Hi, my company encountered a problem regarding COE (Certificate of Exportability). I'll appreciate any discussion from any. Here's our situation.
We are a contract manufacturer (lets call us as BBB), who is located outside of the USA, for a legal manufacturer in USA (lets say it is AAA). This product is a Class III medical device. AAA is not going to seek for FDA clearance for the product. Thus, it is an unapproved product.
We (BBB) now would like to import the device into our country. The regulatory in our country required us to provide COE from FDA to prove the product is manufactured by a US company (AAA). However, as we asked AAA to apply for COE, they told us that FDA couldn't issue them COE since we (BBB) take care of the major parts of manufacturing process. FDA needs to do an on-site inspection on us to ensure we (BBB) comply with the current good manufacturing practice requirements.
My question is, if this is true that an unapproved class III product manufactured by a contract manufacturer can't acquire COE before the contract manufacturer being on-site inspected? It seems making no sense for me. We could wait forever before FDA may have a little...little chance to do the on-site inspection on us.
We are a contract manufacturer (lets call us as BBB), who is located outside of the USA, for a legal manufacturer in USA (lets say it is AAA). This product is a Class III medical device. AAA is not going to seek for FDA clearance for the product. Thus, it is an unapproved product.
We (BBB) now would like to import the device into our country. The regulatory in our country required us to provide COE from FDA to prove the product is manufactured by a US company (AAA). However, as we asked AAA to apply for COE, they told us that FDA couldn't issue them COE since we (BBB) take care of the major parts of manufacturing process. FDA needs to do an on-site inspection on us to ensure we (BBB) comply with the current good manufacturing practice requirements.
My question is, if this is true that an unapproved class III product manufactured by a contract manufacturer can't acquire COE before the contract manufacturer being on-site inspected? It seems making no sense for me. We could wait forever before FDA may have a little...little chance to do the on-site inspection on us.