Dear Commissioner Varhelyi, As a German manufacturer of software as a medical device (SaMD), we expressly support the objective of the European Commission to reclassify devices in a way that saves time and effort and is more proportionate to their inherent risk.
GAIA AG
Company · Germany · EU Transparency Register 955540094252-19
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 925 companies & groups on this site, they rank #539 by legislative files engaged — a count of participation, not a measure of influence.
Declares membership of
- Mitgliedschaften in Deutschland:
- Verband Forschender Arzneimittelhersteller e.V.
- Spitzenverband Digitale Gesundheitsversorgung e.V. →
- Bitkom
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Companies & groups
- Head office
- Hamburg, Germany
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
GAIA AG filed 2 positions between 11 Sept 2025 and 19 Jan 2026, across 1 of the 326 legislative files tracked here, attaching a full position paper 1 time.
What they argued
The current application of MDR Rule 11 leads to a systematic over-classification of Software as a Medical Device (SaMD). Even very low-risk applications, such as self-management or adherence apps, are routinely classified at least as Class IIa under a conservative interpretation. This contradicts the MDRs founding principles, particularly Recitals 58 and 60, which emphasize proportionality and risk-based regulation.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.