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Webinars

The Impact of MDR transition period extensions

February 8, 2023

eBooks

2023 Regulatory performance report

February 1, 2023

4 min read

Today at Rimsys, we unveiled the 2023 MedTech Regulatory Performance Report, a new set of insights into the state of medtech regulatory affairs. Compiled based on interviews with 200 regulatory professionals and executives, the study provides a detailed look into how regulatory teams are staffed, their processes, the tools they use, and ultimately how they perform.

Why did we create this study? There were two driving factors behind the research. The first was a common theme that we heard from a number of our customers: Regulatory leaders don’t have clear data and benchmarks. They don’t necessarily know how long a new market submission should take, and how to plan for or assess the work of their teams. While other studies look at the medtech industry broadly or the state of the regulatory profession, this study tries to build a comprehensive resource for regulatory (and company) leaders.

The second factor was really for ourselves and the team at Rimsys. As a company building solutions specifically for medtech regulatory affairs, we wanted more insight into where companies were successful, where they struggled, and where we can add value.

What did we find? Regulatory teams perform a lot of hero work and rate themselves highly for their accomplishments. At the same time there is a lot of opportunity for process improvements, and companies that invest in digital transformation for regulatory affairs see better performance.

Regulatory professionals are superheroes

Regulatory teams are generally pretty small. Most companies have less than 10 full-time regulatory professionals. These small teams complete an enormous amount of work. Last year on average, RA teams completed 50 license renewals, 50 license updates, and 10 new market submissions. This is impressive output.

Digging a bit under the covers, we found that this output relied heavily on the support of external consultants. 90% of companies use consultants to keep pace with their regulatory workload. Front-line employees also struggle with burnout. They were much more likely to report feeling under-resourced than regulatory leaders.

But process problems persist

A lot of regulatory work remains extremely manual. 70% of regulatory teams spend half their time or more on repetitive administrative tasks.  All of this manual work increases the frequency of errors and required rework. 61% of companies reported a major non-compliance incident in the past 2 years.

Manual work also makes it difficult to complete regulatory projects in a timely fashion. Teams completed a lot of projects, but each took a long time. Over half of all companies spend 4 months or more on license renewals, license updates, and new market submissions.  

Moving regulatory affairs forward

As regulatory requirements become more complex, there’s a natural question about how teams will work moving forward. MDR & IVDR in Europe have significantly increased the regulatory workload required to bring and keep products on the market. Will organizations be able to keep pace with the same resources, tools, and processes?  

No, and the performance report shows that medtech companies are investing to improve their regulatory capabilities. The majority of companies are planning to increase the sizes of their RA teams in 2023, and 40% expect to increase their investments in regulatory software. Companies are increasingly adopting specialized software to better support regulatory processes.

Dig into the survey results

The full survey results provide insights into more aspects of regulatory performance. They show that companies need to take a deeper look into their processes and how regulatory resources are allocated. There are two ways to learn more:

  1. Visit the survey page to see the full results (the survey whitepaper can be downloaded at no cost)
  2. Watch the recording of our webinar with PA Consulting. We discuss the survey results in more detail and share our regulatory predictions for 2023

Data Sheets

Making the case for a RIM system: an Infographic

December 15, 2022

Webinars

Medtech Post-market essentials

December 8, 2022

eBooks

Post-market surveillance for medical devices in the European Union

December 5, 2022

4 min read

This article is an excerpt from Post-market surveillance for medical device in the European Union.

Table of Contents

What is post-market surveillance?

Post-market surveillance (PMS) is designed to monitor the performance of a marketed medical device by collecting and analyzing field use data. Article 10 of the EU MDR and IVDR requires all device manufacturers to have a post-market surveillance system in place. The main elements of the PMS are laid out in Article 83, and additional details for lower-risk and higher-risk devices are covered in articles 84 and85, respectively.

