Summary, you do not need to provide an additional 510(k) Summary with your eSTAR.

After you complete your eSTAR file correctly, the status message at the top will indicate "eSTAR Complete." If you submit your eSTAR file while the status message still indicates "eSTAR Incomplete," the FDA intends to use the eCopy Hold process to put your eSTAR on “eCopy Hold”. The “eCopy Hold” email will include a screenshot of the “Verification” section of the eSTAR that lists the incomplete sections in the submitted eSTAR. Please be advised that the benefits of the eSTAR (for example, no RTA review) are dependent on accurate responses and the FDA intends to verify the accuracy of your responses. Inaccurate responses (for example, inaccurate responses to drop down fields causing the eSTAR to omit subsequent questions) may lead to an early hold in the review of your submission.

CBER eSTAR Pilot

The Center for Biologics Evaluation and Research (CBER) pilot program is free and available for voluntary use by applicants of CBER premarket notification (510(k)) submissions that wish to use the voluntary eSTAR Program. CBER’s voluntary eSTAR Pilot Program is intended to help applicants gain experience with the review of and internal processes for 510(k) submissions using the eSTAR template. It is also intended to help applicants gain experience with use of the FDA Electronic Submissions Gateway for CBER 510(k) submissions using the eSTAR template. During CBER’s voluntary eSTAR Pilot Program, nine participants that meet the selection criteria outlined within the [Federal Register Notice] will have the opportunity to participate in the eSTAR pilot program for submissions to CBER. 

To be considered for CBER’s voluntary eSTAR Pilot Program, a company should submit a statement of interest for participation to [email protected] with the subject line: “CBER Voluntary eSTAR Pilot Program.”  Within the email, the company should:

  • agree to submit a traditional, special, or abbreviated 510(k) for a medical device regulated by CBER using eSTAR within 1 month of acceptance to the CBER voluntary eSTAR Pilot Program. 
  • provide a detailed description of the device to allow CBER to verify that the device is a CBER-regulated device.
  • have a willingness to provide feedback on eSTAR.

Participants selected for CBER’s voluntary eSTAR Pilot Program should include the eSTAR PDF with embedded attachments and the cover letter in their submissions, and provide them to the FDA: 

Whom do I contact if I have questions about CBER’s eSTAR Pilot?

  • If you have questions or feedback regarding CBER’s voluntary eSTAR Pilot Program, an eSTAR PDF submitted to CBER, or if you have general questions about medical devices submitted to CBER, please contact the CBER Manufacturers Assistance and Technical Training Branch (MATTB) by email at [email protected]
  • If you have any questions of submissions submitted to CBER through the Electronic Submission Gateway, please contact [email protected].

How to submit responses to requests for additional information

Revise your original eSTAR and indicate in the "Application/Submission Type" section of the eSTAR that the Application Sub-Type is a response to a request for additional information. After you indicate the intent to provide a response to a request for additional information from the FDA, an additional section will appear near the end of the eSTAR where you can provide responses to requests for additional information.

What are the eSTAR Program MDUFA User Fees?

The eSTAR submissions are subject to user fees. For the current User Fee amounts, please see MDUFA User Fees.

What is the Review Timeline?

After the FDA receives an eSTAR-prepared submission, the FDA does not intend to conduct the RTA process. The remainder of a 510(k) review will be conducted according to the FDA guidance, "The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)],” following the procedures identified in 21 CFR 807 subpart E. A De Novo review will be conducted according to the FDA guidance, “De Novo Classification Process (Evaluation of Automatic Class III Designation),” following the procedures identified in 21 CFR 860, subpart D.

Whom do I contact if I have questions?

If you have questions or feedback regarding the voluntary use of the eSTAR for medical devices regulated by CDRH, or if you have general questions about medical devices, please contact the Division of Industry and Consumer Education (DICE) by email at [email protected], or by phone at (800) 638-2041, or (301) 796-7100.

If you find any malfunctions or errors in the eSTAR template for medical devices regulated by CDRH, please contact [email protected]

If you have questions regarding 510(k)s or De Novos for medical devices regulated by CDRH, please contact [email protected].

More Information

For more information on requirements for electronic submissions, see the FDA’s guidance document, “Providing Regulatory Submissions for Medical Devices in Electronic Format - Submissions Under Section 745A(b) of the Federal Food, Drug, and Cosmetic Act.” The Agency has concluded that it is not feasible to describe and implement the electronic submission templates that would apply to all the submissions covered by Section 745A(b)(3) in one guidance document. Accordingly, individual guidance documents will be developed to specify the formats for specific submission types and corresponding timetables for implementation.

In February 2020, to support the transition of premarket notification [510(k)] submissions being provided solely in electronic format, CDRH developed and piloted the use of the electronic Submission Template And Resource (eSTAR). On September 8, 2020, CDRH expanded the use of the eSTAR to all 510(k) submitters that were not submitting combination products. Subsequently, to move towards consistent implementation of Section 745A(b) for 510(k)s, on September 29, 2021, the FDA issued a draft guidance: Electronic Submission Template for Medical Device 510(k) Submissions. The draft guidance outlines the structure, format, and use of the eSTAR for preparing electronic 510(k) submissions. When finalized, the guidance will represent the current thinking of the FDA regarding this topic and, pursuant to Section 745A(b)(3), require the electronic submission of 510(k)s in accordance with the corresponding timetable identified in the final guidance.

To further support transitioning to utilization of electronic formats for other types of marketing submissions, CDRH has also added the ability to prepare De Novo requests in the eSTAR. De Novo content in the eSTAR, consistent with the De Novo final rule, was provided to permit voluntary eSTAR De Novo requests to the FDA. It is anticipated that the next draft guidance on the content of the eSTAR for a specific submission type will be for De Novo requests.

In June 2022, CBER initiated a pilot to further expand the use of eSTAR for CBER-led medical devices.   

Definitions:

eCopy: An electronic copy is a submission created and submitted on a compact disc (CD), Digital Versatile Disc (DVD), or flash drive and mailed to the FDA, and which is a duplicate of the previously required paper copy sent to the FDA. An eCopy is not considered an eSubmission.

Electronic Submission template: A guided submission preparation tool for industry. An electronic submission template walks industry through the relevant contents and components for the respective premarket submission type and device to facilitate submission preparation and enhance consistency, quality, and efficiency in the premarket review process.

eSTAR (electronic Submission Template And Resource): An electronic submission template built within a structured dynamic PDF that guides a user through construction of an eSubmission. The eSTAR is the only type of electronic submission template that is currently available to facilitate the preparation of eSubmissions. For simplicity, the electronic submission created with this electronic submission template is often referred to as an eSTAR.

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