India Risk Classification for Pain Management as Medical Device

India Risk Classification for Pain Management as Medical Device

Introduction – Pain Management as Medical Device India

This article focuses on pain management medical devices regulatory aspects and the classification of pain management devices as Medical Devices under the Medical Device Rules 2017 in India. The Central Drugs Standard Control Organization (CDSCO) has established specific guidelines for medical device classification India, categorizing them into Class A, B, C, and D based on their risk levels. These devices range from self-notified low-risk products, such as heat therapy gels and ice collars, to highly regulated implantable pain management systems. Regardless of their classification, all pain management devices must comply with CDSCO’s regulatory requirements to ensure safety, efficacy, and quality in the Indian healthcare system.

India is Updating Existing Risk-Based Classifications for Pain Management

As per the latest notification MED-16014(12)/1/2024-eOffice, released on January 6, 2025, 8 devices have been reclassified from Class A to Class A (Self-Notified), and 1 device has been reclassified from Class A to Class B. This update simplifies compliance for low-risk devices and aligns with the CDSCO registration for pain devices in India. The full list of reclassified devices, along with their updated classifications, is available in this document, with changes clearly highlighted in dark grey for easy reference.

Table : CDSCO Pain Management Device Classes and Risk Classification

S. No.

Device Name as per Medical Device Rules in India

Intended Use

Risk Class

1

Acupuncture electrical stimulation system

An assembly of devices used to apply electrical stimuli to acupuncture sites.

B

2

Acupuncture kit

A collection of instruments and supplies used to perform acupuncture procedures.

B

3

Acupuncture point detector

An electronic probe used to precisely locate an acupuncture point on a patient’s body.

B

4

Analgesic spinal cord electrical stimulation system

An assembly of devices that applies an electrical stimulus to all or part of the spinal cord to relieve pain (analgesia).

C

5

Cryogenic analgesia unit

A device designed to provide analgesia by applying extremely low temperatures to body tissues. It is used for postoperative and chronic intractable pain relief.

C

6

Electric pad localized-body heating system

An assembly of devices designed for the transcutaneous application of heat to a localized body site to relieve musculoskeletal pain.

B

7

Endothermic cold therapy pack

A device intended to be applied with pressure to the body surface to provide cold therapy to help reduce fever, pain, and inflammation associated with joint/muscle/tissue injury and/or minor burns.

B

8

Foot bath

A device designed to be filled with water to provide therapeutic heat treatment specifically to the feet. This device is intended to relieve foot pain as well as headaches, coughs, and other cold symptoms.

A

9

Heat therapy gel

A non-sterile gelatinous compound in a container that is dispensed for application to the body surface to provide a warming effect for underlying tissues. It is intended to reduce/relieve pain, muscle tension, and to increase local circulation.(Not in direct contact with tissue)

A

10

Ice collar

Intended to alleviate pain and/or promote healing in minor injuries of the neck, throat, and/or head and to alleviate a sore throat.

A

11

Implantable intrathecal infusion pump

A device designed to be implanted in a patient for the storing and subarachnoid (intrathecal) administration of narcotics/drugs to manage intractable pain and muscle spasms of malignant or non- malignant origin.

D

12

Implantable lumbar neuromuscular electrical stimulation system

The system is designed to deliver episodic electrical stimulation to nerves that innervate lumbar muscles to elicit contraction for the treatment of chronic low back pain (CLBP).

D

13

Inflatable hot/cold therapy pack/electric pump

A assembly of devices intended for localized thermal and compression therapy to facilitate the treatment of a variety of adverse conditions resulting from musculoskeletal injury.

B

14

Inhalational analgesia unit

A device primarily designed to administer analgesic gases to the patient, or produce analgesic vapours for inhalation.

B

15

Intervertebral disc prolapse therapy pack

A device intended to be applied to the skin overlying an affected area of the spine (cervical or lumbar) to reduce pain associated with a prolapsed (herniated) intervertebral disc.

B

16

Neurophysiologic monitoring system

An assembly of devices designed to monitor and provide electrical stimuli to spinal nerves or other neural pathways during intraoperative surgery or intensive care, typically to reduce the incidence of accidental injury during instrumented spine surgery, or to diagnose acute dysfunction in corticospinal conduction.

C

17

Pain-relief phototherapy skin patch

A skin patch designed to reflect the naturally emitted infrared energy back into the body, with a reduced range of wavelength, intended to provide comfort and localized temporary relief of body aches and pains by phototherapeutic stimulation of strategic points on the skin.

B

18

Acupressure wristband

A device designed to be worn on the wrist(s) for the application of pressure to the Nei-kuan (P6) acupressure point, the area identified to help relieve the sensation of nausea.

B

19

Bite relief pad

A thin, plastic, horseshoe-like wafer that is placed between the upper and lower sets of teeth and bitten down on, or chewed, to help relieve pain or discomfort after orthodontic treatment.

Class A (Self-Notified)

20

Ear microsystem needle

An instrument used in auriculotherapy to apply continuous pressure to stimulate meridian points.

Class A (Self-Notified)

21

Ice bag

Intended to alleviate pain and/or promote healing in minor injuries to the body or for application around the neck or limbs.

Class A (Self-Notified)

22

Intubation Teeth protector

A device designed to fit over the upper and lower sets of teeth to protect them from damage during endotracheal (ET) tube intubation procedures.

Class A (Self-Notified)

23

Inversion table

A fixed framework with a tilting table platform designed to support the body of a patient and provide traction for the back muscles and spine by allowing the patient manually invert their entire body in a supine position (feet up and head down), thereby assist patients eliminate/alleviate back pain.

Class A (Self-Notified)

24

Massage table/couch

A table designed for various kinds of complementary therapy.

Class A (Self-Notified)

25

Sitz bath

A tub filled with water, that is heated by its heating elements and circulated by its agitators, intended for use in external hydrotherapy to relieve pain or pruritus and to accelerate the healing of inflamed or traumatized tissues of the perianal and perineal areas.

Class A (Self-Notified)

26

Sitz bath chair

A device designed to be sat upon by a patient in a powered sitz bath for external hydrotherapy to relieve pain or pruritus and to accelerate the healing of inflamed or traumatized tissues of the perianal and perineal areas.

Class A (Self-Notified)

Conclusion:

The classification of pain management medical devices under the Medical Device Rules 2017 reflects ongoing India medical device regulatory approval updates by the Central Drugs Standard Control Organization (CDSCO) in India. These devices, ranging from self-notified Class A products such as heat therapy gels and ice collars to highly regulated Class D implantable infusion pumps, must align with CDSCO’s guidelines to ensure safety and efficacy. The classification helps streamline compliance for manufacturers while maintaining adherence to India’s medical device regulations.

For assistance with the pain management medical device regulatory process in India, reach out to Morulaa. Email us at admin@morulaa.com or visit our website for the latest updates.

Let’s Talk

Request your free proposal. Call us today, or fill out the form and we will get right back to you!

Let’s Talk

Request your free proposal. Call us today, or fill out the form and we will get right back to you!