The International Classification of Functioning, Disability and Health (ICF) was developed as a classification and common language to conceptualise and classify functioning and disability in the context of health. If the ICF were only to be used in the context of a health condition, the application of the ICF in education would be very limited. In addition, a health-based conceptualisation of disability is not compatible with philosophy of inclusive education. Assessment in education is about gaining information for shared problem solving, not about labelling children. The ICF can be used at each step of this process and thereby helps to develop a common understanding. Problem solving in education follows a different logic from problem solving in health contexts. The argument was made that in education, ICF as a common language and as a classification, needs to focus on participation restrictions, not health conditions. The conceptual challenges and uncertainties arising from an specific approach have been highlighted.