Sterility, measuring function and single-use status receive privileged treatment in conformity assessment because they raise the device's risk profile. In class I devices delivered sterile, the production and sterilisation processes enter notified body audit; validation of the sterilisation method, microbiological evidence and packaging integrity are mandatory parts of the technical file. In devices with a measuring function, accuracy and stability are proven against defined metrological requirements; if measurement error affects the patient decision, the assessment deepens. The single-use mark is the manufacturer's open declaration: reuse is exiting the intended purpose, and responsibility for reuse arises with the reuser. At import inspection these three characteristics are sought consistently across the triple of label, instructions and technical file; inconsistency is a ground for nonconformity. The short rule: if one of these three words is on the label, the file must be built thicker than normal.
In the medical device world some products carry an extra special status alongside their class label: those delivered sterile, those with a measuring function, and those marked single-use. These three characteristics deepen the conformity assessment even when the product appears low-risk, such as class I: sterile and measuring class I devices leave the ordinary class I track and enter notified body review; the single-use mark is a legal boundary on reuse whose violation directly produces a safety event. On the import side, these three characteristics generate the most questions at inspection: where is the sterilisation evidence, against which standard was measurement accuracy shown, and are the single-use mark and instruction correct on the label? This article explains the rules of the three special cases, their evidence requirements and the import practice.
Who is this for?
This guide is for every role working with sterile, measuring or single-use devices. Manufacturer representatives manage the cost and process of these characteristics' conformity assessment. Distributors must know the document demands of special-status products in their portfolio. Importers prepare the evidence set that will be requested at inspection. Quality units manage sterilisation validation reports and measurement verification records in the technical file. Hospital and laboratory users and sterilisation centres know the operational counterpart of the single-use boundary and the re-sterilisation prohibition. Regulatory teams track which special status triggers which assessment. Procurement ties requesting characteristic-specific evidence from suppliers into contracts. At audit these three characteristics are product safety's most concrete test area; a file caught unprepared produces a credibility loss.
Which products does it cover?
The scope is medical devices carrying at least one of the three characteristics. Those delivered sterile: surgical instruments, catheters, injection and sampling materials, wound dressings, implants and sterile sets. Those with a measuring function: devices measuring for diagnostic purposes, patient monitoring equipment, sensors carrying accuracy claims, and systems tying measurement results to treatment decisions. Those marked single-use: syringes, biopsy needles, single-use endoscopes, filters and disposable accessories. The characteristics can intersect: a product can be sterile, single-use and measuring at once, and each characteristic demands its own evidence. At the border, for products unclear between reusable and single-use, the decisive factor is the manufacturer's declaration; it must be consistent across the label, instructions and technical file. Devices intended for re-sterilisation in health institutions follow a different regime from devices delivered sterile by the manufacturer, and the two must not be confused.
When does it apply?
The special-status rules apply across the whole placing-on-market and import process; the critical moments are these. In a new product's conformity assessment, if a special status exists the notified body process must be planned from the start; a sterile product pushed into the normal class I track becomes marked through an invalid route. When the manufacturing site or sterilisation supplier changes, the validation evidence must be renewed. On a sensor or algorithm revision, metrological verification is repeated. On label and instruction revisions, the single-use mark, symbols and warning language are kept current. At import inspection these characteristics are checked directly in the physical inspection: packaging integrity, markings, Turkish instructions and batch traceability. In market surveillance, use errors and complaints return as instruction deficiencies. On the health institution side, attempts at reuse or re-sterilisation are assessed as violations of the manufacturer's declaration and must be prohibited through internal processes. Every special status must be managed with its own trigger table.
Legal framework and authority
The frame is the European medical device regulation Türkiye applies nationally. The regulation contains special provisions requiring notified body involvement even for low-class devices that are sterile or carry a measuring function; a separate provision exists for reusable surgical instruments. On the sterilisation side, method-based international standards apply: validation of sterilisation processes, microbiological performance and packaging-system integrity are the subject of these standards. For the measuring function, metrological requirements and accuracy classes are defined; the impact of measurement error on clinical outcomes determines the assessment's depth. Single-use status rests on the manufacturer's declaration and the marking rules; the consequences of reuse are assessed within the product safety framework. The competent authority is TİTCK: it oversees conformity assessment, runs market surveillance and monitors safety events. On the import side the inspection is performed by technical units within the product safety communiqué frame. Current standard lists and guides must be tracked from official sources.
Step-by-step process
- Extract the product's special-status inventory: sterile, measuring, single-use; build a characteristics table.
- Verify the conformity assessment route for each characteristic: if a notified body is required, plan the process from the start.
- File the sterilisation evidence: method, validation report, microbiological data and packaging integrity tests.
- Prepare the measurement verification set: accuracy class, calibration infrastructure and clinical impact assessment.
- Set the single-use declaration consistently with label and instructions: symbol, warning language and the reuse prohibition written openly.
- Check the Turkish-language requirements: instructions, warnings and symbol explanations are mandatory content.
- Prepare the import document set: declaration of conformity, certificate scope, label samples and technical file references.
- Prepare for the physical inspection: packaging, marking and batch traceability verifiable by sampling.
- Inform the user side: deliver the single-use boundaries and instruction content to the receiving institutions.
Document checklist
- Special-status inventory table: characteristics per product.
- Conformity assessment route and notified body process record.
- Sterilisation validation report and method notification.
