21 CFR Part 820 · Quality Management System Regulation

§ 820.35 Control of records

Subpart B - Supplemental Provisions Official text on eCFR Amendment history

In addition to the requirements of Clause 4.2.5 in ISO 13485 (incorporated by reference, see § 820.7 ), Control of Records, the manufacturer must include the following information in certain records:

(a) Records of complaints. In addition to Clause 8.2.2 in ISO 13485, Complaint Handling, the manufacturer shall maintain records of the review, evaluation, and investigation for any complaints involving the possible failure of a device, labeling, or packaging to meet any of its specifications. If an investigation has already been performed for a similar complaint, another investigation is not necessary, and the manufacturer shall maintain records documenting justification for not performing such investigation. For complaints that must be reported to FDA under part 803 of this chapter , complaints that a manufacturer determines must be investigated, and complaints that the manufacturer investigated regardless of those requirements, the manufacturer must record the following information:

(1) The name of the device;

(2) The date the complaint was received;

(3) Any unique device identifier (UDI) or universal product code (UPC), and any other device identification(s);

(4) The name, address, and phone number of the complainant;

(5) The nature and details of the complaint;

(6) Any correction or corrective action taken; and

(7) Any reply to the complainant.

(b) Records of servicing activities. In adhering to Clause 7.5.4 in ISO 13485, Servicing Activities, the manufacturer must record the following information, at a minimum, for servicing activities:

(1) The name of the device serviced;

(2) Any UDI or UPC, and any other device identification(s);

(3) The date of service;

(4) The individual(s) who serviced the device;

(5) The service performed; and

(6) Any test and inspection data.

(c) Unique Device Identification. In addition to the requirements of Clauses 7.5.1, 7.5.8, and 7.5.9 in ISO 13485, the UDI must be recorded for each medical device or batch of medical devices.

(d) Confidentiality. Records deemed confidential by the manufacturer may be marked to aid FDA in determining whether information may be disclosed under the public information regulation in part 20 of this chapter .

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What FDA inspectors cite under § 820.35

Form FDA 483 observations citing this section, fiscal years 2026–2026 (Devices).

  • Records for complaints involving failure to meet specifications not maintained 4
  • UDI was not recorded for each medical device or batch 4
  • Records of complaint investigations do not include required information 3
  • Records of servicing activities do not include required information 2

Warning letters citing § 820.35

1 FDA warning letters since 2017 cite this section :

FDA guidance that cites § 820.35

Amendment history

Federal Register documents that created or amended this section.