
Introduction
Borderline Medical Device Classification Support
At QAEC Limited, we specialise in borderline medical device classification. We help manufacturers, brand owners, and distributors navigate the complex regulatory landscape for aesthetic, consumer, and borderline products.
These include non-medical aesthetic or wellness devices, cosmetic dental products, and skincare beauty tools, that may not have a defined medical purpose.
It is often unclear whether such products qualify as medical devices or general consumer goods. Our role is to bring clarity. We understand that innovation frequently challenges traditional regulatory definitions, and we help you manage that complexity responsibly and efficiently.
We provide clear, proportionate, and practical regulatory support and guidance, to help ensure your products placed on the UK and EU markets are safe, compliant, and correctly classified.
How We Can Help
Borderline Medical Device Classification Services
Borderline Classification and Regulatory Determination: We assess your product’s design, function, and claims to determine whether it falls under the UK MDR 2002, EU MDR 2017/745, EU IVDR 2017/746, or the applicable General Product Safety Regulation (GPSR), UK GPSR 2005 or EU Regulation (EU) 2023/988.
We also identify when aesthetic or wellness products may require partial compliance with medical device standards.
Safety and Technical Documentation Review: Our experts review your product information, safety data, and supporting documentation to ensure compliance. We provide guidance on biocompatibility, required testing, and applicable harmonised and international standards.
Labelling and Claims Assessment: We review labelling, packaging, and promotional materials to ensure they accurately reflect your product’s intended purpose and do not imply a medical function where one does not exist. This helps you avoid misclassification, misleading claims, and regulatory challenge.
Quality Agreements and Supply Chain Assurance: We prepare or review Quality and Technical Agreements between manufacturers, importers, and distributors. This is to define regulatory responsibilities, ensure product traceability, and maintain due diligence.

Company Insights
What Our Clients Say
Charles was extremely accommodating, particularly in that he was able to step into a Quality Manager position temporarily. Right from the start, he quickly established a good working relationship with the team. Moreover, he provided the necessary support across both QC and QA functions.
In addition, his knowledge of our industry and our medical device regulatory consulting requirements was excellent. Furthermore, his input regarding potential future improvements provided a valued insight. As a result, the team were grateful for his support and, consequently, embraced his forward-thinking approach.
Ed provided expert guidance and support for a number of quality, regulatory, and design/development process improvements. In addition, he offered hands-on input to process and document creation as well as review activities, ensuring that each step met high standards.
Moreover, Ed clearly has extensive and relevant experience. Not only that, but he is also a subject matter expert on quality and regulatory matters relating to the development and market approval of medical devices. As such, his contributions were both strategic and practical, adding significant value to our operations.
QAEC Limited provided Quality Assurance and Regulatory Affairs support services in relation to Internal Audits, MDR 2017/745-related activities, and other QARA support functions as necessary. Throughout this time, they worked closely with my team within Quality and Regulatory, consistently addressing and meeting our set objectives.
Given this experience, I would highly recommend Charles (Ed) Spearpoint, QARA Consultant at QAEC Limited, for his expertise as well as his flexible and helpful approach. Indeed, he was a pleasure to work with. Overall, QAEC Limited are a great company—very efficient and professional—and undoubtedly a valuable partner for any organisation seeking high-quality QARA support.
As Lead MDR Consultant, Ed worked closely alongside myself and my team within QA to initially conduct a gap analysis approach against the requirements of MDR 2017/745. Subsequently, he led and supported the remediation of corresponding procedures and processes, collaborating effectively with various departments and subject matter experts across our organisation.
Throughout his time on site, Ed consistently demonstrated a thorough understanding and practical working knowledge of the MDR 2017/745 regulation. In particular, he showed how it interacts with our ISO 13485:2016 Quality Management System and all associated elements. As a result, his contributions were both insightful and impactful.
Charles (Ed) Spearpoint played a key role in the daily operations of our QA Department and provided valuable support during our FDA remediation efforts. Throughout his time with us, Ed consistently demonstrated a very high standard of quality in both his work and his approach.
In addition, he brought a refreshing perspective to the organisation and actively contributed through his professional involvement as a member of both my Worldwide QA team and the local management team.
Moreover, Ed exhibited strong leadership qualities, and it was immediately evident that he brings a wealth of experience to the table. Without hesitation, I can say that my feedback about Ed is entirely positive, and I would recommend him at any time.
Charles (Ed) Spearpoint was engaged in a support capacity for our transition project from MDD to EU MDR 2017/745 for Medical Devices. In this role, Ed provided technical guidance, support, and direction. He also took on key responsibilities related to the compilation of the identified technical files.
Furthermore, he demonstrated a proactive approach and worked collaboratively across the business to help achieve the necessary deliverables in line with regulatory requirements. Notably, he challenged assumptions around what was truly required under the new regulations and helped to embed these changes effectively into our standard ways of working. Through this, he successfully navigated areas of complexity and ambiguity, ensuring compliance while maintaining operational integrity.
