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January 3, 2025

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Philippines Medical Device Classification: Aligning with ASEAN MDD Risk Rules

Philippines Medical Device Classification System

The Philippines medical device regulatory system is undergoing a transition toward harmonization with the ASEAN Medical Device Directive (MDD). Manufacturers must determine their device's classification to ascertain the appropriate market authorization pathway required by the Center for Device Regulation, Radiation Health and Research (CDRRHR) of the FDA.


Risk-Based Classification (Class A to D)

Medical devices are classified into four risk categories, from lowest to highest risk, primarily based on the ASEAN MDD classification rules. Key factors influencing the classification include:

  • Level of Risk: Potential harm to the patient or user.
  • Degree of Invasiveness: Whether the device is non-invasive, invasive, or surgically invasive.
  • Delivery Method: How the device is introduced or used on the human body.
ClassificationRisk LevelMarket Authorization Required
Class ALowest RiskCertificate of Medical Device Notification (CMDN)
Class BLow-Moderate RiskCertificate of Medical Device Registration (CMDR)
Class CModerate-High RiskCertificate of Medical Device Registration (CMDR)
Class DHighest RiskCertificate of Medical Device Registration (CMDR)

IVD Device Classification

In Vitro Diagnostic (IVD) devices are classified separately from general medical devices but also use the four-class risk structure (Class A to D). The risk is determined by specific criteria:

  • Intended Use: The purpose of the diagnostic test.
  • User Expertise: The intended skill level of the user.
  • Impact of Results: The importance of the resulting information and the impact of a false result (e.g., an HIV blood test is typically Class D, while a routine pregnancy test is Class B).

As the IVD risk increases, the required documentation for registration becomes more extensive.


Special Status Exemptions

Certain medical devices are exempt from the standard CMDN or CMDR requirements but still require a Medical Device Listing with the FDA. These include devices intended solely for:

  • Research
  • Clinical Trial
  • Exhibit
  • Donated and/or Novel use

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