Glossary

De Novo

A De Novo application is a submission pathway used by medical device manufacturers seeking to market an entirely new product for which no existing classification exists. The U.S. FDA uses this process to evaluate and classify the device as Class I or Class II – rather than automatically assigning Class III, the highest-risk category – ensuring accurate, risk-based regulation for innovative medical technologies.

Description

The De Novo pathway provides a route for novel devices, in vitro diagnostics or medical software that lack a legally marketed predicate. It allows manufacturers to demonstrate safety and effectiveness through appropriate clinical and non-clinical evidence while avoiding unnecessary regulatory burden.

Developing a De Novo submission is a complex, multi-stakeholder process. It involves regulatory teams, medical writers, engineers, quality specialists and external reviewers working collaboratively to compile structured evidence, risk analyses and labeling content. Traditional document creation can be slow and error-prone, particularly when multiple departments exchange drafts across disparate systems. Using structured content authoring within a Component Content Management System (CCMS) such as Tridion Docs streamlines this process. Authors and reviewers can collaborate concurrently in a single online environment, track changes transparently and maintain full version control across every component – from device descriptions to clinical summaries. Structured content ensures consistent terminology, traceable updates and audit-ready documentation – significantly accelerating time-to-submission.

Example use cases

  • New devices: Preparing applications for novel medical devices or software-as-a-medical-device (SaMD).
  • Collaboration: Collaborating across regulatory, quality and clinical teams in real time.
  • Audit trails: Maintaining a validated audit trail for every author and reviewer action.
  • Reuse: Reusing approved components across related submissions or labeling documents.
  • Efficiency: Reducing re-authoring when updating device data or risk analyses.

Key benefits

Speed
Create, review and publish documentation within a single controlled workspace.
Accuracy
Maintain consistent taxonomies, terminology and metadata.
Compliance
Ensure FDA requirements are met with audit-ready content.
Collaboration
Enable concurrent authoring and review by distributed teams.
Collaboration
Reuse approved content across submissions to reduce time-to-market.

RWS perspective

At RWS, we help life-sciences organizations modernize their regulatory workflows through structured content and intelligent automation.

Using Tridion Docs, we enable medical device manufacturers to produce and maintain De Novo applications that are compliant, traceable and efficient. Our Human + Technology approach combines regulatory expertise with content automation – giving teams the tools to manage taxonomies, reuse data and collaborate securely online. By embedding structure and governance into every stage of the submission process, RWS empowers organizations to bring innovative devices to market faster – with documentation that’s accurate, compliant and future-ready.