# Borderline products: medical devices and medicinal products

Source: https://www.keypedia.com/records/uk_mhra_guidance/uk-mhra/bff1866b-8ce4-4e30-8023-87b81573b401
Type: Guidance
Published: January 19, 2015
Updated: December 31, 2020

> This guidance, issued by the Medicines and Healthcare products Regulatory Agency (MHRA), provides a framework for manufacturers to distinguish between medical devices and medicinal products in Great Britain (England, Wales, and Scotland). The document focuses on 'borderline products,' which are items that do not clearly fall into a single category, creating potential regulatory ambiguity. Because the legal requirements for medicines and medical devices differ significantly, accurate classification is essential for ensuring product safety and market compliance. While this document is a general regulatory framework rather than a report on a specific company inspection or set of violations, it serves to prevent the legal and safety issues that arise from improper product categorization. Under the current regulatory framework, the MHRA determines a product's status based on its primary mode of action and intended use. For instance, products that work through pharmacological or metabolic means are generally classified as medicines, whereas those with physical or mechanical actions are categorized as medical devices. The required actions for manufacturers involve a comprehensive self-assessment of their products against these MHRA standards to ensure they follow the correct authorization pathways. Compliance is mandatory for any entity wishing to place healthcare products on the market in Great Britain. Furthermore, the guidance clarifies that different rules apply in Northern Ireland, necessitating that companies operate with awareness of regional legislative variations to avoid distribution delays or regulatory enforcement actions.

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## Content

This guidance outlines how the MHRA decides whether a borderline product is a medical devices or a medicine, and which regulations apply. This guidance is specific to products placed on the market in Great Britain (England, Wales and Scotland). Find out how medical devices are regulated in Northern Ireland .

## Attachments

- [Borderlines between medical devices and medicinal products](https://assets.publishing.service.gov.uk/media/5fedc5a7e90e0776ab4e2069/Borderlines_between_medical_devices_and_medicinal_products.pdf)