Rule number
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Ruletitle
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General explanation
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Class
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Rule
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Examples
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Practical Issues of classification
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Rule 1
Devices that either do not come in direct contact with the patient or contact intact skin only
This is a fall-back rule applying to all devices that are not covered by a more specific rule. This is a rule that applies in general to devices that come into contact only with intact skin or that do not come in direct contact with the patient.
I (Klasse 1)
All non-invasive devices are classified as class I, unless one of the rules set out hereinafter applies
- Devices intended in general for external patient support (e.g. hospital beds, patient hoists, walking aids, wheelchairs, stretchers, dental patient chairs) - Body liquid collection devices intended to be used in such a way that a return flow is unlikely (e.g. to collect body wastes such as urine collection bottles, incontinence pads or collectors used with wound drainage devices). They may be connected to the patient by means of catheters and Tubing - Devices used to immobilise body parts and/or to apply force or compression on them (e.g. non-sterile dressings used to aid the healing of a sprain, plaster of Paris, cervical collars, gravity traction devices, compression hosiery) - Corrective spectacle frames (i.e. glasses) and lenses in Frames - Stethoscopes - Eye occlusion plasters - Incision drapes - Non-invasive conductive gels i.e. ultrasound gels2 - Non-invasive electrodes (electrodes for EEG or ECG) - Permanent magnets for removal of ocular debris - Wheelchairs pushed by hand
Some non-invasive devices are indirectly in contact with the body and can influence internal physiological processes by storing, channelling or treating blood, other body liquids or liquids which are returned or infused into the body or by generating energy that is delivered to the body. These are handled by other rules because of the hazards inherent in such indirect influence on the body. Note 1: Intact skin includes the skin around an established stoma unless the skin is breached. Signs of breached skin include, but not limited to, tears, erythema, oedema, weeping and infection. The definition of intact skin must apply for the continuous use of the device. Note 2: Ultrasound gels are not to be absorbed or locally dispersed within the body at the site of action in order to achieve their intended Purpose.
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Rule 2
Channelling or storing for eventual administration
This rule applies to non-invasive devices intended for channeling or storing blood, body liquids, cells or tissues, liquids or gases for specific purposes. Invasive devices, other than surgically invasive devices which are intended to administer medicinal products by inhalation, fall under the Rule 20 These types of devices should be considered separately from the non-contact devices of Rule 1 because they may be indirectly invasive. They channel or store substances that will eventually be administered to the body. Typically these devices are used in transfusion, infusion, extracorporeal circulation and delivery of anaesthetic gases and oxygen. In some cases devices covered under this rule are very simple delivery devices that rely on gravity.
IIa (Klasse 2a)
All non-invasive devices intended for channeling or storing blood, body liquids, cells or tissues, liquids or gases for the purpose of eventual infusion, administration or introduction into the body are classified as class IIa: - if they may be connected to a class IIa, class IIb or class III active device; or if they are intended for use for channeling or storing blood or other body liquids or for storing organs, parts of organs or body cells and tissues,
- Devices intended to be used as channels in active drug delivery systems, e.g. tubing intended for use with an infusion pump - Devices used for channelling gases, e.g. antistatic tubing for anaesthesia, anaesthesia breathing circuits - Syringes for infusion pumps - Devices intended to channel blood (e.g. in transfusion, extracorporeal circulation) - Devices intended for temporary storage and transport of organs for transplantation (i.e. containers, bags) - Devices intended for long term storage of biological substances and tissues such as corneas, sperm, human embryos, etc. (i.e. containers, bags) - Fridges/freezers specifically intended for storing blood, tissues etc. - Tubings/blood lines for extracorporeal treatment (dialysis and apheresis therapies)
If a device, e.g. tubing, intended to be used for a purpose that would require it to be connected to an active device, such a device will be automatically in class IIa, unless the manufacturer clearly states that it should not be connected to an active device of class IIa or higher. Note 1: ‘May be connected to an active device’ - such a connection is deemed to exist between a non-active device and an active device where the non-active device forms a link in the transfer of the substance between the patient and the active device and the safety and performance of one of the devices is influenced by the other device. For instance, this applies to tubing in an extracorporeal circulation system which is downstream from a blood pump and in the same blood flow circuit, but not directly connected to the pump. Note 2: See also Chapter 3.1.6 regarding the possible measuring function.
Rule 2
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IIb (Klasse 2b)
- except for blood bags; blood bags are classified as class IIb.
- Blood bags without a substance which, if used separately, can be considered to be a medicinal product
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Rule 2
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I (Klasse 1)
In all other cases, such devices are classified as class I
- Non-invasive devices that provide a simple channelling function, with gravity providing the force to transport the liquid, e.g. administration sets for infusion - Devices intended to be used for a temporary containment or storage function, e.g. cups and spoons specifically intended for administering medicines2 Empty syringes without needles
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Rule 3
Devices that modify biological or chemical composition of human tissues or cells, blood, other body liquids or other liquids intended for implantation or administration into the body
These types of devices must be considered separately from the non-contact devices of Rule 1 because they are indirectly invasive. They modify substances that will eventually be administered into the body. This rule covers mostly the more sophisticated elements of extracorporeal circulation sets, dialysis systems and autotransfusion systems as well as devices for extracorporeal treatment of body fluids which may or may not be immediately reintroduced into the body, including cases where the patient is not in a closed loop with the device. This rule covers also substances in direct contact with human cells, tissues or organs in vitro before their implantation or administration, without substances derived from human or animal origin such as human albumin.
