File Conversion: Device or Non-Device?

SSchoepel

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Hello, I cannot find the right Japan regulations or guidance on how to determine if a file conversion tool is a medical device, excluded, or is not considered a device.

The file conversion tool would do nothing other than change a file from one format to another (for example, it would be like converting from Google Sheets to Excel). There is no interface, no calculation, no control, just pure file conversion.
 
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