MEDICAL DEVICES / U.S. MARKET ENTRY
FDA Initial
Importer.
Regulatory support.
Before arrival.
Specialized U.S.-based regulatory support for medical device manufacturers.
DISCUSS INITIAL IMPORTER SUPPORT ↗
Role Prepare Compare Plan
01 / MEDICAL DEVICES
Understand
the role.
What is an Initial Importer?
An Initial Importer is a U.S.-based importer that furthers the marketing of a foreign manufacturer’s medical device
to the final seller or user without changing its packaging or labeling.
The role includes applicable FDA establishment registration, medical device reporting, corrections and removals,
and postmarket recordkeeping duties. This regulatory role goes beyond shipping, sales, or storage and does not
necessarily require physical handling of the goods.
By designating PCG, you engage a U.S.-based FDA regulatory firm that monitors compliance, supports FDA
communications, and assists with import and postmarket issues within the agreed scope. Manufacturer
responsibilities remain with the manufacturer.
FDA ROLE
Initial Importer
An FDA medical device importer role with applicable compliance, reporting, recordkeeping, and postmarket
duties. Physical handling of goods is not necessarily required.
CUSTOMS ROLE
Importer of Record
A customs designation responsible for entry declarations, duties, taxes, and applicable customs obligations
during the import process. This role is distinct from FDA Initial Importer duties.
02 / MEDICAL DEVICES
Prepare
the essentials.
Required Regulatory Services: PCG onboarding requirements, subject to your device and
establishment activities.
01 / REQUIRED
Establishment Registration
02 / REQUIRED
U.S. Agent Designation
03 / REQUIRED
Device Listing
04 / REQUIRED
Initial Importer
05 / REQUIRED
FDA Label Compliance Review
06 / REQUIRED
GUDID & UDI Submission (if applicable)
Label Compliance Review Service
PCG reviews product labeling, label claims, and applicable mandatory FDA labeling elements before U.S. import
to assess compliance and reduce regulatory risk.
Label review is required for PCG Initial Importer onboarding to assess labeling compliance and reduce import
and postmarket risk. The Initial Importer assumes applicable regulatory duties for devices entering the United
States. Manufacturer obligations remain with the manufacturer.
03 / MEDICAL DEVICES
Compare
the support.
Why an Initial Importer, not a distributor or warehouse?
SERVICE MODEL
PCG Initial Importer
Dedicated regulatory duties, compliance monitoring, FDA communication, and postmarket support within the
agreed service scope.
SERVICE MODEL
Distributor
Primarily focused on sales. Regulatory capabilities and contracted duties vary.
SERVICE MODEL
Warehouse
Primarily focused on storage. Regulatory capabilities and contracted duties vary.
Initial Importer Service
Comparison Chart
01 / FEATURE
Initial importer designation
PCG — Provided
COMPETITOR A — Provided
COMPETITOR B — Provided
02 / FEATURE
U.S. agent
PCG — Provided
COMPETITOR A — Provided
COMPETITOR B — Provided
03 / FEATURE
Import clearance & border support
PCG — FDA communication support
COMPETITOR A — Not publicly indicated
COMPETITOR B — Not publicly indicated
04 / FEATURE
Postmarket management
Complaints, recalls, MDRs, corrections & removals
PCG — Reporting & record support
COMPETITOR A — Limited disclosed scope
COMPETITOR B — Regulations mentioned; scope unclear
05 / FEATURE
Recordkeeping & regulatory alignment
21 CFR 803 / 806 / 807 / 820 / 821
PCG — Applicable CFR support
COMPETITOR A — Part 807 support disclosed
COMPETITOR B — Scope unclear
06 / FEATURE
FDA inspection support
PCG — Inspection readiness support
COMPETITOR A — Qualification not verified
COMPETITOR B — Qualification not verified
07 / FEATURE
Visible expertise & industry presence
PCG — Established regulatory practice
COMPETITOR A — Limited public information
COMPETITOR B — Limited public information
08 / FEATURE
FDA regulatory liaison
PCG — Provided
COMPETITOR A — Not publicly indicated
COMPETITOR B — Not publicly indicated
Comparison reflects PCG’s published assessment. Unverified or undisclosed services are not assumed unavailable.
04 / MEDICAL DEVICES
Plan before
you ship.
Cost Comparison: PCG vs. Self-Importing
SELF-IMPORTING
$13,785
FY2027 FDA establishment registration fee, where applicable. Plus registration service and U.S. agent fees. You
manage importer compliance and inspection response. Noncompliance can lead to FDA enforcement.
PCG INITIAL IMPORTER
Tailored quote
Your quote depends on the number of product codes and the manufacturers or facilities represented.
PCG or its designated affiliate performs contracted importer duties and provides guidance. Inspection
engagements are quoted separately. Manufacturer registration fees and obligations remain separate.
Proactive compliance
Arrange compliant importing before shipment. A last-minute Initial Importer designation does not guarantee FDA
acceptance or shipment release. FDA may refuse entry; export or destruction may be required under applicable
procedures.
PCG can assist when noncompliance is identified, but the FDA inspector retains discretion.
Prepare before
arrival.
Discuss your device, regulatory requirements, and initial importer arrangement.
DISCUSS INITIAL IMPORTER SUPPORT ↗
