The process of comparing a new device to an already-marketed predicate device to prove substantial equivalence is a core driver of the US device market. It also aligns with the iterative innovation cycle, where products are continually updated to enhance outcomes and usability, that the device industry embraces.
But the reality, both FDA and industry say, is that it is proving increasingly difficult to show substantial equivalence between an advanced-technology approach to a problem and a device in the
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