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CA

Classification in Canada

A four-class cascade that asks recognisably similar questions to Annex VIII — and whose labels mean something different from the European ones that look identical.

The framework

AUTHORITY
Health Canada
INSTRUMENT
Medical Devices Regulations (SOR/98-282), Schedule 1
MARKET ACCESS
Medical Device Licence
APPROACH
Rules cascade
ON MDCLASSIFY
The engine for this market is implemented. Classify a device and the result appears alongside the EU class.

How it differs from the EU

Canada classifies under Schedule 1 of the Medical Devices Regulations, a rule cascade built on the same GHTF principles the European directives came from. So the questions feel familiar: invasiveness, duration, whether the device is active, contact with the central circulatory system. What differs is the shape of the answer. Canada uses four classes, I to IV, against the EU's four labels I, IIa, IIb and III — and the boundaries do not fall in the same places. The other structural difference is what the class buys you: a Class I device needs no device licence at all, only an establishment licence, while Classes II to IV each require a Medical Device Licence with escalating evidence.

Why the class does not simply transfer

Canadian Class III is not EU Class III. The Canadian scale runs to IV, so the top European tier maps somewhere between III and IV depending on the device, and the middle tiers do not align at all. Mapping by number is the specific mistake this market invites, because both systems use Roman numerals and one of them has an extra step.

NOTE —

Duration is a single bright line at 30 days rather than the MDR's three bands, so the European short-term band splits across two Canadian classes. Schedule 1 also has no rule for software: rules 8 to 11 speak of software dedicated to an active device, and standalone software is classified by applying those rules under Health Canada guidance rather than under a provision written for it.

The classes

CLASSRISKINDEPENDENT REVIEW
ILowNo licence required; establishment licence only
IILow-moderateLicence on manufacturer attestation
IIIModerate-highLicence with detailed review
IVHighLicence with fullest review

Common questions

How many device classes does Health Canada use?

Four: Class I to Class IV, assigned by the rules in Schedule 1 of the Medical Devices Regulations. Class I is the lowest risk and Class IV the highest.

Is Canadian Class III the same as EU Class III?

No. The Canadian scale has four steps and the European scale has four labels arranged differently, so the numbers do not correspond. A device that is Class III in the EU may be Class III or Class IV in Canada depending on its characteristics.

Does a Class I device need a licence in Canada?

A Class I device does not require a Medical Device Licence, but the company selling it generally requires an establishment licence. Classes II, III and IV each require a device licence, with the evidence required rising with the class.

Classify a device

The questionnaire classifies under the EU MDR and reports the Canada class alongside it, with the rules that produced each. Tick this market when you start.

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