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Accessories to Medical Device
We are class II manufacturers, and our device contains stimulator, its charger and charging cable. Can we call the charger and the cable as accessories or it is part of the stimulator? We don't intend to sell the charger and the cable separately except for replacement as spare parts. On the same context, we also have electrodes which is connected to the stimulator with a cable. The main intended use of the device cannot be achieved without the electrodes and cable. In this scenario can we call the elecetrodes and cable as an accessory to our device? We intend to sell the electrodes and cable each separately. I know if we are planning to sell the device separately, each need to undergo its own conformity assessment but the confusion is whether to declare it as accessory or not? Thanks for the response.
Accessories and standalone SaMD
Could you please provide advise on the following scenario: We are currently working with a medical device class III and in order to fulfil the medical device`s intended purpose, a SaMD is developed and defined as an accessory. There is a strong architecture segregation according to a risk based approach and 62304 that ensure the SaMD to be class II based on the FDA: ...an accessory has the same class as the “parent device”, unless there are different risks for the accessory and the parent device. The accessories are then independently classified according to these risks... Is it possible to assume a similar approach will comply with the MDR regulation? Based on this assumption: Is it possible to reuse the same accessory with other Medical Devices with different classifications, most of them class II and have its own DHF? Is it possible to develop the accessory as a standalone SaMD as an interoperable software as medical device, with interface description, interoperable specification/residual risks etc..and with its own DHF? Is this scenarion feasible in the current MDR regulation? Thank you