Custom-Made Devices
Definition
A custom-made device is a device that is:
- Manufactured to meet the specific needs of a named patient
- Made on the written instructions of a healthcare professional
- Not manufactured in series — it is not a standard product adapted for the patient
Examples
- Orthopaedic implants made to fit a specific patient's anatomy (based on imaging data)
- Dental prosthetics (crowns, bridges, dentures) made from patient impressions
- Hearing aids made to fit the specific shape of a patient's ear canal
- Custom orthotics or prosthetics
Regulatory status
Custom-made devices are exempt from the Device Licence requirement under the MDR. They do not need to be listed in MDALL.
However, custom-made devices are not exempt from all obligations:
- Must still meet the Safety and Effectiveness Requirements of Schedule 1
- Must carry compliant labelling identifying the device and the prescribing healthcare professional
- Manufacturers must maintain records of each custom device made
- Adverse event reporting obligations still apply
Distinction from "made-to-order" devices
Mass-produced devices that are simply selected from a standard catalogue to suit a patient's needs (e.g., selecting an implant of the correct size from a standard range) are not custom-made devices — they are standard devices and require a Device Licence.
True custom-made devices are one-of-a-kind products made from scratch for a specific patient.
Documentation
For a device to qualify as custom-made, the manufacturer must retain:
- The written prescription/instruction from the healthcare professional
- The patient's name or unique identifier
- A description of the specific design characteristics
- Records of materials used and manufacturing steps
Legislative source: Medical Devices Regulations, SOR/98-282, s 63 (exemptions)