In general, a PMS system consists of both proactive activities and reactive, or vigilance, activities. While post-market surveillance and vigilance are sometimes used interchangeably, vigilance consists of separate activities that feed post-market surveillance programs.

Post-market surveillance systems are used to collect and analyze data not only about the manufacturer’s device but also about related competitors’ devices that are on the market. Data collected through PMS procedures is then used to identify trends that may lead to, among other things, quality improvements, updates to user training and instructions for use, and identification of manufacturing issues.

Note that “market surveillance” encompasses activities performed by a Competent Authority to verify MDR compliance, and should not be confused with the topic of this ebook,“post-market surveillance," which is performed by the manufacturer.

What classes of medical devices require post-market surveillance?"

All medical devices marketed in the EU require some level of post-market surveillance, and all medical device manufacturers must implement a post-market surveillance system (PMS). The requirements of the PMS, however, vary and should be “proportionate to the risk class and appropriate for the type of device” (MDR Chapter VII). In particular, the type and frequency of reporting vary based on a device’s risk class.

Components of a successful post-market surveillance plan

A post-market surveillance plan (PMS) is an integral part of a manufacturer’s quality management system and provides a system for compiling and analyzing data that is relevant to product quality, performance, and safety throughout the entire lifetime of a device. The PMS should also provide methods for determining the need for and implementing any preventative and corrective actions. A PMS system should include and define:

Surveillance data sources

With the increased focus on proactive risk identification in the MDR, it is important to design post-market surveillance systems that actively acquire knowledge and detect potential risks. It is not sufficient to rely solely on spontaneous reporting by healthcare providers, patients, and other stakeholders.

Post-market surveillance plan components

In addition to information coming from Clinical Evaluation Reports and complaint and adverse event reporting, typical sources of surveillance data include:

• Social media networks: Because many of your stakeholders may be communicating on social media networks, it is important to employ social listening techniques and/or tools to identify issues and concerning trends as they develop.

• Industry and academic literature: Any studies, academic papers, and other literature that addresses similar devices or the specific use cases for which your device is designed should be evaluated. In particular, risk factors and adverse events identified with similar devices should be closely examined. It is also important to identify newer technologies that may affect the benefit-risk ratio and establish a new definition of “state of the art” for the device type.

• EUDAMED: While the European Database on Medical Devices (EUDAMED) is not yet fully functional, it is intended to provide a living picture of the lifecycle of all medical devices marketed in the EU. Manufacturers should take special care to consider information for similar devices made available through the EUDAMED system in the future.

• Registries: Patient, disease, and device registries can provide information that informs the clinical evaluation process which provides input into the post-market surveillance system.

Data analysis methodology

A well-defined data analysis methodology will accurately identify trends and lead to defendable decisions in the application of post-market experience. Once the necessary information has been identified and collected, and potentially cleaned of incomplete or otherwise unusable data, the data needs to be analyzed.

The goal is to identify meaningful trends, correlations, variations, and patterns that can lead to improvements in the safety and efficacy of the device. There are many data analysis tools available that can assist with:

• Regression analysis that will identify correlations between data (e.g. the device location/geography correlates to battery life).

• Data visualization that can be useful in spotting trends in the data.

• Predictive analytics, which can be particularly useful with large data sets, to identify future trends based on historical data.

• Data mining, which is also normally used with large datasets, to organize data and identify data groups for further analysis.

Benefit-risk indicators and thresholds

The MDR requires that medical device manufacturers not only demonstrate the clinical benefit of their device but also quantify the benefit-risk ratio. The benefit of a device must be shown to clearly outweigh the risk for it to gain market approval. Article 2 (24) of the MDR defines the benefit-risk determination as “the analysis of all assessments of benefit and risk of possible relevance for the use of the device for the intended purpose when used in accordance with the intended purpose given by the manufacturer.”