IIb (Klasse 2b)
All non-invasive devices intended for modifying the biological or chemical composition of human tissues or cells, blood, other body liquids or other liquids intended for implantation or administration into the body are classified as class IIb,
- Devices intended to remove undesirable substances out of the blood by exchange of solutes such as hemodialysers - Devices intended to separate cells by physical means, e.g. gradient medium for sperm separation - Haemodialysis concentrates - Device removing specific blood cells (e.g. activated) by specific binding to a matrix
These devices are normally used in conjunction with an active medical device covered under Rule 9 or Rule 11. Filtration and centrifugation should be understood in the context of this rule as being done exclusively through mechanical methods
Rule 3
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IIa (Klasse 2a)
unless the treatment for which the device is used consists of filtration, centrifugation or exchanges of gas, heat, in which case they are classified as class IIa
- Particulate filtration of blood in an extracorporeal circulation system. These are used to remove particles from the blood - Centrifugation of blood to prepare it for transfusion or autotransfusion excluding centrifuges for manufacturing a medicinal product - Removal of carbon dioxide from the blood and/or adding oxygen - Warming or cooling the blood in an extracorporeal circulation system.
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Rule 3
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III (Klasse 3)
All non-invasive devices consisting of a substance or a mixture of substances intended to be used in vitro in direct contact with human cells, tissues or organs taken from the human body or used in vitro with human embryos before their implantation or administration into the body are classified as class III.
- Substances or mixture of substances for transport, perfusion, storage of organs intended for transplantation that do not achieve the principal intended action by pharmacological, immunological or metabolic means - IVF or ART products without principal pharmacological/metabolic action (substances or mixture of substances) - IVF cell media without human albumin
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Rule 4
Devices that come into contact with injured skin or mucous membrane
This rule applies to non-invasive devices as well as invasive devices that come into contact with injured skin or mucous membrane. This rule is intended to primarily cover wound dressings independently of the depth of the skin wound or mucosa wound. The conventional types of products, such as those used as a mechanical barrier, are well understood and do not result in any great hazard. There have also been rapid technological developments in this area, with the emergence of new types of wound dressings for which new types of claims are made, e.g. management of the microenvironment of a wound to enhance its natural healing mechanism. More novel claims relate to the mechanism of healing by secondary intent, such as influencing the underlying mechanisms of granulation or epithelial formation or preventing contraction of the wound. Some devices used on breached dermis or breached mucosa may even have a life- sustaining or lifesaving purpose, e.g. when there is full thickness destruction of the skin or mucosa over a large area and/or systemic impact. Dressings incorporating a substance which, if used separately, can be considered to be a medicinal product and that has an action ancillary to that of the dressing, fall within class III under Rule 14. Devices composed of other substances which are absorbed by or locally dispersed in the human body fall under Rule 21.
I (Klasse 1)
All non-invasive devices which come into contact with injured skin or mucous membrane are classified as: - class I if they are intended to be used as a mechanical barrier, for compression or for absorption of exudates;
- Wound dressings for skin or mucous, such as: absorbent pads, island dressings, cotton wool, wound strips, adhesive bandages (sticking plasters, band-aid) and gauze dressings which act as a barrier, maintain wound position or absorb exudates from the wound - Ostomy bags
The classification of devices covered by this rule depends on the use intended by the manufacturer’s, e.g. a polymeric film dressing would be in class IIa if the intended use is to manage the micro-environment of the wound or in class I if its intended use is limited to retaining an invasive cannula at the wound site. Consequently, it is impossible to say a priori that a particular type of dressing belongs to a given class without knowing its intended use as defined by the manufacturer. However, a claim that the device is interactive or active with respect to the wound healing process usually implies that the device is at least class IIa. Most dressings that are intended for a use that falls under class IIa or IIb also perform functions that are in class I, e.g. that of a mechanical barrier. Such devices are nevertheless classified according to their intended use in the higher class. For such devices incorporating a substance which, if used separately, can be considered to be medicinal product or a human blood derivative, or animal tissues or derivatives rendered non-viable, see Rule 14 or Rule 18 respectively.
Rule 4
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IIb (Klasse 2b)
- class IIb if they are intended to be used principally for injuries to skin which have breached the dermis or mucous membrane and can only heal by secondary intent;
Are principally intended to be used with severe Wounds: - Dressings intended for ulcerated wounds having breached the dermis - Dressings intended for burns having breached the dermis - Dressings for severe decubitus wounds - Dressings incorporating means of augmenting tissue and providing a temporary skin substitute
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Rule 4
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IIa (Klasse 2a)
- class IIa if they are principally intended to manage the micro-environment of injured skin or mucous membrane; and
- Hydrogel dressings for wounds or injuries that have not breached the dermis or can only heal by secondary intent - Non-medicated impregnated gauze dressings - Polymer film dressings
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Rule 4
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IIa (Klasse 2a)
- class IIa in all other cases
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Rule 4
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This rule applies also to the invasive devices that come into contact with injured mucous Membrane.
