Standards, Guidance & Notices
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MHLW
Notice
Notice
MHLW-PSEHB-MDED-0331-No.1
Partial Amendment of Guideline on Software as a Medical Device Classification
Revision of 2021 SaMD classification guideline (2023 version). Clarifies and refines classification criteria based on accumulated consultation cases. Adds judgment criteria for AI/ML-enabled software, cloud-based programs, and wellness applications. Maintains alignment with IMDRF N10 and N12. Updates judgment flow based on intended use and risk.
Published: 2023-03-31
JFMDA
Notice
Notice
jfmda_20221020_b84d0618
Handling of Software as a Medical Device (SaMD) Class I Products_October 20, 2022
Overview of handling procedures for SaMD Class I products. This document summarizes materials presented during the 2022 SaMD regulatory compliance seminar as an activity report by the SaMD Regulation Response Sub-Working Group.
Published: 2022-10-20
JFMDA
Notice
Notice
jfmda_20221020_fcd85f82
Explanatory Document for Software Medical Device Applicability Guideline - JFMDA Edition Version 1.0 October 20, 2022
JFMDA explanatory document providing detailed guidance on software medical device applicability determination and classification. Clarifies regulatory interpretation for software qualification and classification to support industry compliance and regulatory submissions.
Published: 2022-10-20
EU
MDCG
MDCG
Helsinki Procedure
Helsinki Procedure for borderline and classification under MDR & IVDR
Establishes the procedure by which competent authorities (CAs) in EU Member States consult one another on complex borderline and classification questions under the MDR (2017/745) and IVDR (2017/746), producing consistent EU-wide positions published in the Manual on Borderline and Classification. Manufacturers and trade associations can request an EU-wide opinion via a CA. The initiating CA submits a standardised enquiry describing the device, its intended purpose and the classification issue; other CAs respond within about one month. If more than 75% agree, a draft Manual entry is prepared and put to a vote (adoption requires a 75% majority); where consensus is not reached, the case is escalated to CA meetings or a task force, with coordination from other MDCG working groups (e.g. the New Technologies Working Group) for technology-specific questions. The full process, from enquiry to publication, takes roughly 5.5 months. The procedure is not limited to any particular product category and can be used for unclear qualification/classification questions involving SaMD.
Published: 2021-09-01
MHLW
Notice
Notice
MHLW-PSEHB-MDED-0831-No.14
Handling of Applications for Confirmation of Change Control Plans for Medical Devices
Foundational notification establishing Japan's IDATEN system (Improvement Design within Approval for Timely Evaluation and Notice). Defines the scope of eligible changes, application form requirements, supporting documentation, and notification procedures for implementing changes under a confirmed plan. Enables AI-enabled SaMD and other devices with anticipated post-market improvements to implement changes via minor change notification rather than full partial change approval.
Published: 2020-08-31
EU
MDCG
MDCG
MDCG 2020-1
Guidance on clinical evaluation (MDR) / Performance evaluation (IVDR) of medical device software
Sets out how manufacturers determine the level of clinical evidence needed for medical device software (MDSW) under the MDR (2017/745) and IVDR (2017/746), built around three components: (1) valid clinical association / scientific validity -- whether the software's output is meaningfully linked, per accepted medical knowledge or peer-reviewed literature, to the targeted clinical or physiological state; (2) technical/analytical performance -- whether the software accurately, reliably and precisely generates the intended output from its input data; and (3) clinical performance -- whether the software yields a clinically relevant result in line with its intended purpose. The required evidence level scales with device classification: MDR Class III and implantable devices generally require clinical investigation data (subject to the Article 61(4)-(6)/(10) exceptions), while IVDR generally requires performance studies regardless of class, unless an alternative evidentiary route is justified. Clinical evaluation is treated as part of the quality management system and as an iterative, ongoing process across the software's lifecycle, supported by Post-Market Clinical Follow-up (PMCF) / Post-Market Performance Follow-up (PMPF) to keep the evidence current. Annex II gives six worked examples -- covering a sleep-quality analyser, an image segmentation tool, a semi-quantitative IVD calprotectin detector, embedded device-driving software, an insulin-pump companion app, and closed-loop ventilator CO2-control software -- illustrating when MDSW can be evaluated independently versus when it must be evaluated jointly with the hardware it drives or influences.
