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Risk class is not portable

62% of medical device types are classified differently depending on the market. Here is the data, and what it means for a submission plan.

Of 1,525 device types registered in at least four comparable markets, 945 — 62% — carry a different risk class in at least one of them. A dental implant system is a high-risk device in Brazil, Canada, China, Mexico and Taiwan, a medium-risk device across the EU and most of Asia, and a low-risk device in South Korea. Same device, same GMDN term, three different regulatory burdens.

This is not published anywhere, because it is not any single registry's fact. Each authority states its own classification; none of them states how that compares to the others. It only becomes visible by observing the same device type across many registries at once, which is what Meridian Trace does.

Why it matters before you file

Risk class drives the submission route, the evidence package, the review timeline and often whether a local clinical evaluation is required. A plan built on the assumption that a device's EU class carries into Brazil or China is a plan that discovers a heavier dossier late, when the timeline no longer has room for it.

The direction is not consistent either, which is what makes it hard to intuit. Brazil is stricter than the EU for catheters and femoral nails, and less strict for external fixation systems. Australia and the UK sit low on orthopaedic fixation while China sits high. There is no reliable rule of thumb to substitute for looking.

Device types with the widest spread

Every row below is registered in at least four markets, with at least 15 registrations and 60% agreement per market. Ranked by how far apart the classifications sit.

Device typeClassed High inClassed Medium inClassed Low in
Posterior-chamber intraocular lens, pseudophakic
GMDN 35658 · 9,882 registrations
China, Indonesia, Philippines, Taiwan, Thailand Australia, Colombia, European Union, Hong Kong, India, Malaysia, Saudi Arabia, United Kingdom, Vietnam South Korea
Spinal bone screw, non-bioabsorbable
GMDN 46651 · 8,548 registrations
Canada, China Australia, European Union, India, Saudi Arabia, United Kingdom, United States, Vietnam Brazil, South Korea
Dental implant suprastructure, permanent, preformed
GMDN 44879 · 7,378 registrations
Canada Australia, European Union, India, Singapore, United Kingdom, United States, Vietnam Taiwan
Tibia intramedullary nail
GMDN 38152 · 3,703 registrations
Brazil, Canada, China, South Korea Colombia, European Union, India, Indonesia, Saudi Arabia, United Kingdom, United States, Vietnam Australia
Dental implant system
GMDN 55847 · 3,662 registrations
Brazil, Canada, China, Mexico, Taiwan Australia, Colombia, European Union, Hong Kong, India, Indonesia, Malaysia, Saudi Arabia, Singapore, United Kingdom, Vietnam South Korea
In vitro diagnostic immunological reagent
GMDN 13891 · 3,237 registrations
Colombia, South Korea Canada, China, Costa Rica, European Union, India, Indonesia, Singapore, Taiwan, Vietnam Mexico
Catheter, nelaton
GMDN 10734 · 2,626 registrations
Brazil, Colombia, Thailand Canada, Hong Kong, India, Indonesia, Singapore, Taiwan, Vietnam Mexico
Femur intramedullary nail
GMDN 33187 · 2,563 registrations
Brazil, Canada, China Colombia, European Union, India, Indonesia, Malaysia, Saudi Arabia, Singapore, United Kingdom, Vietnam Australia
Immunochromatographic antigen rapid test
GMDN 12633 · 2,297 registrations
Brazil Canada, China, Hong Kong, India, Indonesia, Saudi Arabia, Singapore, Vietnam European Union, Taiwan
General internal orthopaedic fixation system implantation kit
GMDN 44759 · 2,194 registrations
China Colombia, European Union, Hong Kong, Malaysia, Saudi Arabia, Singapore, Taiwan, United States, Vietnam Australia, Brazil, Indonesia, United Kingdom
External orthopaedic fixation system, single-use
GMDN 48011 · 1,580 registrations
Canada China, Colombia, European Union, Indonesia, Saudi Arabia, Singapore, Taiwan, United States, Vietnam Australia, Brazil, South Korea, United Kingdom
Soft corrective contact lens, daily-wear
GMDN 47842 · 1,523 registrations
China Australia, Brazil, Canada, Colombia, Hong Kong, Indonesia, Malaysia, Saudi Arabia, Taiwan, United Kingdom, United States, Vietnam South Korea
Knee tibia prosthesis trial, reusable
GMDN 58716 · 1,501 registrations
European Union United Kingdom, United States Saudi Arabia
Patient positioning thermoplastic mould material
GMDN 40896 · 1,493 registrations
South Korea Canada, India, United States Brazil, Indonesia, Malaysia, Taiwan, United Kingdom
Barrier membrane, resorbable, periodontal
GMDN 13051 · 1,355 registrations
China, Colombia, European Union, India, South Korea — Brazil

Look up any device type

The same data is queryable for any device type, by GMDN code, GMDN term, or FDA product code. From an AI agent over MCP, or directly:

curl -s https://meridiantrace.com/v1/mcp \
  -H "X-API-Key: YOUR_KEY" \
  -H "content-type: application/json" \
  -d '{"jsonrpc":"2.0","id":1,"method":"tools/call",
       "params":{"name":"classify_device",
                 "arguments":{"device_type":"Dental implant system"}}}'

It returns the GMDN hierarchy, the FDA product codes the type maps to, and the observed risk class in every market where we hold enough records to say — each with the sample size behind it. A free key takes about a minute at meridiantrace.com/api.

Method, and what this is not

These are observed classifications, drawn from the risk class recorded on actual registration records in each market, not from reading each country's classification rules. For every device type and market we report the modal class, the share of records agreeing with it, and the number of records it was drawn from. A market showing n=15 is a hint; n=3,000 is a pattern. Both travel with the answer so you can tell them apart.

That makes this a good way to find out where your assumptions are likely wrong, and a poor substitute for a regulatory determination. Registries also differ in how they name classes, which we normalise to Low / Medium / High — a normalisation that is useful for comparison and lossy at the edges. Confirm against the market's own classification rules before you file.

Data as of 20 August 2026, drawn from 1.9M registration records across 36 national registries. Coverage and per-registry crawl dates are queryable via the get_coverage tool.

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