- Dressings for nose bleeds (the purpose of the dressing is not to manage micro-environment) are in class I according to this rule - Dental wound dressings not containing animal derived material
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Rule 5
Devices invasive with respect to body orifices
Invasiveness with respect to body orifices must be considered separately from invasiveness that penetrates through a cut in the body surface (surgical invasiveness). For short term use, a further distinction must be made between invasiveness with respect to the less vulnerable anterior parts of the ear, mouth and nose and the other anatomical sites that can be accessed through natural body orifices. A surgically created stoma, which, for example, allows the evacuation of urine or faeces, is also to be considered a body orifice. The devices covered by this rule tend to be diagnostic and therapeutic instruments used in particular specialties (otorhinolaryngology, ophthalmology, dentistry, proctology, urology and gynaecology).
I (Klasse 1)
All invasive devices with respect to body orifices, other than surgically invasive devices, which are not intended for connection to an active device or which are intended for connection to a class I active device are classified as: class I if they are intended for transient use;
- Handheld mirrors used in dentistry to aid in dental diagnosis and surgery - Dental impression materials - Stomach tubes - Impression trays - Examination gloves - Urinary catheters intended for transient use - Embryo transfer catheter and insemination catheter
Regarding devices intended for connection to an active device: the strictest rule and sub-rule resulting in higher classification will apply. For instance a trachea cannula for long-term use need to be classified as class IIb. Devices composed of substances which are absorbed by or locally dispersed in the human body may also fall under Rule 21
Rule 5
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IIa (Klasse 2a)
- class IIa if they are intended for short-term use,
- Short term corrective contact lenses - Tracheal tubes - Indwelling urinary catheters intended for short term use - Gasses used for insufflation in the body - Nasobilliary tubes
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Rule 5
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I (Klasse 1)
- except if they are used in the oral cavity as far as the pharynx, in an ear canal up to the ear drum or in the nasal cavity, in which case they are classified as class I; and
- Materials for dental impressions - Plastic syringe used to measure a quantity of medicinal product before oral administration to the patient - Removable or fixed dental prostheses
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Rule 5
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IIb (Klasse 2b)
- class IIb if they are intended for long-term use.
- Urethral stents - Long term corrective contact lenses - Tracheal cannulae for tracheostoma for long term use - Urinary catheters intended for long term use
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Rule 5
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IIa (Klasse 2a)
- except if they are used in the oral cavity as far as the pharynx, in an ear canal up to the ear drum or in the nasal cavity and are not liable to be absorbed by the mucous membrane, in which case they are classified as class IIa.
- Orthodontic wires - Fixed dental prostheses - Fissure sealants
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Rule 5
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IIa (Klasse 2a)
All invasive devices with respect to body orifices, other than surgically invasive devices, intended for connection to a class IIa, class IIb or class III active device, are classified as class IIa
- Tracheostomy or tracheal tubes connected to a ventilator - Blood oxygen analysers placed under the eye-lid - Powered nasal irrigators - Fibre optics in endoscopes connected to surgical lasers - Suction catheters or tubes for stomach drainage - Dental aspirator tips - Endoscopes using a light source in the visible spectrum
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Rule 6
Surgically invasive devices intended for transient use (<60 min
This rule primarily covers three major groups of devices: devices that are used to create a conduit through the skin (e.g. needles, cannulae), surgical instruments (e.g. scalpels, saws) and various types of catheters, suckers, etc.
IIa (Klasse 2a)
All surgically invasive devices intended for transient use are classified as class IIa unless they:
- Needles used for suturing - Needles or syringes - Lancets - Single use scalpels and single use scalpel blades - Surgical swabs - Surgical gloves - Swabs to sample exudates - Guidewires or catheters used outside the central circulatory system
Note 1: Terms such as ‘surgically invasive device’, ‘central circulatory system’, ‘central nervous system’ and ‘reusable surgical instruments’ are defined in Section 2 of Annex VIII to the MDR. In particular surgical instruments connected to an active device are not considered to be ‘reusable surgical instruments’. Note 2: The expression ‘correct a defect’ does not cover auxiliary devices that are used in heart surgery procedures, e.g. clamps, aortic punch instruments. The first indent of this rule does not apply to aortic punches and similar cutting instruments which perform a function similar to that of a scalpel. Note 3: ‘Dedicated’ means that the intended purpose of the device or accessory is to specifically control, diagnose, monitor or correct a defect of the heart or of the central circulatory system. Note 4: The concept of ‘potentially hazardous manner’ is related to the characteristics of the device and not to the competence of the user.
