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To date, there are more than 80 reports of vascularized composite allografts (VCAs; a.k.a. composite tissue allotransplantation). However, the classification of this type of transplantation for oversight purposes has not been clarified. From a biological and regulatory perspective, we propose that VCA retrieval and transplantation is akin to organ transplantation and should be incorporated into the organ oversight structure. As VCA becomes more of a clinical reality, the need for a methodical approach to allocation and access to more donors will develop. Such an allocation system will likely incorporate parameters that deviate from those used for organ transplantation. To develop an effective and balanced system, the use of existing regulatory agencies that oversee solid organs should provide the maximum benefit to the patients and the society.