§ COMPARE REGULATORS

MHRA vs TGA: Medical Device Regulatory Comparison

Compare the medical device registration pathways, classification, and regulatory requirements of MHRA (United Kingdom) vs TGA (Australia).

MHRA

Medicines and Healthcare products Regulatory Agency

United Kingdom

Post-Brexit, the MHRA operates an independent regulatory framework for medical devices in the UK. The UK Conformity Assessed (UKCA) marking is replacing CE marking for the UK market. The MHRA is devel

CLASSES

Class I, IIa, IIb, III

PATHWAY

UKCA marking via UK Approved Body

KEY FUNCTIONS
  • UKCA marking
  • UK device registration
  • Yellow Card adverse event reporting
  • UK Approved Body oversight

TGA

Therapeutic Goods Administration (Australia)

Australia

The TGA regulates medical devices in Australia under the Therapeutic Goods Act 1989. Australia uses a risk-based classification system aligned with GHTF/IMDRF. The TGA is an MDSAP participating author

CLASSES

Class I, IIa, IIb, III, AIMD

PATHWAY

ARTG inclusion via conformity assessment

KEY FUNCTIONS
  • ARTG registration
  • Conformity assessment
  • MDSAP participation
  • Adverse event reporting
  • Post-market surveillance

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§ OTHER COMPARISONS