Rule 6
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III (Klasse 3)
- are intended specifically to control, diagnose, monitor or correct a defect2 of the heart or of the central circulatory system through direct contact with those parts of the body, in which case they are classified as class III;
- Cardiovascular catheters (e.g. angioplasty balloon catheters, stent delivery catheters/systems), including related guidewires, related introducers and dedicated disposable cardiovascular surgical instruments e.g. electrophysiological catheters, electrodes for electrophysiological diagnosis and ablation, - Catheters containing or incorporating sealed radioisotopes, where the radioactive isotope is not intended to be released into the body, if used in the central circulatory system - Distal protection devices
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Rule 6
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I (Klasse 1)
- are reusable surgical instruments, in which case they are classified as class I;
- Scalpels and scalpel handles - Reamers - Drill bits - Saws, that are not intended for connection to an active device - Retractors forceps, excavators and chisels - Sternum retractors for transient use - Staplers (outside the heart, central circulatory or central nervous system - Dental Osteotomes
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Rule 6
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III (Klasse 3)
- are intended specifically for use in direct contact with the heart or central circulatory system or the central nervous system, in which case they are classified as class III
- Neuro-endoscopes - Brain spatulas - Direct stimulation cannulae - Spinal cord retractors - Spinal needles - Cranium guide for use in craniotomy - Dura mater protection; Bone punch for use on the cranium (Intended use: The dura mater protection is intended to protect the dura mater during surgical procedures. It has direct contact to the CNS. The bone punch can be used at the cranium. A direct contact to the CNS is possible during application.) - Peripherally inserted central catheter (PICC) line - Heart valve occluders, sizers and holders - Cardiovascular drainage cannula specifically intended to circulate blood whilst located in the heart or central vascular system - Cryo-ablation of the heart or spine - Appliers/Forceps for aneurysm clips
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Rule 6
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IIb (Klasse 2b)
- are intended to supply energy in the form of ionising radiation in which case they are classified as class IIb; - or
- Catheters containing or incorporating sealed radioisotopes, where the radioactive isotope as such is not intended to be released into the body, excluding the central circulatory system
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Rule 6
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IIb (Klasse 2b)
- have a biological effect or are wholly or mainly absorbed in which case they are classified as class IIb;
- Viscoelastic solution for ophthalmic surgery
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Rule 6
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IIb (Klasse 2b)
- are intended to administer medicinal products by means of a delivery system, if such administration of a medicinal product is done in a manner that is potentially hazardous taking account of the mode of application, in which case they are classified as class IIb.
- Refillable insulin pens - Analgesia pumps
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Rule 7
Surgically invasive devices intended for short-term use (> 60 min <30 days)
These are mostly devices used in the context of surgery or post-operative care (e.g. clamps, drains), infusion devices (e.g. cannulae, needles) and catheters of various types.
IIa (Klasse 2a)
All surgically invasive devices intended for short-term use are classified as class IIa unless they:
- Clamps - Infusion cannulae - Skin closure devices - Temporary filling materials - Arthroscopy trocars - Insufflation gases for surgically invasive endoscopic procedures
Note 1: Administration of medicinal products is more than just channelling, it implies also storage and/or control of the volume and rate of delivery. Implanted capsules for the slow release of medicines, placed on the market as a single integral product, are governed by Directive 2001/83/EC or Regulation (EC) No 726/2004.
Rule 7
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III (Klasse 3)
are intended specifically to control, diagnose, monitor or correct a defect of the heart or of the central circulatory system through direct contact with those parts of the body, in which case they are classified as class III;
- Cardiovascular catheters - Cardiac output probes - Temporary pacemaker leads - Thoracic catheters intended to drain the heart, including the pericardium - Carotid artery shunts - Ablation catheter - Heart bypass cannula (aortic perfusion cannula and venous drainage cannula) - Peripherally inserted central catheter (PICC) line and central line
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Rule 7
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III (Klasse 3)
are intended specifically for use in direct contact with the heart or central circulatory system or the central nervous system, in which case they are classified as class III;
- Neurological catheters - Cortical electrodes - Central venous/vascular catheters
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Rule 7
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IIb (Klasse 2b)
are intended to supply energy in the form of ionizing radiation in which case they are classified as class IIb;
- Brachytherapy devices
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Rule 7
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III (Klasse 3)
have a biological effect or are wholly or mainly absorbed in which case they are classified as class III;
- Absorbable sutures
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Rule 7
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IIb (Klasse 2b)
are intended to undergo chemical change in the body in which case they are classified as class IIb, except if the devices are placed in the teeth; or.
- Vascular closure devices - Haemostatic foams
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Rule 7
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IIb (Klasse 2b)
are intended to administer medicines1, in which case they are classified as class IIb.
- Temporal dialysis catheter, CVVH catheter
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Rule 8
Implantable devices and long-term surgically invasive devices (> 30 days
These are mostly implants in the orthopaedic, dental, ophthalmic and cardiovascular fields as well as soft tissue implants such as implants used in plastic surgery.
IIb (Klasse 2b)
All implantable devices and long-term surgically invasive devices are classified as class IIb unless they:
- Artificial ligaments for reinforcement2. Dental implants and abutments - Shunts - Peripheral stents and peripheral valves - Plates - Intra-ocular lenses - Internal closure devices (including vascular closure devices1) - Tissue augmentation implants (excluding breasts) - Peripheral vascular catheters for long-term use - Peripheral vascular grafts and stents - Penile implants - Non-absorbable sutures, non-biodegreable bone cements and maxillo-facial implants, visco- elastic surgical devices intended specifically for ophthalmic anterior segment surgery2 - Pedicle screws
Note 1: For closure of arteriotomies in the peripheral vascular system (refer to definition of central circulatory system). Note 2: These devices are implants because in normal conditions a significant amount of the substance remains at the surgical site after the procedure. Rule 18 may also be relevant. Note 3: Implants without bioactive coatings intended to secure teeth or prostheses to the maxillary or mandibular bones are in Class IIb following the general rule. Note 4: The clause about chemical change under this rule does not apply to products such as bone cements where the chemical change takes place during the placement and does not continue in long term. Note 5: Also non-implantable and non-active accessories to AIMDs should be classified as Class III under Rule 8.
