This document provides guidance on FDA’s interpretation of the statutory requirement for  submission in electronic format; however, this document also contains guidance on additional  submission types for which submission in electronic format is anticipated to be recommended.
Therefore, to the extent that this guidance describes recommendations that are not “standards,” “timetable,” or “criteria for waivers” and “exemptions” under section 745A(b)(3), this document  does not create or confer any rights for or on any person and does not operate to bind FDA or the public, but does represent the Agency’s current thinking on this topic. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. If  you want to discuss an alternative approach, contact the FDA staff listed on the title page of this guidance.

Providing Regulatory Submissions for Medical Devices in Electronic Format — Submissions Under Section 745A(b) of the Federal Food, Drug, and Cosmetic Act