A PMS system should clearly define benefit-risk calculations and the data used to support them. Post-market surveillance activities are critical in order to re-evaluate and maintain the benefit-risk calculations and determinations of a device throughout its life. Information that is gained through a PMS system can lead to:

Identification of new risk factors.

Adjustments to risk frequency and/or severity values based on actual use data.

Adjustments to established risk calculations based on new “state of the art” technologies becoming available.

Adjustments to established benefit calculations based on actual use data.

Complaint and feedback handling processes

While complaint handling and other feedback tracking are more often described as part of post-market vigilance systems, they play a role in the more proactive post-market surveillance processes as well. A PMS system should define ...

To continue reading this ebook, download the full version.

Webinars

Regulatory clearance for medical devices

November 10, 2022

Blogs

Brexit overview for medical device manufacturers

By

Bethaney Lentz

September 7, 2022

4 min read

What is Brexit?

Brexit - meaning "British exit" is the process of the official withdrawal of the United Kingdom (UK) from the European Union (EU) on January 31, 2020, at 11:00 PM (GMT). The UK had been a member state of the EU since January 1, 1973, when it was known as the European Communities. 

Leaving the EU was no easy task for the UK and it was six years in the making before it was final. When they “left” in January 2020, a discussion and negotiation transition period with the EU began. The negotiation process was both politically challenging and deeply isolating. Under the UK Prime Minister, Boris Johnson, the country continued to participate in many EU institutions during the one-year transition period in order to ensure frictionless trade until a long-term relationship could be agreed upon. Trade deal negotiations continued up until just days before the scheduled end of the transition period (December 31, 2020) and the EU–UK Trade and Cooperation Agreement was signed on December 30, 2020.

Following Brexit, EU law and the Court of Justice of the European Union no longer have power over British citizens and companies, with the exception of select areas related to Northern Ireland. Under the terms of the Brexit withdrawal agreement, Northern Ireland continues to participate in the European Single Market in relation to goods and to be a de facto member of the EU Customs Union

The European Union Referendum Act 2015 set the wheels in motion. This Act of the Parliament of the United Kingdom made a legal provision for a referendum to be held on whether it should remain a member state of the European Union or leave it completely. The related legislation was introduced to the House of Commons in May of 2015, and it was passed on its third review in the House of Commons in early September 2015 and approved by the House of Lords in December 2015. The Act went into full legal force on February 1, 2016.

The initial withdrawal in March 2019 was delayed by the deadlock in the British parliament after the June 2017 general election. This deadlock then led to three extensions of the UK’s Article 50 of the Treaty of European Union (TEU), which began the member states’ withdrawal, known as Brexit.

Brexit timeline

Brexit’s effect on medical device regulations

All medical devices, including IVDs, custom-made devices, and systems or procedure packs must be registered with the UK’s Medicines and Healthcare Products Regulatory Agency (MHRA) before they can be placed on the UK market. The MHRA is developing a new regulatory framework for medical devices, designed to safeguard and advance the health of its people by enabling early access to a high-quality supply of safe, effective, and innovative medical products. CE marked devices will initially be recognized in the UK, but manufacturers will have to obtain UK Conformity Assessment (UKCA) certification and follow the marking requirements per UK MDR 2002, beginning July 1, 2023. CE-marked devices will be allowed in the UK market until June 30, 2023, as long as they have been CE marked under one of the following:

Medical device manufacturers continue to be able to self-certify CE marked devices until June 30, 2023 - providing the certificates remain valid for the EU market under the transitional timelines listed in the EU MDR and IVDR.

From January 1, 2022, non-UK manufacturers will require a UK Responsible Person for the purposes of registering devices. A Northern Ireland-based Authorized Representative will no longer be able to register devices on a manufacturer’s behalf for Great Britain.

You will need to use the new UKCA marking before January 1, 2023, if your product:

  1. will be marketed in Great Britain, and
  2. is covered by legislation that requires the UKCA marking, and
  3. requires mandatory third-party conformity assessment, and
  4. conformity assessment has been carried out by a UK conformity assessment body.

