Product Classification

Why a “Non-medical Certification” Is Not a Certificate That Can Be Used Indefinitely

A classification determination is tied to a specific product.

Market Terminology and Regulatory Meaning

The market often calls a determination that a product is “not regulated as a medical device” a “non-medical certification.” In substance, it is not a general quality certification and not a permanent pass for every product in the same series.

What the Result Depends On

  • Intended purpose and target users
  • Structure, operating principle and method of use
  • Technical parameters, risk controls and verification evidence
  • Consistency between the submitted dossier and the marketed product

What Companies Should Maintain

After a determination, companies still need version-consistency control for hardware redesigns, software updates, new accessories, instructions, training and promotion. Any change that may alter purpose or risk characteristics should be reassessed.

This article provides general compliance information and cannot replace a formal assessment of a specific product. Regulations, classification catalogues, guidance, and enforcement practice may change; each project should rely on the rules then in effect, the actual product, and formal documents.
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