Medical Device Vigilance: Important Considerations to Comply With the EU MDR
Vigilance reporting and postmarket surveillance of medical devices are among the many requirements documented in the EU MDR (2017/745) to ensure the...
3 min read
Veranex : Apr 26, 2024 9:41:14 AM
The EU Parliament adopted the regulation amending EU 2017/745 (MDR) and EU 2017/746 (IVDR) aiming to protect patients by ensuring the availability of safe devices that are essential for healthcare systems. The amending regulation extends the transition periods for certain IVDs (legacy devices and in-house devices) subject to the fulfilment of certain conditions and introduces a gradual rollout of EUDAMED and a new obligation for manufacturers to give a prior notice in case of disruption of supply.
Here’s a quick overview of the changes put forward by the amending regulation.
The availability of safe and effective IVDs is essential for patient care and the regulation EU 2017/746 aims to modernize the EU framework to ensure safe and effective devices are made available to the EU public.
80% of the IVDs under IVDD are self-certified (i.e., no involvement of a notified body in the conformity assessment process) and under the new regulation, shall need a notified body intervention for obtaining a CE mark. One of the big challenges for the IVD industry in the process of complying with the new requirements is the availability of notified bodies that can support in conformity assessment process. To ensure the availability of such devices, the amending regulation proposes more time for manufacturers to comply with new requirements under certain conditions, without compromising safety requirements.
Devices for which the conformity assessment procedure under Directive 98/79/EC did not require the involvement of a notified body (up-classified devices) will benefit from longer transition periods provided certain conditions are met. The proposed transition periods are:
Only ‘legacy devices’ (as defined in MDCG 2022-8) may benefit from extended transition periods if they fulfil the following conditions:
It’s important to note that manufacturers of legacy devices can benefit from longer transition periods only when the above-mentioned conditions are met, and these conditions would have a direct impact on the transitional effort.
Manufacturers are now required to give prior notice (ideally 6 months in advance) if they foresee an interruption of supply of IVDs or medical devices.
As a measure to enhance transparency regarding medical devices made available on the EU market, the amending regulation shall enable the gradual implementation of the individual EUDAMED modules that are audited and declared functional. As such mandatory use of several EUDAMED modules start as early as Q4 2025.
Although extending transition periods based on device risk classes supports a better implementation of the regulation and gives adequate time for the industry to prepare for the transition, we strongly encourage IVD manufacturers to continue their transitional efforts without any pause!
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