This does not apply to existing stock if your goods were fully manufactured, CE marked, and placed on the market before January 1, 2021.

Northern Ireland – the rules are different

In some circumstances, it is a requirement of the UK MDR 2002 that you inform the MHRA when you first place your device on the Northern Ireland market. Under the Northern Ireland Protocol, different rules apply than those in Great Britain. The precise requirements depend on the location of the manufacturer, the location of the Authorized Representative, and the device class. For more information on the regulatory system for medical devices in Northern Ireland, refer to the Regulation of medical devices in Northern Ireland.

The future of medical device regulations under Brexit

As you can see, the rules have changed and may continue to be refined until June 30, 2023. Currently, the CE marking is only valid in the UK for areas where both UK and EU rules remain the same. The UKCA marking is not recognized in the EU market, therefore, products will need the CE marking to sell in the EU. The UK MDR 2002 is up to date with all changes known to be in force on or before June 28, 2022. However, there may be changes that will be brought into force at a future date. 

For more information on the EU MDR and IVDR requirements, read our Ultimate guide to the EU MDR/IVDR unique device identifier (UDI) system and Ultimate guide to the EU MDR GSPR - general safety and performance requirements.

MedTech
Blogs

The RegUP rundown

By

Dell Lundy

August 18, 2022

4 min read

What is a RegUP?

The medical device industry is, by its very nature, a high-stress one. New medical technologies are being created all the time, and as a result, regulations are constantly changing. Being a regulatory professional in the medtech industry requires extraordinary attention to detail and nerves of steel. Rimsys was founded by regulatory pros for regulatory pros, and we understand the need to unwind in a professional environment with other leaders in the industry. That’s why we came up with the idea of the RegUP. 

So, what’s a RegUP? It’s short for “Regulatory Meetup,” and it’s a small gathering of regulatory professionals, not a large conference. We’ll enjoy delicious food and beverages as we get to know each other and discuss regulatory trends and best practices.

When and where?

Boston - Sept 29th

Our first RegUP event will be held on the East Coast in Boston, MA, on September 29, 2022, at Democracy Brewing. Democracy Brewing, nestled in historic Downtown Crossing (one of the oldest neighborhoods in the United States), is the first cooperative brewery in Boston. Their menu features plenty of delicious craft beers and an eclectic selection of cuisines ranging from Mediterranean to classic American bar food. 

San Jose - Oct 13th

Our second event will be held on the West Coast in the San Jose area on Oct 13, 2022, at Big Dog Vineyards. Big Dog Vineyards is a locally owned and operated winery in the picturesque Milpitas Hills, CA. Their Winery & Tasting Room opened in 2009, right beside the estate vineyard, which was planted in 1997. 

What should you expect at a RegUP event?

As  mentioned, we understand that regulatory professionals in the medical device industry are under constant pressure to ensure they keep up with ever-changing trends and best practices. And if you are like us, the opportunity to hone your trade and sharpen your skills and knowledge in a more casual setting will be welcome. 

Here’s the agenda for RegUP Boston to give you an idea of what to expect at our events:

  • 12:00 - 12:30 pm Welcome: Increasing confidence in regulatory planning. Many regulatory challenges are driven by a lack of visibility into regulatory timelines, resources, and needs. A comprehensive regulatory data strategy can help RA teams build more resilient plans, and shift their organizational posture from reactive to proactive.
  • 12:30 - 1:15 pm Catered lunch
  • 1:15 - 1:45 pm TBD Regulatory best practices case study
  • 1:45 - 2:15 MDR/IVDR information essentials: MDR/IVDR compliance remains top of mind for RA teams. New information requirements including GSPRs, UDI/EUDAMED, and Post-market surveillance and reporting require a new approach to regulatory information management.
  • 2:15 - 4:00 pm Brewery tour, tasting, and networking

Rimsys Speakers

  • James Gianoutsos - Founder & CEO
  • Bruce McKean - Director of Regulatory (Boston)
  • Adam Price - Director of Product, Post Market (San Jose)

We hope to see you there!

