Clinical Evaluation Requirements
Overview
All medical devices submitted for registration in Russia must be supported by clinical evidence demonstrating safety and performance. The extent of clinical evidence required depends on device class and whether the device is innovative (no registered equivalent in Russia).
Clinical data requirements by class
| Class | Clinical evidence required |
|---|---|
| Class I | Existing clinical literature review may be sufficient; local testing often waived if adequate data available |
| Class IIa | Clinical evaluation report required; local testing may be waived if good-quality existing data is available |
| Class IIb | Clinical evaluation report required; local clinical testing typically required |
| Class III | Full clinical evaluation required; local clinical testing generally mandatory |
What constitutes clinical evidence
Clinical evidence may consist of:
- Published clinical literature (peer-reviewed studies, systematic reviews)
- Clinical investigation data from studies conducted abroad
- Equivalent device clinical data (where equivalence can be justified)
- Post-market clinical follow-up data
However, for innovative devices or where foreign data is considered insufficient, Roszdravnadzor (via the FGBU) may require local clinical testing in Russia.
Innovative devices
For devices with no registered equivalent in Russia, a local clinical investigation must be conducted. This means:
- The manufacturer must design a clinical investigation protocol
- National Ethics Committee approval must be obtained before starting the investigation
- The investigation must be conducted in approved Russian clinical centres
- Results are submitted to Roszdravnadzor as part of Phase 2 of registration
This requirement adds considerable time to the registration process — plan for several additional months at minimum.
Pre-clinical testing
Pre-clinical test reports (safety and biocompatibility testing, electrical safety, EMC) must be included in the dossier. All testing should align with applicable GOST R standards. Where testing is conducted outside Russia, reports from internationally accredited laboratories are generally accepted, but the FGBU may require supplementary local testing.
Government Decree No. 1684 (2025): government.ru