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What are the consequences of distributing unapproved IVDs labeled for research use only (RUO) or investigational use only (IUO)?

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About the Author
Proxima CRO Team
Joel Reid
Regulatory Affairs Associate
Throughout his experience at Proxima, Joel has developed his skills to advise companies in the best path forward in the development of drugs and devices across a range of therapeutic and diagnostic areas.

FDA is concerned that the distribution of unapproved and uncleared IVD products labeled RUO or IUO, but intended for purposes other than research or investigation (for example, for clinical diagnostic use), has led, in some cases, to the clinical diagnostic use of products with unproven performance characteristics, and with manufacturing controls that are inadequate to ensure consistent manufacturing of the finished product. Use of such tests for clinical diagnostic purposes may mislead healthcare providers and cause serious adverse health consequences to patients, who are not aware that they are being diagnosed with or treated based on the results of tests with research or investigational products.

RUO and IUO labeling must be consistent with the manufacturer’s intended use of the device. This applies to IVD products that have not been approved, cleared or licensed for any use, and is not intended to address off-label uses of any approved, cleared or licensed products.

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