Rule 8
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IIa (Klasse 2a)
- are intended to be placed in the teeth3, in which case they are classified as class IIa;
- Bridges and crowns - Dental filling materials and pins - Dental alloys, ceramics and polymers
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Rule 8
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III (Klasse 3)
- are intended to be used in direct contact with the heart, the central circulatory system or the central nervous system, in which case they are classified as class III;
- Prosthetic heart valves - Aneurysm clips - Vascular prosthesis and stents - Central vascular catheters for long-term use - Spinal stents - CNS electrodes - Cardiovascular sutures - Permanent and retrievable vena cava filters - Septal occlusion devices - Intra-aortic balloon pumps - External left ventricular assisting devices
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Rule 8
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III (Klasse 3)
- have a biological effect or are wholly or mainly absorbed, in which case they are classified as class III;
- Long term absorbable sutures - Adhesives and implantable devices claimed to be bioactive through the attachment of surface coatings such as phosphoryl choline - Biodegrable Bone Cements - Elastoviscus fluids for joint movement(eg. hyaluronan of non-animal origin)
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Rule 8
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III (Klasse 3)
- are intended to undergo chemical change4 in the body in which case they are classified as class III, except if the devices are placed in the teeth
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Rule 8
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III (Klasse 3)
- are intended to administer medicinal products, in which case they are classified as class III;
- Rechargeable non-active drug delivery systems - Peritoneal dialysis
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Rule 8
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III (Klasse 3)
- are active implantable devices or their accessories, in which cases they are classified as class III;
- Cochlear implants and accessories Implantable cardiac pacemakers - Implantable cardioverter defibrillators (ICD) - Leads, electrodes, adaptors for pacemakers and implantable defibrillators - Implantable nerve stimulators - Implantable bladder stimulators - Implantable sphincter stimulators - Accessories to active implantable devices (with or without contact to the heart), be it implantable or non-implantable active or not5: -- torque wrench for implantable pulse generator / implantable cardioverter defibrillator -- cables for programmer / pacing system analyser -- magnet for Implantable Pulse Generator / Implantable Cardioverter Generator -- programmer or an external transmitter intended for activating or controlling the implantable part of the device -- implantable pacemaker leads
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Rule 8
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III (Klasse 3)
- are breast implants or surgical meshes, in which cases they are classified as class III;
- Breast implants - Breast tissue expanders - Surgical meshes for hernia repair - Tension free vaginal tape
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Rule 8
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III (Klasse 3)
- are total or partial joint replacements, in which case they are classified as class III, with the exception of ancillary components such as screws, wedges, plates and instruments; or
- Hip, knee - Shoulder - Ankle
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Rule 8
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III (Klasse 3)
- are spinal disc replacement implants or are implantable devices that come into contact with the spinal column, in which case they are classified as class III with the exception of components such as screws, wedges, plates and instruments
- Spinal disc replacement implants - Spinal implants: hooks that fix the rod on the spinal column - Stems that are implantable in contact with the spinal column - Device placed in the disc space - Interbody fusion devices
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Rule 9
Active therapeutic devices intended to administer or exchange energy, as well as active devices intended to control/monitor/directly influence certain devices
This rule covers many different groups of devices, such as: - electrical equipment used in surgery such as lasers and surgical generators; - stimulation devices; - devices intended to emit ionizing radiation2 for therapeutic purposes, including devices which control or monitor such devices, or which directly influence their performance; - devices intended for controlling, monitoring or directly influencing the performance of active implantable devices. Active implantable devices are covered by Rule 8. Rule 22 may also apply to active therapeutic devices.
IIa (Klasse 2a)
All active therapeutic devices intended to administer or exchange energy are classified as class IIa
- Electrical and/or magnetic and electromagnetic Energy: -- muscle stimulators -- external bone growth stimulators -- TENS devices -- eye electromagnets -- electrical acupuncture - Thermal energy: --heat exchangers, except the types described below - Mechanical energy: --powered dermatomes --powered drills --dental hand pieces - Light: --phototherapy for skin treatment and for neonatal care - Sound: --external hearing aids - Ultrasound: --equipment for physiotherapy - Sleep apnoea ventilators without monitoring function
Note 1: The decision as to whether a medical device administers or exchanges energy to and from the human body in a potentially hazardous way should take into account the following factors. The concept of ‘potentially hazardous’ is dependent on the type of technology involved and the intended application of the device to the patient and not on the measures adopted by the manufacturer in view of good design management (e.g. use of technical standards, risk analysis). For instance, all devices intended to emit ionizing radiation, all lung ventilators and lithotriptors should be in Class IIb. However, the manufacturer's obligation to comply with design requirements and solutions adopted, exist independently from the classification system. Devices for illumination, i.e. administration of rays in visible light spectrum, for use in the process of diagnosis are classified as class IIa or higher, e.g. visual electrophysiology or fundoscopes for examination of the eye; whereas devices for illumination for purposes other than in the process of diagnosis, e.g. therapeutic purposes (light therapy), are class I. Note 2: ‘Ionising radiation’ means energy transferred in the form of particles or electromagnetic waves of a wavelength of 100 nanometres or less (a frequency of 3 × 1015 hertz or more) capable of producing ions directly or indirectly (Directive 2013/59/EURATOM, Article 4, 46).