Our RegUP events in Boston and San Jose will be the first of many opportunities for us to network, further regulatory knowledge and processes, and even enjoy each other’s company over tasty beverages. Best of all, these events are free for Rimsys customers and qualified guests. 

Of course, you can also expect these events to get bigger and better with time. Nonetheless, you don’t want to miss out on the first of these opportunities to get to know us and our industry better. We hope to see you there! If you are unable to attend though, keep an eye on our LinkedIn page for future RegUP events in a city near you. 

To get more information and register for our upcoming events, click the links below:

MedTech
Blogs

IVDR: In Vitro Diagnostic Regulation within the European Union

By

Wendy Levine

August 3, 2022

4 min read

What is the IVDR In Vitro Diagnostic Regulation?

The European Union’s In Vitro Diagnostic Regulation (IVDR) 2017/746 applies to IVD devices and came into force on May 26, 2022. The IVDR is a major change over the In Vitro Diagnostic Directive (IVDD), which it supersedes. The new regulation is designed to better protect patients and address changes in IVD technology through new requirements and stricter controls. As a Regulation, unlike a Directive, the IVDR becomes a requirement in every EU country on the same day, which means that compliance with the IVDR is paramount for market access within the EU.

Major changes in the IVDR 

The IVDR includes changes to IVD classification, increased documentation requirements, and UDI specifications. It is critical for manufacturers and their European representatives to understand and implement the new regulations as soon as possible. There is significant concern that notified bodies will not have sufficient resources to handle the increased need for their services.

The major changes between the IVDR and its predecessor, IVDD, are as follows:

Changes to the classification system

Under the IVDD only a small percentage of IVD products were assigned a higher risk classification (based on a predefined list of products). All other products were exempt from notified body oversight and allowed for manufacturers to self-certify through conformity procedures. Under the IVDD, only 10%-20% of IVD products were subject to notified body oversight, whereas, under the IVDR, 80%-90% of IVD products will be subjected to notified body oversight.

Unlike the IVDD, the IVDR defines 4 risk classes based on risk profile:

  • Class A: Lowest risk (e.g. specimen containers)
  • Class B: Low to moderate risk (e.g. pregnancy tests)
  • Class C: Moderate to high risk (e.g. cancer screening products)
  • Class D: High risk (e.g. HIV tests)

It is important that IVD manufacturers re-classify their products using the new classification rules as soon as possible. Notified body oversight is required for IVDs in class B through class D.

Increased technical documentation requirements

Under the IVDD, technical documentation requirements were vague and left largely to the discretion of the manufacturer. The IVDR, however, details specific requirements for the content of technical documentation. Annex I details the General Safety and Performance Requirements, Annex II details primary technical documentation requirements, and Annex III details requirements for technical documentation for post-market surveillance.

Unique Device Identification (UDI) requirements

IVDs now require UDI labeling and registration in the European Union Database of Medical Devices, more commonly known as EUDAMED, in the same way as other medical devices. A UDI must be assigned to all medical devices, with some exceptions for custom-made and investigational devices.

Each UDI consists of multiple elements, including a Basic UDI-DI (also known as “BUDI”), a device identifier (DI) with static device information, and a product identifier (PI) with dynamic information provided by the manufacturer (such as serial number and manufacturing date). In addition, manufacturers can now register their device in EUDAMED, though this is not yet required.

Quality management system requirements

All IVD manufacturers are expected to have a quality management system in place, even though only those manufacturing class B to D devices require certification of conformity assessments by a notified body.

