Multi-market product qualification

Is it a medical device in every market?

Compare one product across the European Union, Great Britain, the United States, Canada and Australia. See the possible regulatory routes before changing claims, appointing representatives or requesting market-entry quotations.

Compare the routes that need to be tested.

Select the closest product type and the markets in scope. This navigator identifies review questions; it does not issue an automated classification decision.

Markets to compare
Selected product

Health app, software or AI

Open the full country comparison →

Use in healthcare does not by itself make software a device. Function, user, significance of the output and manufacturer claims are decisive.

European Union

possible routes

Possible routes: medical-device software under the MDR or IVDR, a non-medical function, or a module outside device scope.

What changes the answer

Whether the software analyses patient-specific data and provides information used for diagnosis, therapy, monitoring or prediction.

Market-entry consequence

If the product is a device, its class, conformity-assessment route and evidence for CE marking must be established before market entry.

European Commission: MDCG guidance and borderline manual →

Great Britain

England, Scotland and Wales
possible routes

Possible routes: device software under the UK MDR, or an informational, administrative or general-wellness product.

What changes the answer

Intended purpose, the output’s significance for a clinical decision and the specificity of medical claims.

Market-entry consequence

Status must be established under Great Britain rules. A qualification reached in another jurisdiction should not be transferred automatically.

MHRA: borderlines with medical devices →

United States

possible routes

Possible routes: device software, a mobile medical-app function outside active FDA oversight, or a low-risk general-wellness product.

What changes the answer

Intended use, indications and whether the output is used for diagnosis, treatment or to affect a body function.

Market-entry consequence

If the product meets the device definition, the applicable FDA device type, product code and premarket route must be identified.

FDA: how to determine if a product is a medical device →

Canada

possible routes

Possible routes: software as a medical device, a general-wellness function or an administrative tool.

What changes the answer

Whether the standalone function processes an image, signal or data and provides a recommendation on prevention, diagnosis or treatment.

Market-entry consequence

Qualification affects device class, device or establishment licensing and the Canadian importer. An alternative route may lead to a drug or natural health product.

Health Canada: factors at the device–drug interface →

Australia

possible routes

Possible routes: regulated device software, excluded software, an exempt device, or a general-wellness product.

What changes the answer

Therapeutic purpose, clinical use, serious-disease claims and satisfaction of every condition of a specific exclusion.

Market-entry consequence

If the product is a device and no exclusion or exemption applies, it generally requires ARTG inclusion through an Australian sponsor before supply.

TGA: confirm whether a product needs ARTG inclusion as a device →
Defined next step

Written qualification for the actual product and selected markets

MEDDEV reviews the intended purpose, mode of action, labelling, instructions, product website and promotional claims. The output records the rationale, open issues and next regulatory route.

Navigator scope: orientation only. Official sources last checked 27 July 2026. Status depends on the specific product version, stated intended purpose, mode of action and communication. A binding determination may be made by the competent authority or a court.

Qualification file

What MEDDEV tests before stating a route

A reliable answer must cover the marketed product, not an abstract product category.

  1. Define the exact product and markets. Manufacturer, configuration, users, sales channels and countries.
  2. Freeze the intended purpose and claims. Label, instructions, website, app stores, catalogues and distributor copy.
  3. Test the principal mode of action. Physical, mechanical, chemical, pharmacological, immunological or metabolic contribution.
  4. Compare the local legal routes. Device, medicine, cosmetic, biocide, food, wellness product or another category.
  5. Record the consequence. Classification work, evidence, local representative or sponsor, registration and claim changes.
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