Special Device Types
Radiation-Emitting Devices โ LK-Unique Dual Approvalโ
Medical devices that emit ionising or non-ionising radiation require two separate regulatory approvals:
- NMRA โ Registration Certificate and Import Licence (standard process)
- Atomic Energy Authority (AEA) of Sri Lanka โ approval under the Atomic Energy Authority Act
Both must be obtained before the device can be commercially supplied. The processes are independent โ progress with both in parallel. See Radiation-Emitting Devices.
Affected device types include: Diagnostic X-ray equipment ยท Dental X-ray units ยท Fluoroscopy systems ยท CT scanners ยท Radiation therapy equipment ยท Nuclear medicine equipment ยท DEXA bone densitometers ยท UV therapy lamps
Active Implantable Devicesโ
Active implantable devices (pacemakers, ICDs, cochlear implants, neurostimulators) are typically Class III and require the most rigorous registration pathway including MDEC review. Consider pre-submission consultation with the NMRA before preparing the dossier.
Devices Incorporating Medicinal Substancesโ
Products combining a device with a medicinal component may have elevated classification. The medicinal substance's role must be fully documented:
- Is the substance ancillary to the device function?
- Does the substance provide pharmacological activity?
- What is the regulatory precedent in reference countries?
NMRA may consult with the drug regulatory division for borderline combination products.
Software & SaMDโ
Classified and registered as medical devices. Required documentation includes IEC 62304, IEC 62366, ISO 14971 (for software hazards), and algorithm validation for AI/ML systems. See SaMD & Borderline Products.
Custom-Made Devicesโ
Devices manufactured to the specific requirements of an individual patient (custom-made devices) are generally exempt from standard NMRA registration. The manufacturer must maintain documentation of essential requirements compliance but formal NMRA listing is not required.
Devices Exempt from Registration โ Waiver of Registrationโ
The following uses are exempt from NMRA registration but require a Waiver of Registration (WOR):
- Devices used strictly for research purposes
- Devices used in clinical trials
- Exhibition devices at conferences (not for commercial supply)
- Donated new devices provided to healthcare institutions
Apply for a WOR from the NMRA Medical Devices Regulatory Division. Provide:
- Device description and approved research/exhibition purpose
- Confirmation device will not be sold commercially
- Institutional ethics approval (for clinical investigations)
- Post-WOR: report adverse events; do not supply beyond approved use
Single-Use Devices (SUDs)โ
Must be labelled as single-use. Third-party reprocessing of SUDs is a separate regulatory consideration that must be addressed if reprocessing is intended.