Published: 2020-03-01
EU
MDCG
MDCG
MDCG 2018-5
UDI assignment to medical device software
Clarifies, for software that is placed on the market either as a standalone medical device or as a component of another medical device, when manufacturers must assign a new Basic UDI-DI as opposed to simply updating the UDI-PI (production identifier) for a minor version change. A new Basic UDI-DI is required when a change affects the software's original performance, safety, or interpretation of data -- for example, new or modified algorithms, database structures, operating platforms, architecture, user interfaces, or new interoperability channels -- or when the Basic UDI-DI itself, the name/trade name, version/model number, critical warnings or contraindications, or the user-interface language changes. By contrast, minor revisions such as bug fixes, non-safety-related usability improvements, security patches, or operating-efficiency changes do not require a new Basic UDI-DI; these are tracked instead through the manufacturer's own version/release identification scheme reflected in the UDI-PI. The guidance notes that UDI placement (labelling/display) criteria are addressed in a separate, later guide, and should be read together with MDCG 2018-1 on UDI assignment.
Published: 2018-10-01
IMDRF
IMDRF/SaMD WG/N41 FINAL:2017
Software as a Medical Device (SaMD): Clinical Evaluation
IMDRF final document on the clinical evaluation of SaMD. It defines clinical evaluation as a set of ongoing activities to assess and analyze a SaMD's clinical safety, effectiveness, and performance, consisting of three components: valid clinical association (is there a valid clinical association between the SaMD output and the targeted clinical condition?), analytical validation (does the SaMD correctly process input data to generate accurate, reliable, and precise output data?), and clinical validation (does use of that output achieve the intended purpose in the target population in the context of clinical care?). All SaMD should demonstrate these components, using existing evidence or generating new evidence. Depending on the N12 risk category and subject to each jurisdiction's laws, manufacturers of certain low-risk SaMD may self-declare the appropriateness of the evidence, while independent review of clinical evidence becomes more important for higher-risk SaMD. Manufacturers continue to collect real-world performance data after market entry.
Published: 2017-09-21
IMDRF
IMDRF/SaMD WG/N12 FINAL:2014
Software as a Medical Device: Possible Framework for Risk Categorization and Corresponding Considerations
IMDRF final document proposing a possible framework for risk categorization of SaMD and the corresponding considerations. The category is determined by combining two factors: the significance of the information provided by the SaMD to the healthcare decision (treat or diagnose, drive clinical management, or inform clinical management) and the state of the healthcare situation or condition (critical, serious, or non-serious), resulting in four categories, I to IV, with treating or diagnosing a critical condition in the highest category (IV). The categories are relative and reflect the level of impact on the patient or public health, where accurate information provided by the SaMD is vital to avoid death, long-term disability, or other serious deterioration of health. Categorization relies on an accurate and complete SaMD definition statement. Other aspects, such as the transparency of inputs or technological characteristics, do not influence the category but inform the identification of considerations specific to a given SaMD, such as clinical evaluation, quality management, and information security.
Published: 2014-09-18
IMDRF
IMDRF/SaMD WG/N10 FINAL:2013
Software as a Medical Device (SaMD): Key Definitions
IMDRF final document setting out a common definition of SaMD and a reminder of related key terms. SaMD is defined as software intended to be used for one or more medical purposes that perform these purposes without being part of a hardware medical device, and the document converges on the term SaMD in place of terms such as "standalone software." Notes to the definition state that SaMD is a medical device and includes IVD medical devices; that it is capable of running on general purpose (non-medical purpose) computing platforms; that "without being part of" means the software is not necessary for a hardware medical device to achieve its intended medical purpose; that software intended to drive a hardware medical device does not meet the definition; that SaMD may be used in combination with (e.g., as a module) or interfaced with other products, including medical devices; and that mobile apps meeting the definition are SaMD. Software used to make or maintain a device is not considered SaMD. Relevant key terms previously defined in GHTF documents are also restated.
Published: 2013-12-18