Rule 9
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IIb (Klasse 2b)
unless their characteristics are such that they may administer energy to or exchange energy with the human body in a potentially hazardous way, taking account of the nature, the density and site of application of the energy, in which case they are classified as class Iib.
- Kinetic energy: lung ventilators - Thermal energy: --incubators for babies --blood warmers --electrically powered heat exchangers (with patients incapable of reacting, communicating /or who are without a sense of feeling) - Electrical energy: -- high-frequency electrosurgical generators, and electrocautery equipment, including their electrodes -- external pacemakers and external defibrillators with no integrated or incorporated diagnostic function -- electroconvulsive therapy equipment - Coherent light: surgical lasers -Ultrasound: lithotriptors, surgical ultrasound devices, high-intensity focused ultrasound (HIFU
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Rule 9
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IIb (Klasse 2b)
All active devices intended to control or monitor the performance of active therapeutic class IIb devices, or intended directly to influence the performance of such devices are classified as class Iib.
- External feedback systems for active therapeutic devices
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Rule 9
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IIb (Klasse 2b)
All active devices intended to emit ionizing radiation for therapeutic purposes, including devices which control or monitor such devices, or which directly influence their performance, are classified as class Iib
- Brachytherapy therapy devices if the device also generates the radiation - Therapeutic cyclotrons and linear accelerators - Therapeutic X-ray sources
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Rule 9
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III (Klasse 3)
All active devices that are intended for controlling, monitoring or directly influencing the performance of active implantable devices are classified as class III
- Programming units and pacing system analysers - Cardioscopes with pacing pulse indicators specifically intended to monitor active implantable devices - Programmer for: -- implantable Pulse Generator (IPG); -- implantable Cardioverter Defibrillator (ICD) -- implantable Loop Recorder - Remote monitoring devices for active implantable devices
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Rule 10
Active devices for diagnosis and monitoring or intended for diagnostic or therapeutic radiology
This rule covers a whole range equipment in various fields for capture of physiological signals, as well as specifically therapeutic and diagnostic radiology. Note that devices for recording diagnostic X-ray images are covered by Rule 17. Devices specifically intended to monitor active implantable devices fall under Rule 8 or Rule 9.
IIa (Klasse 2a)
Active devices intended for diagnosis and monitoring are classified as class IIa: - if they are intended to supply energy which will be absorbed by the human body,
- Magnetic resonance equipment - Pulp testers - Evoked response stimulators - Diagnostic ultrasound
Note 1: ‘Illuminate’ means: to administer rays in visible light spectrum to for use in the process of diagnosis for example in visual electrophysiology and eye diseases, and not just to cast a light to improve the visibility. When performing diagnosis to, for example, perform visual electrophysiology in search of eye diseases, the intended purpose of the device is not limited to ‘illumination’, but may include diagnosis. Note 2: A device is considered to allow direct diagnosis when it itself provides the diagnosis of the disease or condition in question or when it provides decisive information for the diagnosis (MDR 2017/745, Annex VIII, 3.7). For the definition of diagnosis see the MDCG Guidance document covering the borderline between medical devices and medicinal products. Note 3: Vital physiological processes and parameters include, for example, respiration, heart rate, cerebral functions, blood gases, blood pressure and body temperature. Medical devices intended to be used for continuous surveillance of vital physiological parameters in anesthesia, intensive care or emergency care are in class IIb, whilst medical devices intended to be used to obtain readings of vital physiological signals as part of routine checkups or self-monitoring are in class IIa. A thermal imaging device intended to monitor blood flow is not considered to be a body temperature measuring device. Note 4: ‘Ionising radiation’ means energy transferred in the form of particles or electromagnetic waves of a wavelength of 100 nanometers or less (a frequency of 3 × 1015 hertz or more) capable of producing ions directly or indirectly (Directive 2013/59/EURATOM, Article 4, 46). Note 5: Therapeutic interventional radiology refers to diagnosis being carried out during a surgical procedure. Note 6: This refers to active devices for the control, monitoring or influencing the emission of ionizing radiation and not to the subsequent processing, recording or viewing of the resulting image. Devices for recording diagnostic X-ray images are covered by Rule 17.
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I (Klasse 1)
except for devices intended to illuminate1 the patient's body, in the visible spectrum, in which case they are classified as class I;
- Examination lamps - Surgical microscopes intended to illuminate the patient’s body in the visible spectrum - Dermatoscopes with integrated light sources
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IIa (Klasse 2a)
- if they are intended to image in vivo distribution of radiopharmaceuticals; or
- Gamma cameras - Positron emission tomography and single photon emission computer tomography
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IIa (Klasse 2a)
- if they are intended to allow direct diagnosis2 or monitoring of vital physiological processes
- Electrocardiographs - Electroencephalographs - Electronic thermometers - Electronic stethoscopes - Electronic blood pressure measuring equipment
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IIb (Klasse 2b)
unless they are specifically intended for monitoring of vital physiological parameters and the nature of variations of those parameters is such that it could result in immediate danger to the patient, for instance variations in cardiac performance, respiration, activity of the central nervous system, or they are intended for diagnosis in clinical situations where the patient is in immediate danger, in which cases they are classified as class IIb.
