Regulatory Status (United States)
Factual, neutral, device-centered.
Per the corrected FDA baseline (2026-05-21): medicinal leeches were the second living organism FDA-cleared (after maggots in January 2004). Cleared under 510(k) K040187 on June 21, 2004 — NOT under product code 880.5475 or as "Class II". The product code is NRN; classification is Unclassified Pre-Amendment. See FDA jurisdiction entry for full regulatory documents.
FDA classification
Medicinal leeches are listed by FDA under product code NRN with device-centered indication language focused on venous congestion associated with graft tissue healing. [S1][S3]
Public 510(k) documentation provides supporting labeling context (examples include K040187 and K140907). [S3][S4]
This site summarizes classification and oversight neutrally and does not interpret classification as an expansion of indications.
510(k) clearance history
Center assignment transition
CBER transfer (administrative)
The transfer from the Center for Devices and Radiological Health (CDRH) to the Center for Biologics Evaluation and Research (CBER) reflects FDA's broader reorganization of biological products. For hospitals and clinicians, the practical impact is minimal: 510(k) clearances remain valid, and the cleared indication language is unchanged.
CDRH → CBER crosswalk
The December 30, 2024 transfer is administrative. The table below itemizes what changes (which FDA center receives new submissions) and what does not (every active clearance, indication, and regulatory identifier). No clinician needs to take action; no procurement contract is invalidated.
| Aspect | CDRH (pre-Dec 30, 2024) | CBER (post-Dec 30, 2024) |
|---|---|---|
| FDA center | Center for Devices and Radiological Health (CDRH) | Center for Biologics Evaluation and Research (CBER) |
| Regulatory pathway | 510(k) premarket notification | 510(k) premarket notification (unchanged) |
| Product code | NRN (medicinal leech) | NRN (unchanged) |
| CFR regulation | No device-specific CFR section (Pre-Amendment) | No device-specific CFR section (unchanged) |
| Classification | Unclassified — Pre-Amendment | Unclassified — Pre-Amendment (unchanged) |
| Active 510(k) clearances | K040187 (Ricarimpex, June 21, 2004) · K132958 (Biopharm, February 19, 2014) · K140907 (Carolina Biological, August 7, 2015) | All three remain valid; CBER tracking BK251211, BK251217, BK251218 |
| Cleared indications | Venous congestion in grafts, flaps, and replants (microsurgical salvage) | Identical — indication language unchanged |
| Marketing status | Cleared device, legal interstate sale to qualified purchasers | Identical — no change to marketing or distribution |
| New 510(k) submissions | Received by CDRH | Received by CBER (effective Dec 30, 2024) |
| Clinical impact for hospitals | — | None. No protocol revision, supplier change, or credentialing impact. |
Plain-English summary
Source: FDA Federal Register notice, December 30, 2024 (transfer of regulatory authority for medicinal leeches and other biological products from CDRH to CBER). The transfer reflects FDA's broader reorganization of biological products; it is not a re-evaluation of safety, efficacy, or indication scope.
Cleared vs off-label vs investigational
| Context | Meaning | Typical governance |
|---|---|---|
| Cleared | Use within labeled indication language (device-centered) — e.g., venous congestion associated with graft tissue healing. [S1][S3] | Institutional protocol, credentialing, infection control, and documentation aligned with hospital policy. |
| Off-label | Use outside labeled indication at clinician discretion, subject to institutional policy and risk governance. | Credentialing, pharmacy stewardship, infection control, and documentation requirements typically apply. |
| Investigational | Use under defined protocol contexts (e.g., IRB, registry, research protocol) with explicit endpoints and safety monitoring. | Protocol governance, data dictionary, adverse event reporting, and neutral results reporting. |
International regulatory context
Regulatory frameworks for medicinal leeches vary by jurisdiction. The following provides a factual summary of major markets:
| Jurisdiction | Authority | Classification | Status |
|---|---|---|---|
| United States | FDA (CBER) | 510(k) cleared medical device | 3 active clearances |
| European Union | National authorities (MDR) | Traditional medicinal use | Widely practiced; regulatory framework varies by member state |
| Germany | BfArM | Arzneimittel (pharmaceutical) | Regulated as pharmaceutical product; insurance-covered in some cases |
| Russia | Roszdravnadzor | Medical product | Established practice with breeding facilities |
| Canada | Health Canada | Case-by-case | Used in clinical settings; no specific leech classification |
Institutional boundaries (governance-level)
Hospitals typically formalize boundaries for credentialing, infection control, pharmacy stewardship, documentation, and adverse event escalation.
Procurement traceability and chain-of-custody documentation are positioned as best practices to support audit readiness, reporting, and quality processes.
Practical guidance for institutions
Procurement
- Order from FDA-cleared suppliers only (verify active 510(k) status)
- Maintain chain-of-custody documentation from receipt to use
- Establish backup supplier agreements for continuity
Clinical protocol
- Define credentialing requirements for practitioners
- Implement infection control protocols (Aeromonas prophylaxis)
- Establish adverse event reporting and documentation standards
Last updated: March 18, 2026
References
- [S1]
FDA Product Classification — Device leeches, medicinal (Product Code NRN)
Device classification entry for medicinal leeches under product code NRN.
- [S2]
Federal Register (GovInfo PDF) — Transfer of regulatory responsibility to CBER (FR Doc. 2024–31266)
Federal Register / GovInfo(2024-12-30)https://www.govinfo.gov/content/pkg/FR-2024-12-30/pdf/2024-31266.pdfAdministrative transfer of regulatory responsibility; effective December 30, 2024.
- [S3]
FDA 510(k) — K040187 (Indications for Use language)
- [S4]
FDA 510(k) — K140907 (510(k) summary; indications language and context)
- [S9]
FDA 510(k) — K132958 (Biopharm Leeches, February 2014)