Loaded spring device - Active medical device?

#1
Does anyone know if the presence of a pre-loaded spring inside a device makes it automatically an active medical device?
My company is producing a painless blood collection device which initially we thought would fall into a class 2a. Recently our CM told us that from their experience, if the -device has a pre-loaded spring (mechanical energy) it will automatically be an active medical device. Is this true? Does anyone had similar experiences?
 
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#2
Below is the definition of active medical device, as it appears in the new European law - MDR:

‘active device’ means any device, the operation of which depends on a source of energy other than that generated by the human body for that purpose, or by gravity, and which acts by changing the density of or converting that energy. Devices intended to transmit energy, substances or other elements between an active device and the patient, without any significant change, shall not be deemed to be active devices.

Nothing is "automatically" classified as an active medical device.
You will need to evaluate your device based on this definition.

Good luck.
 
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