- Blood gas analysers used in open heart surgery - Apnoea monitors, including apnoea monitors in home care - Patient monitors (intended use: Monitor intended for multi-parameter patient monitoring. The device will produce visual and audible alarms if any of the physiological parameters monitored vary beyond pre-set limits and timed alarm recordings will be produced.), for example in intensive care monitoring, e.g. blood pressure, temperature, oxygen saturation
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IIb (Klasse 2b)
Active devices intended to emit ionizing radiation4 and intended for diagnostic or therapeutic radiology, including interventional radiology devices and devices which control or monitor such devices, or which directly influence their performance, are classified as class IIb.
- Diagnostic X-Ray machine - Computed Tomography Devices
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Rule 11
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IIa (Klasse 2a)
Software intended to provide information which is used to take decisions with diagnosis or therapeutic purposes is classified as class IIa, except if such decisions have an impact that may cause:
- MDSW intended to rank therapeutic suggestions for a health care professional based on patient history, imaging test results, and patient characteristics, for example, MDSW that lists and ranks all available chemotherapy options for BRCA-positive individuals. - Cognitive therapy MDSW where a specialist determines the necessary cognitive therapy based on the outcome provided by the MDSW.
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III (Klasse 3)
— death or an irreversible deterioration of a person's state of health1, in which case it is in class III; or
- MDSW intended to perform diagnosis by means of image analysis for making treatment decisions in patients with acute stroke.
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IIb (Klasse 2b)
— a serious deterioration of a person's state of health1 or a surgical intervention, in which case it is classified as class Iib.
- A mobile app intended to analyse a user’s heartbeat, detect abnormalities and inform a physician accordingly. MDSW intended for diagnosing depression based on a score resulting from inputted data on patient symptoms (e.g. anxiety, sleep patterns, stress etc.).
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IIa (Klasse 2a)
Software intended to monitor physiological processes is classified as class Iia,
- MDSW intended to monitor physiological processes that are not considered to be vital. - Devices intended to be used to obtain readings of vital physiological signals in routine check-ups including monitoring at home.
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IIb (Klasse 2b)
except if it is intended for monitoring of vital physiological parameters3, where the nature of variations of those parameters is such that it could result in immediate danger to the patient, in which case it is classified as class Iib.
- Medical devices including MDSW intended to be used for continuous surveillance of vital physiological processes in anaesthesia, intensive care or emergency care.
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I (Klasse 1)
All other software is classified as class I.
- MDSW app intended to support conception by calculating the user’s fertility status based on a validated statistical algorithm. The user inputs health data including basal body temperature (BBT) and menstruation days to track and predict ovulation. The fertility status of the current day is reflected by one of three indicator lights: red (fertile), green (infertile) or yellow (learning phase/cycle fluctuation).
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Rule 12
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IIa (Klasse 2a)
All active devices intended to administer and/or remove medicinal products, body liquids or other substances to or from the body are classified as class Iia,
- Suction pump - Feeding pumps - Jet injectors for vaccination - Elastomeric pumps or balloon pumps for infusion
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Rule 12
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IIb (Klasse 2b)
unless this is done in a manner that is potentially hazardous, taking account of the nature of the substances involved, of the part of the body concerned and of the mode of application in which case they are classified as class Iib.
- Infusion pumps - Ventilators - Anaesthesia machines - Anaesthetic vaporisers - Dialysis equipment - Blood pumps for heart-lung machines - Hyperbaric chambers - Pressure regulators for medical gases - Medical gas mixers - Moisture exchangers in breathing circuits if used on unconscious or non-spontaneously breathing patients - Oxygen concentrator used to deliver oxygen enriched air directly to the patient
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Rule 13
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I (Klasse 1)
All other active devices are classified as class I.
- Electric wheelchairs - Dental curing lights - Electric hospital beds - Patient hoists - Dental patient chairs
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Rule 14
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III (Klasse 3)
All devices incorporating, as an integral part, a substance which, if used separately, can be considered to be a medicinal product, as defined in point 2 of Article 1 of Directive 2001/83/EC, including a medicinal product derived from human blood or human plasma, as defined in point 10 of Article 1 of that Directive, and that has an action ancillary to that of the devices, are classified as class III.
- Bone cement with antibiotics - Condoms with spermicide - Catheters coated with anticoagulants (e. g. heparin) - Endodontic materials with antibiotics - Ophthalmic irrigation solutions principally intended for irrigation, which contain components supporting the metabolism of the endothelial cells of the cornea - Dressings incorporating an antimicrobial agent where the agent has an ancillary action on the wound - Drug eluting stents (e.g. coronary, pulmonary) - Surgical sealants containing human serum albumin or thrombin - Implants coated with human fibrinogen - Blood bags incorporating heparin or other substances as anticoagulant agents which, if used separately, can be considered to be a medicinal product - IVF cell media with human albumin2 - Intra Uterine Devices (IUD) containing medicinal substances3 including copper or silver - Catheter lubrication gels containing analgesia e.g. lidocaine
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Rule 15
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IIb (Klasse 2b)
All devices used for contraception or prevention of the transmission of sexually transmitted diseases are classified as class Iib,
- Condoms and femidoms (internal condoms) - Contraceptive diaphragms - Fertility monitors and medical device software intended to be used in contraception (e.g. by using the basal body temperature)
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Rule 15
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III (Klasse 3)
unless they are implantable or long term invasive devices, in which case they are classified as class III.
