EU Borderline and Classification Manual Version 4 Released

View profile for Guillaume Valenzuela

Guiding Medtechs from Design Controls to Regulatory Compliance

🇪🇺 𝗡𝗲𝘄 𝘃𝗲𝗿𝘀𝗶𝗼𝗻 𝗼𝗳 𝘁𝗵𝗲 𝗘𝗨 𝗕𝗼𝗿𝗱𝗲𝗿𝗹𝗶𝗻𝗲 & 𝗖𝗹𝗮𝘀𝘀𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻 𝗠𝗮𝗻𝘂𝗮𝗹 Version 4 of the EU manual on borderline and classification under MDR and IVDR was officially published today. It adds over 6 new real-life cases discussed and agreed upon by competent authorities through the Helsinki Procedure, including borderline evaluations and updated classifications. The manual isn’t legally binding — but it’s the go-to reference for: • National authorities • Notified bodies • And yes, manufacturers defending the qualification of their product If you develop borderline products, or anything that doesn’t fit neatly into the MDR definition… this manual is essential reading. Examples: • ❌ Nasal spray with anti-COVID antibodies → Not a medical device, as the main action is immunological • ✅ Root canal irrigation solution → Can be class III MDs, if antimicrobial action is ancillary • ❌ dual action cream with menthol and capsaicin (new) → Rejected as MD, both substances act pharmacologically • ✅ Medical calculators → Class IIa according to rule 11 (software intended to provide information which is used to take decisions with diagnosis or therapeutic purposes) • ✅ medical examination table covers (new) → (Class I) MD, purpose = prevention of disease • ✅ FeNO measuring device → IVD device, analyzes exhaled NO to assess asthma-related inflammation What you should do as a manufacturer: 1. Check your borderline products: any overlap with these cases? 2. Review your justification of intended purpose & mode of action 3. Prepare robust scientific evidence, claims alone aren’t enough anymore The manual makes it clearer: no “regulatory shortcuts” will fly under MDR/IVDR. Need help with borderline analysis, risk classification or technical documentation? We do that for a living at CSDmed. 🔗 𝐋𝐢𝐧𝐤 𝐢𝐧 𝐭𝐡𝐞 𝐜𝐨𝐦𝐦𝐞𝐧𝐭𝐬 💕 𝐄𝐧𝐣𝐨𝐲 ———————————— 𝐂𝐒𝐃𝐦𝐞𝐝 𝐂𝐨𝐧𝐬𝐮𝐥𝐭𝐢𝐧𝐠 𝘢𝘴𝘴𝘪𝘴𝘵𝘴 𝘪𝘯 𝐑&𝐃, 𝐐𝐮𝐚𝐥𝐢𝐭𝐲, 𝐚𝐧𝐝 𝐑𝐞𝐠𝐮𝐥𝐚𝐭𝐨𝐫𝐲 𝘤𝘩𝘢𝘭𝘭𝘦𝘯𝘨𝘦𝘴 𝘸𝘪𝘵𝘩 𝘢 𝘧𝘰𝘤𝘶𝘴 𝘰𝘯 𝐢𝐧𝐭𝐞𝐠𝐫𝐢𝐭𝐲 𝐚𝐧𝐝 𝐩𝐚𝐭𝐢𝐞𝐧𝐭-𝐜𝐞𝐧𝐭𝐫𝐢𝐜 𝐬𝐨𝐥𝐮𝐭𝐢𝐨𝐧𝐬. 𝘞𝘩𝘢𝘵 𝘴𝘦𝘵𝘴 𝘶𝘴 𝘢𝘱𝘢𝘳𝘵? 𝘈 𝐜𝐨𝐥𝐥𝐚𝐛𝐨𝐫𝐚𝐭𝐢𝐯𝐞 𝐬𝐩𝐢𝐫𝐢𝐭, 𝘧𝘰𝘤𝘶𝘴𝘦𝘥 𝘰𝘯 𝐝𝐞𝐥𝐢𝐯𝐞𝐫𝐢𝐧𝐠 𝐢𝐦𝐩𝐚𝐜𝐭𝐟𝐮𝐥 𝐬𝐨𝐥𝐮𝐭𝐢𝐨𝐧𝐬 𝘸𝘪𝘵𝘩 𝘢 𝐩𝐨𝐬𝐢𝐭𝐢𝐯𝐞 𝐨𝐮𝐭𝐥𝐨𝐨𝐤. 𝘊𝘰𝘯𝘵𝘢𝘤𝘵 𝘶𝘴 𝘵𝘰 𝘥𝘪𝘴𝘤𝘰𝘷𝘦𝘳 𝘰𝘶𝘳 𝘢𝘱𝘱𝘳𝘰𝘢𝘤𝘩 𝘢𝘯𝘥 𝘷𝘢𝘭𝘶𝘦𝘴.

To view or add a comment, sign in

Explore content categories