09/30/2026
Accelerated aging data can carry a 510(k) or PMA submission through FDA review. What it cannot do is replace real-time aging entirely. ASTM F1980-21 is explicit: accelerated data supports the initial shelf-life claim, and a parallel real-time arm must ultimately confirm it. The Q10 value, temperature, and humidity choices each need a written rationale in the protocol. A clean accelerated result with no real-time program running is the version that draws reviewer questions.
https://lso-inc.com/news/accelerated-vs-real-time-aging-in-your-submission-dfb9516d/
When ASTM F1980 accelerated aging satisfies an FDA reviewer versus when real-time data is expected, plus Q10, humidity, and extrapolation limits.