Person Responsible for Regulatory Compliance (PRRC)

Manufacturers will now be required to designate at least one person to monitor compliance with regulatory requirements. A PRRC must be qualified by way of a relevant degree and a minimum of one year of professional experience, or at least 4 years of experience in medical device regulatory affairs or quality management. Note that smaller manufacturers do have the option to subcontract their PRRC functions, but one person cannot act as a PRRC for a manufacturer based outside of the EU and for an Authorized Representative. 

IVDR deadlines

Manufacturers who were able to self-declare conformity under the IVDD, but require a notified body under IVDR may continue to place IVDs on the market assuming they had issued a declaration of conformity prior to the original May 26, 2022 deadline, introduce no significant changes to the product, meet all post-market surveillance and vigilance requirements, and register in EUDAMED as specified in the IVDR. Assuming that these requirements are met, the new transition dates are as follows:

  • May 26, 2022 - All new devices and non-sterile self-declared devices
  • May 26, 2025 - Class D devices
  • May 26, 2026 - Class C devices
  • May 26, 2027 - Class B devices and Class A sterile devices

IVD regulations outside of the EU

This article is specific to requirements in the EU. It is important to note that other countries, such as the United States, have their own regulations related to In Vitro Diagnostics that are covered by the country’s medical device regulations. Each country with medical device regulations has its own classification scheme that may cause your device to be regulated in a different way. During the initial phase of planning for global commercialization of a product and throughout the product life cycle, it is imperative that you consider international regulations, their classification schemes, and the registrations that each country will require.   

For additional information, The ultimate guide to EU MDR and IVDR general safety and performance requirements and also The Ultimate Guide to EU MDR/IVDR UDI.

MedTech
Blogs

CE marking guide for medical devices in the European Union

By

Bethaney Lentz

July 28, 2022

4 min read

This article is an excerpt from the CE marking guide for medical devices in the European Union.

Table of Contents

What is CE marking?

CE marking is a symbol that consists of “CE, “ which is the abbreviation of the French phrase "Conformité Européene" meaning "European Conformity". The term initially used to describe “CE” was "EC Mark" but it has officially been replaced by "CE marking" according to the EU Directive 93/68/EEC. CE marking is used in all EU official documents, although you will still see "EC Mark" being used in common language. If you are using EC Mark in your documentation, you should change that terminology to CE marking in the future.

The letters ‘CE’ appear on many products traded on the Single Market in all the member states of the European Union plus Iceland, Liechtenstein, Norway and Switzerland. Simply put, The CE mark is a mandatory compliance mark, informing the consumer that the product is compliant with all applicable EU directives and regulations where the CE mark is required.

The Single Market was established in 1993 and is still considered one of the most significant achievements of the European Union. The main goal was to ensure the movement of goods and services freely within all the member states and to establish high safety standards for consumers. The CE mark indicates that goods and services do not need to be verified when shipping into another member country. To further support this movement, in April 2011, the Single Market Act was established to boost growth and strengthen confidence in the economy even further.

Why is CE marking important?

CE marking is required for many types of products, not just medical devices. The CE symbol can be found on bicycle helmets, toys, laptop batteries, wheelchairs, construction equipment, gas appliances and cell phone chargers - to name a few. CE marking is required for products manufactured anywhere that are sold in the EU, and only for those products for which EU specifications exist and require CE marking. The CE marking signifies that the product has been found to meet the general safety and performance requirements (GSPRs) of the European health, safety and environmental protection legislation and allows the product to be sold in the EU. 

CE marking responsibilities

Manufacturer responsibilities for CE marking

Medical device manufacturers are responsible for properly and legally CE marking products before they leave the warehouse.

Most Class II and III medical devices, along with IVDs and some Class I devices, require a conformity assessment performed by a Notified Body to ensure that all legislative requirements are met before it can be placed on the market. Manufacturers of most Class I devices can self assess conformity. This process needs to demonstrate that all the legislative requirements are met, including any testing and inspections, and that all necessary certifications are obtained.

