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EC: New Entries in the MDCG Borderline Manual

The Medical Device Coordination Group (MDCG) has updated its manual on the classification of products that are on the borderlines between medtech and other regulatory categories (Version 4).

The following newly added cases illustrate current regulatory decisions on qualification and classification:

  • Red blood cell additive solutions containing adenine
    Medical Device, Class III
    Adenine exerts metabolic/pharmacological effects on RBCs; therefore, the solution is classified as part of a Class III device.
  • Dual-action cream with menthol and capsaicin
    Not a medical device
    Principal mode of action is pharmacological (via receptor activity); classified as a medicinal product.
  • Lactose vaginal tablets
    Not a medical device
    Mode of action is metabolic, based on lactic acid bacteria metabolizing lactose into lactic acid.
  • Microabrasion dental stain removers (tooth whitening)
    Not a medical device
    Purely cosmetic purpose (aesthetic improvement), no proven medical benefit.
  • Medical examination table covers
    Medical device
    Intended to prevent disease transmission (infection prevention), thus meeting the definition of a medical device.
  • Mobile sterile air system
    Not a medical device
    Controls the environment (air purification/laminar flow), without direct action in or on the human body.

The updates highlight the strict distinction between medical purpose and cosmetic, pharmacological, or purely environmental functions. Manufacturers must provide robust scientific evidence of the principal mode of action to ensure correct regulatory qualification.


Source:

EC: Manual on borderline and classification for medical devices under Regulation (EU) 2017/745 on medical devices and Regulation (EU) 2017/746 on in vitro diagnostic medical devices


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