[ANALYSIS] The Overview of Requirement for High Risk Cosmetic Devices in Different Countries
We have discussed the registration requirement of high-risk cosmetic implants in Indonesia, Philippines, Malaysia and Singapore in the previous (August 2019) issue. We received several responses from the readers who are interested in China market. Thus, in this issue, we have included China registration experience, along with some information on United States FDA and Europe’s requirement for high-risk cosmetic implants.
In China, medical devices are classified based on intended use categories. High-risk medical devices used for aesthetic purposes such as implants, are classified under a broader category – “Plastic and general surgical implants”. Examples of devices included under this category include breast implants and dermal fillers. NMPA publishes specific guidance documents for breast implants and dermal fillers.
Table 1: Specific Guidance Documents for Breast implants and Dermal Fillers issued by NMPA
During the market stage of the product, NMPA requests for Post Market Clinical Follow-up (PMCF) for each patient. This requirement is specifically indicated in the Product Certificate.
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As we have tackled the key information on how authorities regulate medical aesthetic devices, it is also noteworthy to mention that the European and US authorities also have established guidelines in regulating these types of devices.
The New European Regulations entitled Regulation (EU) 2017/745 on Medical Devices has just broadened the definition of medical devices to include non-medical and cosmetic devices which were previously not regulated. The included devices are summarized in Table 3. In reference with the new guideline, it was mandated that manufacturers should be able to demonstrate conformity of devices belonging under this category, with regards to application of risk management and clinical evaluation if necessary. Generally, devices with non-medical intended purpose should fulfill the requirements applicable to devices with- and to devices without intended medical purposes
List of Groups of Products Without an Intended Medical Purpose Referred to in Article 1(2) of Regulation (EU) 2017/745:
1. Contact lenses or other items intended to be introduced into or onto the eye.
2. Products intended to be totally or partially introduced into the human body through surgically invasive means for the purpose of modifying the anatomy or fixation of body parts with the exception of tattooing products and piercings.
3. Substances, combinations or substances, or items intended for facial or other dermal or mucous membrane filling by subcutaneous or intradermal injection or other introduction, excluding those for tattooing.
4. Equipment intended to be used to reduce, remove or destroy adipose tissue, such as equipment for liposuction, lipolysis or lipoplasty.
5. High intensity electromagnetic radiation (e.g. Infra-red, visible light and ultra-violet) emitting equipment intended for use on the human body, including coherent and non-coherent sources, monochromatic and broad spectrum, such as lasers and intense pulsed light equipment, for skin resurfacing, tattoo or hair removal or other skin treatment.
6. Equipment intended for brain stimulation that apply electrical currents or magnetic or electromagnetic fields that penetrate the cranium to modify neuronal activity in the brain.
In the US, specific guidelines for dermal fillers and breast implants belong under the category of “Cosmetic Devices”, which was defined by USFDA as devices used to improve appearance and do not impart any health benefits, e.g. soft dermal filler. The USFDA approves dermal fillers that are made from absorbable or temporary material for specific usage in the correction of moderate to severe facial wrinkles and skin folds, such as nasolabial folds. The agency also approves several absorbable dermal fillers for use as lip and cheek augmentation in patients over the age of 21, and the correction of contour deficiencies, such as acne scars. Fillers for hand augmentation are also approved by FDA.
FDA has NOT approved the dermal fillers to:
increase breast size (breast augmentation)
increase size of the buttocks
increase fullness of the feet
implant into bone, tendon, ligament, or muscle
With regards to breast implants, USFDA has only approved two types of breast implants for sale in US, there are saline-filled and silicone gel-filled. Both types have a silicone outer shell and vary in size, shell thickness, shell surface texture, and shape (contour).
Boost demand on medical aesthetic devices in Asia contributes to the development of health care. In the meantime, the health authority of some countries starts to regulatory of this kind of devices, especially the high-risk device. The post market surveillance of the product would become more and more important for the manufacturer. Here we suggest the manufacturer build up itself PMS plan as much as earlier.