The IVDR has brought in a “Risk based” approach as against the earlier “List based approach”. This classification is based on a GHTF guideline (GHTF/SG1/N045:2008), thereby it aligns with international best practice. The objective of this system is to improve patient safety. Although IVDs do not typically have the potential to cause direct harm, as may be the case with other medical devices, they do have the potential to cause indirect harm. For instance, an erroneous false positive or false negative result may lead to incorrect diagnosis and incorrect treatment leading to harm to the patient of varying magnitudes. For example, consider the impact of an incorrect test result for COVID-19 or for HIV.
Devices are now classified into four classes- Class A, B, C, D (highest) depending on the risk of the product. Only Class A products do not require Notified Body oversight. Under the IVDR, more than 80% of the IVDs will require notified body approvals, as against the 20% IVDs under IVDD!
Therefore, before considering CE marking, it is imperative that manufacturers revisit their device’s classification under the new rules and the implications of up-classification is huge!