Class IIa (Medium-Risk) Medical Device Manufacturing Insurance (UK Guide)

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Class IIa (Medium-Risk) Medical Device Manufacturing Insurance (UK Guide)

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Class IIa (Medium-Risk) Medical Device Manufacturing Insurance: What You Need, Why You Need It, and How to Get It Right

Manufacturing a Class IIa (medium-risk) medical device is a serious step up from low-risk products. Even if your device is not implantable and not life-sustaining, it still sits in a category where patient safety, regulatory compliance, performance claims, and traceability matter a lot.
That’s exactly why insurance becomes more than a “tick-box.” For Class IIa manufacturers, the right insurance programme can protect you from the financial shock of:
  • A product complaint that escalates into a claim
  • A batch issue that triggers a recall
  • A supplier defect that causes downstream harm
  • A cyber incident that disrupts production or compromises data
  • A regulatory investigation that halts sales
  • Contractual liability from distributors, hospitals, or procurement frameworks
This guide breaks down the core insurance covers Class IIa device manufacturers typically need, what insurers look for, common gaps, and how to keep premiums under control—without leaving your business exposed.

What is a Class IIa medical device (and why does it matter for insurance)?

Class IIa devices are generally considered medium-risk under medical device classification rules. The exact classification depends on jurisdiction and device rules, but Class IIa often includes products such as:
  • Certain diagnostic devices and monitoring equipment
  • Non-invasive devices that interact with the body in limited ways
  • Some dental devices
  • Certain surgical instruments (depending on use and invasiveness)
  • Devices used for short-term contact with the body
  • Some software as a medical device (SaMD), depending on intended use
From an insurance perspective, Class IIa matters because it typically implies:
  • Higher product liability exposure than Class I
  • Greater scrutiny on quality management systems (QMS)
  • More emphasis on post-market surveillance, vigilance, and traceability
  • Stronger contractual requirements from buyers and distributors
  • Higher likelihood of recall costs being material
  • Increased risk of regulatory action impacting revenue
In plain terms: the more “medical” and risk-bearing your product becomes, the more insurers care about your controls—and the more expensive a claim can be if something goes wrong.

The core insurance covers for Class IIa device manufacturers

1) Product Liability Insurance (the foundation)

If you manufacture medical devices, product liability is usually the most critical cover. It protects your business if your product causes:
  • Bodily injury (patient/user harm)
  • Property damage
  • Associated legal defence costs
Even a single allegation can become expensive quickly. Legal costs, expert witnesses, and settlement negotiations add up—especially when medical evidence is involved.
What insurers will ask you:
  • Your device types, intended use, and classification
  • Territories sold into (UK only vs EU/US/global)
  • Annual turnover, batch sizes, and distribution model
  • Complaint rates, incident history, and recalls
  • QMS standards (e.g., ISO 13485), audits, CAPA process
  • Supplier controls and traceability
  • Labelling, IFU clarity, and marketing claims governance
Common gaps to avoid:
  • Policies that exclude certain territories (e.g., US/Canada) when you export
  • Exclusions for “medical products” hidden in generic manufacturing policies
  • Inadequate limits for contracts with hospitals/distributors

2) Product Recall / Product Contamination Insurance (often overlooked)

Product liability covers injury/property damage claims, but recall costs can be a separate financial event—especially when the issue is discovered early and you recall before harm occurs.
A recall policy can help cover:
  • Notification and communication costs
  • Product retrieval and logistics
  • Disposal/destruction
  • Replacement or repair costs (depending on wording)
  • Crisis management / PR support
  • Business interruption tied to recall (sometimes optional)
For Class IIa manufacturers, recall risk can be triggered by:
  • Sterility assurance failures
  • Packaging integrity issues
  • Labelling errors (wrong IFU, language issues, contraindications missing)
  • Supplier material defects
  • Software bugs affecting performance claims
  • Traceability gaps that force wider-than-necessary recall scope
Why it matters:
Even if nobody is harmed, a recall can still cost tens or hundreds of thousands—sometimes more—especially if you sell through multiple channels.

3) Professional Indemnity (PI) / Errors & Omissions (E&O)

Many medical device manufacturers provide more than a physical product. You may also provide:
  • Design services
  • Device configuration
  • Training and implementation support
  • Technical documentation support
  • Software updates and performance guidance
  • Consulting around integration or clinical workflow
That’s where professional indemnity becomes important. It covers claims that your advice, design, or professional services caused a client financial loss or harm.
Typical triggers:
  • Incorrect instructions or training materials
  • Misleading performance claims in documentation
  • Integration errors (especially with software and connected devices)
  • Failure to meet contractual specifications
If you produce software as a medical device or connected devices, PI/E&O becomes even more relevant.

4) Clinical Trials / Clinical Investigation Insurance (if applicable)

If you run clinical investigations, you may need specific cover for:
  • Participant injury
  • Sponsor and investigator liabilities
  • Ethics requirements and contractual obligations
This is usually separate from standard product liability and depends on where and how trials are conducted.

