Procedure: New Market Authorization Class I-IV
Country: Global Procedure
Version #: 01/08/2024
Author: Daria Kostiuchenko
Editor: Daria Kostiuchenko

                                                                 

ID: GP-MD-VI-IV-SR
Category: Medical Devices
Validity: For five years

Certified by: Vlad Reznikov
Copyright: Pattern of USA Inc.

SUMMARY

The classification of medical devices into Class I to IV is commonly used in regulatory frameworks in various countries and regions. The classification is based on the level of risk associated with the device, with Class I representing the lowest risk and Class IV the highest. Here’s a general overview of where the classification system is implemented in some ML4 counties:
1. United States (FDA): The U.S. Food and Drug Administration (FDA) classifies medical devices into three categories – Class I, Class II, and Class III. Class I devices are considered low risk, Class II devices are moderate risk, and Class III devices are high risk. The classification determines the regulatory requirements for market authorization, with Class III devices requiring the most stringent review process.
2. European Union (EU): In the EU, medical devices are classified into four classes – Class I, Class IIa, Class IIb, and Class III. The classification is based on the potential risks associated with the device. Class I devices are considered low risk, while Class III devices pose the highest risk. The classification determines the conformity assessment route for market authorization, with higher-risk devices requiring involvement from a Notified Body. 
3. Canada: Health Canada classifies medical devices into four classes – Class I, Class II, Class III, and Class IV. The classification is based on the risk associated with the device and the regulatory controls required. Class I devices are considered low risk, while Class IV devices pose the highest risk. The classification determines the regulatory requirements for market authorization, with Class IV devices requiring the most stringent review process. 

4. Australia: The Therapeutic Goods Administration (TGA) in Australia classifies medical devices into four classes – Class I, Class IIa, Class IIb, and Class III. The classification is based on the risk associated with the device. Class I devices are considered low risk, while Class III devices pose the highest risk. The classification determines the regulatory requirements for market authorization, with higher-risk devices requiring involvement from a Conformity Assessment Body. 

5. Japan: In Japan, medical devices are classified into three classes – Class I, Class II, and Class III. The classification is based on the risk associated with the device. Class I devices are considered low risk, while Class III devices pose the highest risk. The classification determines the regulatory requirements for market authorization, with Class III devices requiring the most stringent review process.

Gp Medical Devices New Market Authorization Class I Iv Simplified Regulations Card Gantt Chart Page 0001

Must-Have Requirements, Recognized Standards, and Certifications:                                                               

  • Device description, including variants
  • Technical documentation (MDR/IVDR)
  • Instructions for use (IFU)
  • Quality Management System (QMS/QSR)
  • Good Manufacturing Practice (GMP)
  • Declaration of Conformity (DoC)
  • Risk Management
  • Clinical Evidence
  • POA
  • Substantially equivalent to the predicate device
  • MAs in other countries
  • CE mark and ISO 13485 in many countries

Nice-to-have:

  • IEC 60601
  • ISO 14971
  • ISO 10993
  • Labeling

Typical Gaps and Deficiencies: Understanding of the regulatory pathway and requirements applicable to the device. Incorrect predicate device selection. Inadequate documentation. Rush in submitting the application without being prepared                                           

Implementation Period: Immediately upon approval                                                          

Deliverables: Market Authorization (Clearance or Registration), NRA Listing and Establishment registration

PHASE

TASK

TASK

START

DURATION

 

Fee

 

KPI

NUMBER

TITLE

OWNER

W/M/Q/Y

in weeks

3rd Party 

Service 

State

 

0

In-house Pre-Submission Activity

       

  0.1

NDA signing or validation

Executor

week 1

1

    

  0.2

Contract Closing

MAH

week 1

1

    

  0.3

SOW is approved by MAH

MAH

week 1

1

   

SOW

  0.4

POA issuance and shipping

MAH

week 2

1

    

  0.5

Invoice is sent to MAH and paid

MAH

week 3

1

   

POP

I

Prep and Submission

       

  I.1

Predicate device equivalence, admin. & info set review

Executor

week 4

1

    

  I.2

Classify the device (exemption review)

Executor

week 5

1

    

  I.3

Technical Documentation review vs. NRA requirements

Executor

week 6

2

    

  I.4

Application and supplement documents development

Executor

week 8

2

    

  I.5

Approval of the Application

MAH

week 10

1

    

  I.6

NRA payment

MAH

week 10

1

    

  I.7

Submission of the Application

Executor

week 11

1

   

Submission

II

Studies

       

  II.1

Сonducting technical, toxicology, electrical, and software tests, as well clinical and suitability studies, if required

Executor

week 12

4

   

Reports

III

Review and Evaluation

       

  III.1

NRA Application review

NRA

week 16

2

    

  III.2

NRA Technical file review

NRA

week 18

2

    

  III.3

NRA Lab tests and clinical evaluation review

NRA

week 20

2

    

  III.4

NRA Addressing clarifications or queries if so

NRA

week 22

1

    

  III.5

Answering with relevant documents from MAH

Executor

week 23

1

    

  III.6

Facility Inspection if required

NRA

week 24

4

    

  III.7

NRA Official Response

NRA

week 28

1

    

  III.8

NRA Approval (GoTo Ph. IV) or Query (Rpt. Ph. III.5)

NRA

week 29

1

   

Approval

IV

Approval

       

  IV.1

NRA/NB Conclusion draft verification

Executor

week 30

1

    

  IV.2

NRA Conclusion publication

NRA

week 31

1

    

  IV.3

State Listing update

Executor

week 32

1

    

  IV.4

Reporting  to MAH

Executor

week 33

1

   

Report

F

Final Phase In-house Post-Authorization Activity

       

  F.1

Service Acceptance Certificate signing

MAH

week 34

1

    

  F.2

Final Invoice

Executor

week 34

1

    

  F.3

Final Payment

MAH

week 35

1

    

  F.4

Contract Termination

Executor

week 35

1

    

  F.5

Archiving and limiting access

Executor

week 36

1

   

Archiving

 

Feel free to submit a Request for Proposal (RFP) for a specific country or territory to info@patternofusa.com