- Microbiological evidence and release criteria.
- Packaging integrity and shelf-life tests.
- Measurement verification reports and the metrological requirement mapping.
- Calibration infrastructure and traceability records.
- Single-use declaration: symbol, warning and instruction language.
- Label and instruction samples, with the Turkish content check.
- Import file: declaration, inspection outcome and receipt records.
Parties and responsibilities
| Party | Responsibility |
|---|---|
| Manufacturer / Authorised representative | Producing the special-status evidence and keeping it in the technical file |
| Notified body | Assessment and audit for sterile and measuring products |
| Importer | Currency and presentation of the document set at inspection |
| Distributor | Transport and storage conditions, label integrity |
| Quality unit | Managing validation and verification records |
| Health institution / user | Compliance with the single-use boundary and application of instructions |
| TİTCK | Conformity oversight, market surveillance and safety monitoring |
The most critical row is the user: reusing a single-use device renders the entire chain's evidence meaningless in one move. User information must be designed as part of the process.
Exceptions and edge cases
The edges of the special statuses produce frequent questions. A device designed for re-sterilisation in the health institution and a device sterilised by the manufacturer are different regimes; in the first, the re-sterilisation instruction and cycle limit are evidenced, in the second, the validation of production sterilisation is demanded. In products not delivered sterile but foreseeing sterilisation before use, the label declares this openly. The boundary between a measuring function and an indicator lies in the measurement's weight in the medical decision; a screen showing decorative values is assessed differently. A health institution cleaning and reusing a single-use product leaves the manufacturer's area of responsibility but produces regulatory and safety risk; for some products official guidance draws the line on reprocessing. A set can contain sterile and non-sterile components together; each component is labelled with its own declaration. Shelf life and sterility guarantee are not the same thing; each is proven with its own test. In borderline cases the basis must be written: the instruction, the standard or the authority's opinion.
Common mistakes
The most common mistake is pushing a sterile class I product into the normal class I track; the notified body is skipped and the mark loses its basis. The second is taking the sterilisation validation from the supplier and not filing it; the report exists but not in the technical file. The third is treating marketing documents as proof of measurement accuracy; a metrological report is required. The fourth is adding the single-use symbol but not writing the warning language; the mark stands alone, the instruction is weak. The fifth is neglecting packaging integrity tests; sterility lives with the packaging. The sixth is adding Turkish instructions to a sterile product afterwards; the information chain to the user breaks. The seventh is not taking reuse reports seriously; single cases are safety signals requiring systemic correction.
Important notice
This article is general information, not legal or customs advice; for requirements on sterilisation, measurement accuracy and single-use status, the applicable legislation, standards and guides must govern. Product examples and GTİP information in the text are for orientation; the GTİP examples are not binding. Standard versions can be updated; official sources must be checked before any transaction.
Frequently asked questions
Why does a sterile class I device require a notified body?
Because sterility carries an additional risk arising not from the product itself but from the process. The choice of sterilisation method, its validation, microbiological monitoring and packaging integrity must be assessed together; this whole must be subjected to independent review, not left to the manufacturer's own declaration. The regulation therefore ties even low-class devices delivered sterile to notified body involvement. The practical result is this: even if the product looks class I, the document set and cost approach the high-class track; planning must be made accordingly.
Who determines the single-use mark and what does it mean?
The manufacturer decides and shows its declaration consistently across the label, instructions and technical file. The mark is an open notice that the product is designed for a single use only and must not be reused afterwards. Reuse is exiting the intended purpose: safety and performance are no longer proven, and responsibility passes to the using side. Health institutions must protect this boundary with internal processes; in products where reuse is bounded by official guidance, the guidance governs. The importer's task is to inspect the declaration's consistency with the label.
Which evidence is demanded for devices with a measuring function?
Evidence of accuracy and stability is demanded according to the metrological requirements the product declares: error limits, repeatability and performance under use conditions. The evidence rests on reports produced with defined test methods; on sensor or algorithm revisions it is renewed. Where the measurement result enters a diagnostic or treatment decision, a clinical impact assessment is added and the assessment deepens. The calibration infrastructure and traceability are also shown in the file. At import inspection the counterparts of this evidence in the technical file can be requested; an unprepared file stops the transaction.
How is a device intended for re-sterilisation distinguished from one delivered sterile?
The decisive factor is the manufacturer's declaration. In a device foreseeing re-sterilisation, the instructions define the permitted methods, cycle limits and how performance is preserved; the health institution complies with that instruction. In a device delivered sterile by the manufacturer, sterility is achieved through a one-time production process, and after the package is opened use must occur within the foreseen time. The two regimes' evidence sets differ: in the first, re-sterilisation validation; in the second, production sterilisation validation. Confusion leads to errors in both the technical file and the user instructions; which regime applies must be written openly per product.
Official sources
- Medical Device Regulation (EU) 2017/745, EUR-LexTİTCK / Ticaret Bakanlığı · verified 07 Sep 2026
- TİTCK Medical Device Clinical ResearchTİTCK / Ticaret Bakanlığı · verified 07 Sep 2026
- Product Safety and Inspection Communiqué AnnouncementsTİTCK / Ticaret Bakanlığı · verified 07 Sep 2026
Revision history
v1.1 · 07 Sep 2026 — Content import: external full text applied.
v1.0 · 16 Aug 2026 — Initial source-backed publication.