In addition, Ed also delivered awareness training aligned with MDR 2017/745, further contributing to organisational readiness and alignment with the new framework.
We engaged Charles Spearpoint's IVD consultancy services to support the implementation of the MDSAP standard.
With his expert guidance, we successfully completed the first stage audits for MDSAP and also achieved certificate renewals for ISO 13485:2016, ISO 9001:2015, and the Medical Device Directive.
As a result of Charles’s involvement, we are now in a significantly stronger position with regard to compliance and regulatory activities. Moving forward, we will not hesitate to use QAEC Limited’s consulting services again when needed. We would also confidently recommend their services to other companies seeking reliable and professional QARA support.
Charles was extremely accommodating, particularly in that he was able to step into a Quality Manager position temporarily. Right from the start, he quickly established a good working relationship with the team. Moreover, he provided the necessary support across both QC and QA functions.
In addition, his knowledge of our industry and our medical device regulatory consulting requirements was excellent. Furthermore, his input regarding potential future improvements provided a valued insight. As a result, the team were grateful for his support and, consequently, embraced his forward-thinking approach.
Ed provided expert guidance and support for a number of quality, regulatory, and design/development process improvements. In addition, he offered hands-on input to process and document creation as well as review activities, ensuring that each step met high standards.
Moreover, Ed clearly has extensive and relevant experience. Not only that, but he is also a subject matter expert on quality and regulatory matters relating to the development and market approval of medical devices. As such, his contributions were both strategic and practical, adding significant value to our operations.
QAEC Limited provided Quality Assurance and Regulatory Affairs support services in relation to Internal Audits, MDR 2017/745-related activities, and other QARA support functions as necessary. Throughout this time, they worked closely with my team within Quality and Regulatory, consistently addressing and meeting our set objectives.
Given this experience, I would highly recommend Charles (Ed) Spearpoint, QARA Consultant at QAEC Limited, for his expertise as well as his flexible and helpful approach. Indeed, he was a pleasure to work with. Overall, QAEC Limited are a great company—very efficient and professional—and undoubtedly a valuable partner for any organisation seeking high-quality QARA support.
As Lead MDR Consultant, Ed worked closely alongside myself and my team within QA to initially conduct a gap analysis approach against the requirements of MDR 2017/745. Subsequently, he led and supported the remediation of corresponding procedures and processes, collaborating effectively with various departments and subject matter experts across our organisation.
Throughout his time on site, Ed consistently demonstrated a thorough understanding and practical working knowledge of the MDR 2017/745 regulation. In particular, he showed how it interacts with our ISO 13485:2016 Quality Management System and all associated elements. As a result, his contributions were both insightful and impactful.
Charles (Ed) Spearpoint played a key role in the daily operations of our QA Department and provided valuable support during our FDA remediation efforts. Throughout his time with us, Ed consistently demonstrated a very high standard of quality in both his work and his approach.
In addition, he brought a refreshing perspective to the organisation and actively contributed through his professional involvement as a member of both my Worldwide QA team and the local management team.
Moreover, Ed exhibited strong leadership qualities, and it was immediately evident that he brings a wealth of experience to the table. Without hesitation, I can say that my feedback about Ed is entirely positive, and I would recommend him at any time.
Charles (Ed) Spearpoint was engaged in a support capacity for our transition project from MDD to EU MDR 2017/745 for Medical Devices. In this role, Ed provided technical guidance, support, and direction. He also took on key responsibilities related to the compilation of the identified technical files.
Furthermore, he demonstrated a proactive approach and worked collaboratively across the business to help achieve the necessary deliverables in line with regulatory requirements. Notably, he challenged assumptions around what was truly required under the new regulations and helped to embed these changes effectively into our standard ways of working. Through this, he successfully navigated areas of complexity and ambiguity, ensuring compliance while maintaining operational integrity.
In addition, Ed also delivered awareness training aligned with MDR 2017/745, further contributing to organisational readiness and alignment with the new framework.
We engaged Charles Spearpoint's IVD consultancy services to support the implementation of the MDSAP standard.
With his expert guidance, we successfully completed the first stage audits for MDSAP and also achieved certificate renewals for ISO 13485:2016, ISO 9001:2015, and the Medical Device Directive.
As a result of Charles’s involvement, we are now in a significantly stronger position with regard to compliance and regulatory activities. Moving forward, we will not hesitate to use QAEC Limited’s consulting services again when needed. We would also confidently recommend their services to other companies seeking reliable and professional QARA support.
Get Compliance Clarity
Why Choose Us
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Proven Track Record
Global expertise in quality assurance and regulatory affairs for a variety of industries, ensuring global regulatory standards are met.
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Customised Solutions
Tailored consultancy to meet your specific business needs.
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MDR and IVDR Experts
IVDR 2017/746.
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End-to-End Support
From setup and validation to ongoing audit support, we ensure continuous compliance and quality.
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Our Flexible Resource
Monthly retainer, short-term, interim, or long-term quality or regulatory support, we can help you meet your goals cost-effectively.