FDA 510(k) Review Time and Clearance Timeline: How Long Does It Take?

The average FDA 510(k) review time is 149 days for cleared submissions in 2025, based on 175,730 real FDA submission records. This page tracks 510(k) clearance timelines by year and by FDA specialty panel, and explains the factors that affect how long a 510(k) submission takes from acceptance to decision.

Based on 175,730 FDA submissions · Data sourced from FDA public files · Updated November 2026

149d
Avg cleared 2025
▼ 10d vs 2024
185d
Peak year (2022)
▲ Highest on record
337d
Avg denied submission
▲ 2.3× cleared avg
90d
FDA target (MDUFA IV)
▲ Rarely achieved

510(k) Review Time at a Glance

Key FDA 510(k) review time benchmarks from 175,730 cleared and denied submissions. The FDA's MDUFA target is 90 days — actual clearance timelines are consistently longer due to Additional Information Requests (AIRs) that pause the review clock.

MetricDays
FDA MDUFA target (standard 510k)90d
All-time average (cleared, 2000–2026)129d
Average cleared - last 2 years149d
Average cleared - 2025146d
Average denied submission337d
Fastest panel - last 2 years (Toxicology)90d
Slowest panel - last 2 years (Immunology)227d

Average 510(k) Review Time by Year (2000–2026)

Historical FDA 510(k) clearance timeline data from 2000 to 2026. Average review time peaked at 185 days in 2022 and has declined since. Use this chart to understand how 510(k) review times have evolved and contextualize your submission planning against historical benchmarks.

Average days from FDA acceptance to decision for cleared 510(k) submissions. Source: 510k Database - 175,730 records.

510(k) Review Time by FDA Specialty Panel

Review times differ substantially across the 20 FDA specialty panels. The table below shows all-time average, last 2 years average, and average review time for denied submissions - all based on real cleared and denied 510(k) records.

Panel All-time avg Last 2 years Denied avg Cleared
Toxicology Fastest 86d
94d
284d
3,017
Orthopedic 119d
118d
348d
17,228
General & Plastic Surgery 114d
136d
423d
17,866
Physical Medicine 113d
148d
462d
5,312
Dental 127d
150d
279d
12,607
Radiology 107d
150d
258d
15,634
Microbiology 100d
151d
275d
7,012
Cardiovascular 125d
152d
329d
17,959
Gastroenterology & Urology 130d
154d
293d
9,854
Neurology 146d
154d
419d
6,243
General Hospital 128d
160d
463d
17,717
Hematology 112d
162d
394d
3,286
Ear, Nose, Throat 88d
163d
320d
3,799
Obstetrics & Gynecology 160d
169d
294d
4,492
Ophthalmic 109d
169d
403d
5,081
Chemistry 88d
175d
238d
13,202
Pathology 75d
212d
192d
1,084
Anesthesiology 138d
217d
492d
8,908
Immunology 104d
231d
158d
3,774
Medical Genetics Slowest 317d
349d
515d
12

Factors Affecting FDA 510(k) Review Time and Clearance Timeline

The FDA 510(k) pathway has a statutory 90-day review target under MDUFA IV performance goals. In practice, review times are consistently longer because the 90-day clock stops during any period when the FDA requests additional information from the manufacturer - a process known as an Additional Information Request (AIR) or Hold. This distinction between FDA days (active review time) and calendar days (total elapsed time) is critical for submission planning.

Review times increased steadily from around 100 days in 2000–2006 to a record high of 185 days in 2022. This reflects growing submission volume, increased device complexity, and disruptions caused by the COVID-19 pandemic. The data shows a meaningful reduction since 2023, with 2025 averaging 146 days - the lowest since 2019.

Denied submissions take significantly longer to resolve - an average of 337 days across all panels, compared to 149 days for cleared devices. This reflects the back-and-forth of additional information requests before a final denial decision. The Anesthesiology panel has the longest average denied review time at 500 days.