5) Employers’ Liability (UK legal requirement)

If you employ staff in the UK, Employers’ Liability is generally required by law. It covers claims from employees who suffer illness or injury arising from their work.
For device manufacturing, this might include:
  • Exposure to chemicals/solvents (where relevant)
  • Repetitive strain injuries
  • Workplace accidents in production or warehousing
  • Cleanroom-related hazards (depending on operations)

6) Public Liability (site and operational risks)

Public liability covers injury or property damage to third parties caused by your business activities—separate from product defects.
Examples:
  • A visitor slips at your facility
  • A contractor is injured while on-site
  • Damage caused during installation work (if you do on-site work)

7) Property Insurance (buildings, contents, stock, equipment)

Manufacturing is asset-heavy. Property cover can protect:
  • Buildings (if owned)
  • Contents and equipment (including specialised manufacturing machinery)
  • Stock and materials
  • Tools and test equipment
If you have cleanrooms, calibration equipment, or specialised testing rigs, it’s worth ensuring the policy reflects replacement cost and any specialist reinstatement needs.

8) Business Interruption (BI)

If a fire, flood, or insured event shuts down production, BI can cover:
  • Lost gross profit
  • Ongoing fixed costs
  • Increased cost of working (e.g., temporary premises, outsourcing)
For Class IIa manufacturers, BI can be especially important because:
  • Lead times and validation requirements can make recovery slow
  • Supply chain disruption can cascade
  • Regulatory re-validation may be needed after certain incidents

9) Cyber Insurance (increasingly essential)

Medical device manufacturing is now deeply digital:
  • ERP and inventory systems
  • Quality systems and document control
  • Connected production equipment
  • Customer and supplier data
  • Device software, updates, and telemetry (where applicable)
Cyber insurance can help with:
  • Ransomware response and recovery
  • Business interruption from cyber events
  • Data breach response (legal, notification, forensics)
  • Third-party liability claims
  • Regulatory defence costs (depending on wording)
Even if you don’t store patient data, you may still hold sensitive commercial data and intellectual property—and downtime alone can be devastating.

10) Directors’ & Officers’ (D&O) Liability

If you have investors, a board, or senior leadership exposure, D&O can protect directors and officers from claims alleging mismanagement, breach of duty, or regulatory failures.
This can be relevant if:
  • A recall impacts financial performance
  • A regulatory issue triggers stakeholder disputes
  • Contractual disputes escalate into claims against leadership

Contractual requirements: what buyers and distributors often demand

Class IIa manufacturers frequently face insurance requirements in contracts, including:
  • Minimum product liability limits (sometimes £5m/£10m+ depending on buyer)
  • Inclusion of distributors as “additional insured” (varies by contract)
  • Worldwide territorial cover (especially if exporting)
  • Evidence of recall cover
  • Cyber requirements (especially for connected devices)
A common mistake is buying a policy that looks “big enough” but doesn’t match:
  • the territory
  • the product type
  • the contractual wording
  • the definition of “insured products”

What affects the cost of Class IIa manufacturing insurance?

Insurers price risk based on both hazard (what could go wrong) and controls (how you prevent and respond). Typical pricing drivers include:
  • Device type and intended use (risk profile)
  • Sales territories (US exposure can materially increase cost)
  • Turnover and batch volume
  • Claims/complaints history
  • Recall history
  • Strength of QMS (ISO 13485, internal audits, CAPA maturity)
  • Supplier management and incoming inspection
  • Traceability and UDI practices
  • Post-market surveillance processes
  • Labelling/IFU governance and change control
  • Software development lifecycle controls (if applicable)
  • Storage conditions and distribution controls
The good news: manufacturers who can demonstrate strong controls often get better terms.

How to reduce risk (and often improve insurance terms)

Insurers love evidence. If you can show the following, you typically look like a better risk:
  • Clear device classification rationale and technical documentation
  • Robust complaint handling and trend analysis
  • CAPA records that show real corrective action
  • Supplier qualification and audit trails
  • Batch traceability and retention samples (where relevant)
  • Documented change control for design, labelling, and IFU updates
  • Clear marketing claims governance (no “miracle cure” language)
  • Training records and competency checks
  • Calibration schedules and maintenance logs
  • Incident response plan (recall + cyber)
Even if you’re a smaller manufacturer, strong systems can help you compete for better premiums.

Common mistakes Class IIa manufacturers make with insurance

Here are a few issues that regularly cause coverage disputes or nasty surprises:
  1. Assuming public liability covers product issues
    It usually doesn’t. Product liability is separate and must be explicit.
  2. Not declaring exports or online sales territories
    If you sell into the EU/US or ship internationally, your policy must reflect it.
  3. Buying generic manufacturing insurance
    Some policies exclude medical devices or impose strict conditions.
  4. Ignoring recall exposure
    Recalls can happen without injury. Without recall cover, you may pay everything.
  5. Underinsuring business interruption
    If your recovery time is realistically 6–12 months, insure accordingly.
  6. No cyber cover despite connected operations
    Ransomware doesn’t care if you’re “small.”

What to prepare before you request a quote (to speed things up)

If you want quicker, cleaner quotes, have these ready:
  • Product list with classification and intended use
  • Territories sold into and distribution model
  • Turnover split by product line and geography
  • QMS certifications (e.g., ISO 13485) and audit summaries
  • Claims/complaints/recall history (even if “none”)
  • Manufacturing process overview (including any outsourced steps)
  • Supplier management approach
  • Cyber controls overview (MFA, backups, patching, incident response)
  • Desired limits and contractual requirements
This helps brokers and insurers avoid assumptions—and assumptions are where exclusions and delays come from.

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