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An example report, for a made-up over-the-counter pulse oximeter. The PDF is what arrives by email. Get one for your device.

Pathway report

Over-the-Counter Fingertip Pulse Oximeter Pathway

A fingertip pulse oximeter sold over the counter at pharmacies and online. Adults with COPD use it at home to spot-check their blood oxygen level and pulse rate, and call their doctor if the reading drops. Two AAA batteries, reusable, no alarms, no app.

Draft Prepared by software from FDA records on 2026-09-24 and read by a second model. It proposes; a regulatory professional decides. Not regulatory advice.

Your deviceProduct codeOLKExempt510(k)De NovoPMA
Proposed product code
OLK Pulse Oximeter For Over-The-Counter Use High
Regulation
21 CFR 870.2700 · Class 2
Proposed pathway
510(k) HighThe route FDA has on record for OLKFDA's goal: a decision in 90 FDA days · fee $28,653, or $7,163 for a small business

What a 510(k) means

You show FDA the device is substantially equivalent to one already on the market: the same intended use, and technology that raises no new questions of safety and effectiveness.

FDA's review goal
A decision within 90 FDA days; days waiting on you do not count
FDA fee from Oct 1, 2026
$28,653, or $7,163 as a small business
Small business saving
$21,490, with gross receipts of $100 million or less
Every year after launch
Establishment registration, $13,785 (no small-business rate)

Small business rate. Qualify first, then pay: send FDA Form 3602N with your latest tax return (and any affiliates') through the CDRH Portal. FDA aims to decide within 60 days, and the status lasts one fiscal year, to September 30, so apply in the year you submit. How to apply

Sources: FDA user fees for FY2027 (Federal Register, July 30, 2026), MDUFA V performance goals, FDA small business program.

High the FDA record says it outright · Medium the record plus one inference · Low a reading of the description; check it

We assumed: The stated spot-check use is intermittent rather than continuous monitoring. The device measures oxygen saturation optically through a fingertip, as is inherent in the described pulse oximeter type.

1. Classification and pathway

OLK (pulse oximeter for over-the-counter use) specifically covers a non-wearable fingertip pulse oximeter used OTC for non-continuous monitoring, matching the stated device and use. High

Every product code considered

CodeDevice nameFits?What distinguishes it
QWEHyperoxia Monitoring Device Adjunct To Pulse Oximetry21 CFR 870.2720 · Class 2 · 510(k)noQWE (hyperoxia monitoring device adjunct to pulse oximetry) monitors elevated hemoglobin oxygen saturation as an adjunct, while this device spot-checks oxygen saturation and pulse rate. High
QYUInfant Pulse Rate And Oxygen Saturation Monitor For Over-The-Counter Use21 CFR 870.2705 · Class 2 · 510(k)noQYU (infant pulse rate and oxygen saturation monitor for OTC use) is intended for infants, while the stated users are adults with COPD. High
OLKPulse Oximeter For Over-The-Counter Use21 CFR 870.2700 · Class 2 · 510(k)yesThe proposed code, for the reason above. High
MUDOximeter, Tissue Saturation21 CFR 870.2700 · Class 2 · 510(k)noMUD (oximeter, tissue saturation) is exemplified by devices measuring regional tissue saturation, while this device is described as measuring blood oxygen saturation at a fingertip. High
QVTMonitor For Opioid Induced Impairment Of Oxygenation21 CFR 868.2250 · Class 2 · 510(k)noQVT (monitor for opioid induced impairment of oxygenation) detects desaturations resulting from opioid overdose, a purpose not stated for this COPD spot-check device. High
OUWInfant Positioner, Rx, Use In Highly Monitored Setting21 CFR 880.5680 · Class 1 · 510(k)noOUW (infant positioner, Rx, use in highly monitored setting) is an infant positioning device rather than an oximeter. High
MMAOximeter, Fetal PulseClass 3 · PMAnoMMA (oximeter, fetal pulse) concerns fetal oxygen saturation monitoring, while the stated users are adults. High
NMDOximeter, Tissue Saturation, Reprocessed21 CFR 870.2700 · Class 2 · 510(k)noNMD (oximeter, tissue saturation, reprocessed) is for reprocessed devices, and this product is described as a reusable device rather than a reprocessed device. High
PGJOximeter, Wellness21 CFR 870.2700 · Class 2 · Enforcement discretionnoPGJ (oximeter, wellness) is for wellness use, while this device is intended for adults with COPD to monitor blood oxygen and contact their doctor when a reading drops. High
DQAOximeter21 CFR 870.2700 · Class 2 · 510(k)maybeDQA (oximeter) is a broader oximeter code that covers related pulse oximeters, but OLK is preferred because its definition specifically matches OTC fingertip, non-continuous use. High
QEMCerebral Oximeter21 CFR 870.2700 · Class 2 · 510(k)noQEM (cerebral oximeter) measures cerebral tissue saturation, not fingertip blood oxygen saturation. High
KLKMonitor, Oxygen, Cutaneous, For Infant Not Under Gas Anesthesia21 CFR 868.2500 · Class 2 · 510(k) exemptnoKLK (monitor, oxygen, cutaneous, for infant not under gas anesthesia) uses a heated skin sensor to monitor cutaneous oxygen tension, not fingertip pulse oximetry. High
CCEAnalyzer, Gas, Oxygen, Partial Pressure, Blood-Phase, Indwelling21 CFR 868.1200 · Class 2 · 510(k)noCCE (indwelling blood oxygen partial pressure analyzer) measures in-vivo blood oxygen partial pressure with a catheter-tip transducer, not fingertip oxygen saturation. High
NLFOximeter, Reprocessed21 CFR 870.2700 · Class 2 · 510(k)noNLF (oximeter, reprocessed) is for reprocessed oximeters, whereas the description does not identify this product as reprocessed. High
DQECatheter, Oximeter, Fiber-Optic21 CFR 870.1230 · Class 2 · 510(k)noDQE (fiberoptic oximeter catheter) estimates blood oxygen saturation using a catheter, unlike this external fingertip device. High
OCHOximeter, Infrared, Sporting, Aviation21 CFR 870.2700 · Class 2 · Enforcement discretionnoOCH (oximeter, infrared, sporting, aviation) is solely for sporting and aviation activities, while this product is intended for home medical monitoring by adults with COPD. High

Pathway

Proposed: 510(k). OLK is Class II and not 510(k) exempt, and its definition expressly covers OTC fingertip pulse oximetry for non-continuous monitoring; the described medical use falls within that intended-use category. High

  • Why not De Novo: De Novo is not proposed because OLK covers this OTC, fingertip, non-continuous monitoring use.
  • Why not PMA: PMA is not proposed because the best-fitting candidate OLK is Class II, not Class III.

What would change the answer

IfThen
The labeled use were limited to wellness without a medical purpose.Reassess whether the product is a medical device and whether PGJ (oximeter, wellness) is the relevant reference. Medium
The device were intended for continuous monitoring or for a different patient population or clinical purpose.Reassess whether OLK still covers the intended use and whether another product code is more appropriate. Medium

3 checks for this section are under What to confirm next