Special Device Types
Radiation-Emitting Devices — LK-Unique Dual Approval
Medical devices that emit ionising or non-ionising radiation require two separate regulatory approvals:
- NMRA — Registration Certificate and Import Licence (standard process)
- Atomic Energy Authority (AEA) of Sri Lanka — approval under the Atomic Energy Authority Act
Both must be obtained before the device can be commercially supplied. The processes are independent — progress with both in parallel. See Radiation-Emitting Devices.
Affected device types include: Diagnostic X-ray equipment · Dental X-ray units · Fluoroscopy systems · CT scanners · Radiation therapy equipment · Nuclear medicine equipment · DEXA bone densitometers · UV therapy lamps
Active Implantable Devices
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 Substances
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 & SaMD
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 Devices
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 — Waiver of Registration
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)
Must be labelled as single-use. Third-party reprocessing of SUDs is a separate regulatory consideration that must be addressed if reprocessing is intended.
In Radiation-Emitting Devices section, change 'See Radiation-Emitting Devices.' to 'See Radiation-Emitting Devices for detailed guidance on dual approval processes and AEA coordination.'
For borderline cases where the medicinal and device components are inextricably combined, the NMRA may require a joint application or coordinated review with the medicinal products regulatory division.