Manufacturers planning a 510(k) submission should use the last 2 years average for their specific panel as their primary planning benchmark, not the FDA's 90-day target or the all-time average, which reflects historical periods with different FDA workload and processes.

Special 510(k) Timeline vs Traditional 510(k)

The Special 510(k) pathway is designed for modifications to a manufacturer's own cleared device. The FDA's review goal for Special 510(k)s is 30 calendar days — significantly shorter than the 90-day target for Traditional 510(k)s. However, this timeline only applies when the submission qualifies as a Special 510(k) and the FDA does not issue an AIR. If an Additional Information Request is issued, the review clock stops and the actual clearance timeline extends considerably. Manufacturers should verify with their regulatory consultant whether their device modification qualifies for the Special 510(k) pathway before planning their timeline.

What Are FDA Industry Days in 510(k) Review?

FDA industry days refers to the number of days the FDA actively worked on a submission — excluding time when the submission was on hold for an AIR. This metric appears in FDA MDUFA performance data and differs from the total calendar days from submission to decision. The 510k Database calculates review time using calendar days from acceptance date to decision date, which better reflects actual planning timelines for manufacturers.

Frequently Asked Questions

How long does a 510(k) submission take in 2026?
The average FDA 510(k) review time in 2025 is 146 days for cleared submissions, based on 3,195 cleared devices. 2026 data is being updated monthly as new clearances are published. The FDA's official MDUFA target is 90 days, but actual times are consistently higher due to Additional Information Requests (AIRs) where the clock stops. Plan for 5–7 months from acceptance to clearance for most device types.
What is the Special 510(k) timeline?
The Special 510(k) pathway is for modifications to a manufacturer's own cleared device. The FDA's review goal is 30 calendar days, compared to 90 days for a Traditional 510(k). However, this only applies when no Additional Information Request is issued. If the FDA places the submission on hold, the clock stops and total calendar days increase significantly. Special 510(k) submissions must demonstrate that the modification does not affect safety or effectiveness in ways that require new testing.
What is the difference between FDA days and calendar days in 510(k) review?
FDA days (also called "industry days") counts only the days the FDA actively reviewed the submission — excluding any period when the submission was on hold for an Additional Information Request (AIR). Calendar days is the total time from acceptance to decision, including holds. The FDA's 90-day MDUFA target is measured in FDA days, which is why actual calendar day timelines are consistently longer. The 510k Database reports calendar days, which better reflects real planning timelines.
Which FDA panel has the fastest 510(k) review time?
Toxicology is the fastest panel with a last-2-years average of 90 days, followed by Orthopedic at 117 days. Toxicology's low volume (3,015 cleared devices) and device simplicity contribute to its consistently fast review times.
Which FDA panel has the slowest 510(k) review time?
Immunology has the slowest recent average at 227 days, followed by Pathology (217d) and Anesthesiology (211d). These panels typically review higher-risk or more complex devices that require additional clinical or analytical data.
How long does a denied 510(k) take?
Denied submissions take an average of 337 days - more than twice the average cleared submission. The Anesthesiology panel has the longest denied average at 500 days. The extended timeline reflects multiple rounds of additional information requests before the FDA issues a final Not Substantially Equivalent (NSE) decision.
What is the FDA's 510(k) review time target?
Under the Medical Device User Fee Amendments (MDUFA IV), the FDA committed to reviewing 90% of standard 510(k) submissions within 90 FDA days. Note that "FDA days" excludes time when the submission is on hold for additional information - so the actual calendar time is substantially longer. The FDA's MDUFA performance data is published annually.
Why did 510(k) review times peak in 2022?
The 185-day average in 2022 was the highest since records began. Contributing factors include COVID-19 pandemic disruptions to FDA operations (2020–2021), a backlog of submissions, increased submission volume, and greater device complexity. Review times have improved since 2023 as FDA staffing and processes normalized.
Data source: FDA 510(k) public database, processed and maintained by 510k Database. Dataset includes 175,730 submissions from 1976 to present. Review times calculated from FDA acceptance date to decision date. Updated monthly. · About this dataset