- Tubal ligation devices (e.g. clips or rings) - Non-hormonal intrauterine contraceptive devices (IUCD or ICD)
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Rule 16
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IIb (Klasse 2b)
All devices intended specifically to be used for disinfecting, cleaning, rinsing or, where appropriate, hydrating contact lenses are classified as class Iib.
- Contact lens storing solutions - Cleaners for contact lenses - Ultraviolet, vibration, or ultrasonic devices for cleaning and disinfecting contact lenses
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Rule 16
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IIa (Klasse 2a)
All devices intended specifically to be used for disinfecting or sterilising medical devices are classified as class Iia,
- Disinfecting solutions specifically intended for non-invasive medical devices - Washer-disinfectors intended specifically for disinfecting non-invasive medical devices - Sterilisers intended to sterilise medical devices in a medical environment
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Rule 16
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IIb (Klasse 2b)
unless they are disinfecting solutions or washer-disinfectors intended specifically to be used for disinfecting invasive devices, as the end point of processing1, in which case they are classified as class Iib.
- Solutions/disinfectors for trans oesophageal ultrasound probes) - Washer-disinfector equipment specifically for disinfecting endoscopes or other invasive devices at the end point of processing (e. g. dental equipment) - Disinfectants for the fluid pathways of haemodialysis equipment - Denture disinfecting products
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Rule 16
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This rule does not apply to devices that are intended to clean devices other than contact lenses by means of physical action only.
- Brushes specifically intended to clean medical devices by mechanical action - Ultrasonic devices (for other devices than contact lenses)
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Rule 17
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IIa (Klasse 2a)
Devices specifically intended for recording of diagnostic images generated by X-ray radiation are classified as class Iia.
- Digital x-ray detectors for recording images - Photostimulable phosphor plates - X-ray films
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Rule 18
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III (Klasse 3)
All devices manufactured utilising tissues or cells of human or animal origin, or their derivatives1, which are non- viable or rendered non-viable, are classified as class III,
- Animal derived biological heart valves - Porcine xenograft dressings - Devices made from animal sourced collagen/gelatine - Devices utilising hyaluronic acid of animal origin - Substance-based devices containing collagen for use in body orifices - Collagen dermal fillers - Bone graft substitutes
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Rule 18
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I (Klasse 1)
unless such devices are manufactured utilising tissues or cells of animal origin, or their derivatives, which are non-viable or rendered non-viable and are devices intended to come into contact with intact skin only.
- Leather components of orthopaedic appliances
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Rule 19
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All devices incorporating or consisting of nanomaterial are classified as
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Rule 19
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III (Klasse 3)
—class III if they present a high or medium potential for internal exposure
- Bone fillers with nanomaterials in their formulation (not polymerized before blood/tissue contact, and degradable) - Superparamagnetic iron oxide nanoparticles (Intended use: thermal ablation of tumors or thermal modulation of the tumor microenvironment by submission to alternating magnetic fields) - Intravascular catheter made of non-degradable polymer, with nano-coating
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Rule 19
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IIb (Klasse 2b)
— class IIb if they present a low potential for internal exposure
- Bone fixation screws/plates with a strongly bound nano-coating high potential - Solution administration set made of non-degradable polymer, with a strongly bound nano-coating
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Rule 19
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IIa (Klasse 2a)
— class IIa if they present a negligible potential for internal exposure
- Intravascular catheter for short term use made of non- degradable polymer, with nanomaterial embedded in the polymer matrix - Solution administration set made of non-degradable polymer, with nanomaterial embedded in the polymer matrix - Dental filling materials
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Rule 20
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IIa (Klasse 2a)
All invasive devices with respect to body orifices, other than surgically invasive devices, which are intended to administer medicinal products by inhalation are classified as class Iia,
- Spacer intended for metered dose inhalers (attached to the inhaler) unless treating life- threatening conditions. - Inhalers for nicotine replacement therapy (nicotine not included) - Oxygen delivery system with a nasal cannula unless treating life-threatening conditions - Inhalers and nebulisers in case their mode of action has probably no essential impact on the efficacy and safety of the administered medicinal product or which are not intended to treat life-threatening conditions
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Rule 20
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IIb (Klasse 2b)
unless their mode of action has an essential impact1 on the efficacy and safety of the administered medicinal product or they are intended to treat life- threatening conditions, in which case they are classified as class Iib
- Nebulisers (not pre-charged with a specific medicinal product) where the failure to deliver the appropriate dosage characteristics could be hazardous - Spacer intended for metered dose inhalers attached to the inhaler
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Rule 21
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III (Klasse 3)
Devices that are composed of substances or of combinations of substances that are intended to be introduced into the human body via a body orifice or applied to the skin and that are absorbed by or locally dispersed in the human body are classified as: — class III if they, or their products of metabolism, are systemically absorbed by the human body in order to achieve the intended purpose;
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Rule 21
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III (Klasse 3)
— class III if they achieve their intended purpose in the stomach or lower gastrointestinal tract and they, or their products of metabolism, are systemically absorbed by the human body;
- Na/Mg alginate, xyloglucan - Fat absorbers that are systemically absorbed, themselves or their metabolites
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