How to Determine if Your Product is a Medical Device in Indonesia

Understanding whether your product qualifies as a medical device is a critical step in ensuring compliance with regulatory requirements. In Indonesia, medical devices encompass a broad range of products from basic diagnostic tools to advanced medical technologies. This guide, tailored for businesses navigating the regulatory landscape, provides clear steps to identify whether your product meets the definition of a medical device under Indonesian regulations.

Step 1: Define Your Product’s Intended Use

The first step is to clearly establish the intended use and indications for use of your product. These definitions are crucial for determining whether your product qualifies as a medical device.

  • Intended Use: Describes the general purpose of the product or its function. For example, is the product designed to diagnose, treat, or prevent medical conditions?
  • Indications for Use: Describes the specific conditions or patient population the product is intended to address. For example, a glucose meter is intended to monitor blood sugar levels in diabetic patients.

According to Indonesian Ministry of Health (Kementerian Kesehatan or Kemenkes) regulations, products that are intended to diagnose, prevent, monitor, treat, or alleviate disease typically fall under the medical device category.


Step 2: Identify Applicable Medical Device Classifications

Once you have defined your product’s purpose, the next step is to determine its classification. Indonesian regulations categorize medical devices into risk-based classes:

  • Class A: Low-risk devices (e.g., tongue depressors, surgical gloves)
  • Class B: Medium-risk devices (e.g., syringes, infusion sets)
  • Class C: High-risk devices (e.g., ventilators, surgical lasers)
  • Class D: Highest-risk devices (e.g., pacemakers, in vitro diagnostic (IVD) test kits)

Methods to Determine Classification:

  1. Review Similar Devices: Search for existing medical devices with similar functions that have been approved by Kemenkes. This helps to confirm if your product falls under a particular classification.
  2. Consult the Indonesian Medical Device Catalog: This catalog provides detailed classifications and regulatory pathways for medical devices.
  3. Engage with Regulatory Experts: Consulting with regulatory professionals, like the INSIGHTOF team, can streamline the classification process and ensure compliance with local regulations.

Step 3: Special Considerations for Software and Combination Products

If your product involves software, it may qualify as a Software as a Medical Device (SaMD). Additionally, combination products that integrate medical devices with drugs or biological components may require additional regulatory pathways. INSIGHTOF can assist in navigating these complex classifications.

What to Do if Your Product is Not a Medical Device

If your product does not meet the definition of a medical device, it may fall under other regulatory categories such as cosmetics, pharmaceuticals, or general consumer goods. For instance:

  • Cosmetics are regulated under BPOM (Badan Pengawas Obat dan Makanan).
  • Pharmaceuticals fall under specific guidelines by the Ministry of Health.


Navigating medical device regulations in Indonesia can be complex. At INSIGHTOF, we specialize in assisting companies with product registration, regulatory compliance, and market authorization. Our experienced team can guide you through every step—from determining product classification to securing approvals.

If you are unsure about your product’s classification or require expert assistance, contact INSIGHTOF today for a consultation. Our regulatory experts ensure your product complies with all Kemenkes and BPOM requirements, allowing you to focus on delivering innovative healthcare solutions.

For any inquiries, please feel free to contact us at marketing@insightof.co.id.

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