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December 16, 2025

Approximately 5 minutes

Medical Device Classification in Malaysia: Risk-Based System and AMDD Alignment

Medical Device Classification in Malaysia: Risk-Based System and AMDD Alignment

The Medical Device Authority (MDA) in Malaysia manages the classification system for medical devices and In Vitro Diagnostic (IVD) products, as established under the Medical Device Regulation 2012. This system is closely aligned with the ASEAN Medical Devices Directive (AMDD), employing a risk-based approach that determines the level of regulatory scrutiny required for market entry.

General Medical Device Risk Classification

Medical devices (excluding IVDs) are classified into five categories, ranked from lowest to highest risk:

  • Class A: Low risk (e.g., non-invasive items like bandages or surgical retractors).
  • Class B: Low to moderate risk.
  • Class C: Moderate to high risk.
  • Class D: High risk (e.g., life-sustaining or implanted devices).
  • Combination Devices: A fifth category for products that combine a medical device with a drug, biological product, or other regulated component.

Factors Determining Classification

The MDA uses a set of general principles to assign a classification, primarily based on the risk associated with the device at the point of usage. Key factors include:

  • Intended Purpose and Action: The intended use and whether the device delivers medicine or energy to the patient, or is intended to have a biological effect.
  • Contact and Invasiveness: The duration of contact with the body, and the degree of, and site of, invasiveness into the body.
  • Effects: Whether the effects are local versus systemic, and whether the device comes into contact with injured skin.
  • Design and Use: The effectiveness of risk management techniques applied during design, manufacture, and use.

IVD Device Classification

IVD devices are categorized separately but also use the four risk classes (A, B, C, D), from lowest to highest risk. The risk level for IVDs is determined by:

  • Intended Use: The diagnostic application.
  • User Expertise: The required expertise of the intended user.
  • Diagnostic Importance: The importance of the information provided by the diagnostic test.
  • Impact of Results: The potential impact of the test results on patient health (e.g., an HIV blood test is high-risk Class D, while a pregnancy test is lower-risk Class B).

Classification of Software

  • Embedded Software: Software incorporated into a medical device that drives or influences its use (e.g., image enhancement software) is classified the same as the medical device itself.
  • Standalone Software: Software that functions independently and falls within the definition of a medical device is classified on its own merits, using the same active device classification rules. Standalone software is generally considered an active device.

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Questions & Answers (4)

A
Guest

Our wearable biosensor monitors heart rate, oxygen saturation, and respiratory rate for elderly patients at home. It triggers an alert to a cloud-based dashboard if parameters fall below a threshold. Since this is non-invasive and used in a "Home Care" setting, can we argue for Class B (Rule 11)? Does the classification change if the system is also used for "Post-Operative Monitoring" within a hospital environment?

ElendiLabs

For Rule 11 of MDA/GD/0009 - Rules of Classification for General Medical Devices, the classification hinges on whether the monitoring is for "Vital Physiological Parameters" where a variation could result in immediate danger. For general home wellness, Class B is possible. However, if the device is intended for Post-Operative Monitoring where clinicians make immediate life-saving interventions based on the data, the MDA classifies this as Class C. Since your device covers both scenarios, you must register it as Class C to legally cover the hospital-use claim.

W
Guest

We are registering an In-Vitro Diagnostic (IVD) kit that detects specific biomarkers for early-stage pancreatic cancer. According to IVD Classification Rule 3, tests for life-threatening diseases are usually Class C. However, if we intend to market this as a "Population Screening Tool" rather than a "Clinical Diagnostic for Symptomatic Patients," will the MDA force a re-classification to Class D?

ElendiLabs

In Malaysia, the "Intended Use" is the primary driver. Under MD-GD0001 Rule 3, most cancer screening IVDs are Class C. However, if the MDA determines that the test is intended for screening blood, tissues, or organs for high-risk infectious agents (even if secondary), or if the failure of the screening has a massive public health impact (similar to Rule 1 for HIV/Hepatitis), it may escalate to Class D. For cancer markers, they usually stay in Class C, but your Clinical Evidence Report (CER) must prove that the "Population Screening" claim does not lead to unacceptable rates of false negatives for this fatal disease.

A
Guest

我们正在马来西亚注册一款带药物涂层的牙科骨填充材料。虽然单纯的骨填充物通常属于 Class C(基于 Rule 8),但由于其含有促进愈合的药用成分,是否会自动触发 Rule 13(药械组合产品) 而被归为 Class D?如果该药物成分在马来西亚尚未获得药监局(NPRA)的注册,审批流程会受到何种影响

ElendiLabs

确切如此。根据 东盟法规Rule 13,任何含有药用物质且该物质对器械功能起辅助作用的产品,一律归为最高风险等级 Class D。即便该药物含量极低,只要具备生物活性,分类就会升级。如果该药物未在 NPRA 注册,MDA 会要求进行“会审(Joint Consultation)”,这通常会将总审批周期延长 6-12 个月,因为需要额外评估药物部分的安全性。

T
Guest

我们有一款用于物理治疗的高频电疗设备。如果该设备具备“微电流刺激”和“热疗”两种模式,根据 Rule 9,这种能够向人体释放能量的设备通常属于 B 类。但如果我们在新版本中增加了“激光手术切除”可选配件,该产品是否需要按照“成套工具 (Set)”整体升为 C 类申报?

ElendiLabs

是的。在马来西亚,分组(Grouping)中的风险等级由最高等级的组件决定。MDA/GD-04 Rule 9 规定,如果能量释放的强度或方式可能对人体造成显著伤害(如激光手术属于 Class C),则整个注册项必须按照 Class C 进行申报。这意味着您可能需要通过合格评定机构 (CAB) 的完整技术文件审核(Full Audit),而不能走 B 类的简化审计路径。

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