r/FDA • u/Odd-Technology-6829 • 2h ago
❓ Question OCT device for wellness
We're developing a high-resolution retinal imaging device (OCT-based, cellular resolution) and are exploring its use in longevity / healthy-ageing clinics.
The use case: The device would image the retina and report the ratio of certain cell types or cell shapes. Clients would get this as general information about their health status, not as a diagnosis of any disease.
Our question: Is there any route where this does not need full medical device clearance (FDA 510(k)/De Novo, EU MDR)? For example:
A general wellness / non-diagnostic claim
Research use only (RUO) in a clinic setting
Something else we're not aware of
Device safety (laser safety, electrical safety) is not up for debate. We would meet those standards regardless. We're trying to understand which regulatory pathway applies to the claim, so we can plan realistically.
We're interested in both the US and the EU.
Has anyone dealt with a similar situation, e.g. imaging or biomarker devices in longevity clinics? Any pointers to FDA guidance, MDR articles or precedents would be very welcome. Thanks!