The European Commission lists 6 steps that manufactures should follow to affix a CE marking to their devices:

  1. Identify the applicable directive(s) and harmonized standards - see EU standards for Medical Devices, In Vitro Diagnostic (IVD) devices, and Implantable Medical Devices.
  2. Verify product specific requirements using the essential principles identified in the above standards.
  3. Identify whether an independent conformity assessment by a Notified Body is necessary. Notified bodies will be required to verify compliance with relevant Essential Requirements for most medical devices classified as IIa, IIb, or III - along with sterile class I devices. See the Notified and Designated Organization (NANDO) database for available notified bodies.
  4. Test the product and check its conformity.
  5. Create and keep available the required technical documentation.
  6. Affix the CE marking and create the EU Declaration of Conformity.

Importer responsibilities for CE marking

If you are importing medical devices into the EU, it is your responsibility to review all the technical documentation and maintain a copy, or to make sure that it’s available to you upon request. 

You should verify:

  • That the device has been CE marked and that the EU declaration of conformity has been completed.
  • That the manufacturer has designated and established an authorized representative.
  • That the device is labeled appropriately and contains instructions for use (IFU).
  • When applicable, that a UDI has been assigned to the product.
  • Whether or not the product is registered in EUDAMED (registration is currently voluntary).

Take action:

  • List your name and address on the device or packaging, in addition to the manufacturer’s information.
  • Keep records of complaints, non-conformities, recalls, etc. on file.
  • Report any noticed non-conformity or product complaints from end users to the manufacturer and authorized representative immediately.
  • Maintain a copy of the EU declaration of conformity and any other relevant certificates.

Distributor responsibilities for CE marking

If you are a distributor, you are responsible for reviewing the technical documentation provided to you so that you can verify the product is safe to put on the local market. You must also be sure the product is labeled correctly with the CE marking symbol clearly visible. The technical file documentation contains all of the information that is necessary to show conformity of the product to the applicable requirements.

You should verify:

  • That the device has been CE marked and that the EU declaration of conformity has been completed.
  • That the device includes all the appropriate labeling, including instructions for use.
  • That if imported, the importer has complied with all the EU regulations.
  • When applicable, that a UDI has been assigned to the product.

Take action:

  • Report any noticed non-conformity to the manufacturer, importer, and authorized representative immediately.
  • If a product appears to be out of compliance to the regulations and could pose a serious risk, the information should be reported to the Competent Authority, and  to the manufacturer, importer and authorized representative.
  • Any complaints or reports from end users about the product should be reported to the manufacturer and, if necessary, to the importer and authorized representative.

Important note: If the importer or distributor markets the product under their own company name, then they become responsible for CE marketing, and take over that role from the manufacturer. 

What countries require or accept CE marking?

CE marking is mandatory when importing products into the European Union, which is part of the larger European Economic Area (EEA). The EEA Agreement, established in 1992 and made official in 1994, is an international agreement that enables the extension of the European Union’s single market to non-EU members. It consists of the 27 EU countries plus the four European Free Trade Association (EFTA) countries - Iceland, Liechtenstein, Norway and Switzerland. Today, the EFTA has 29 Free Trade Agreements (FTAs) with 40 countries and territories outside the EU. Because these countries operate in the single market, this allows free movement of goods and services across all of the EEA. 

Source: European Environment Agency (EEA).

Which medical devices require a CE mark?

All medical devices sold in the EU require a CE mark. While a CE mark is not required for items such as chemicals and pharmaceuticals, it can be required for combination devices and medical device software. For these two situations, how do you know if your product requires a CE mark?

To continue reading this ebook, including an overview of CE mark costs, and the associated technical documentation/general safety and performance requirements (GSPRs) that manufacturers are required to maintain please register to download the full version

MedTech
Blogs

Ask us Anything ... about UDI!

By

Wendy Levine

July 27, 2022

4 min read

Your UDI questions answered

Our first “Ask us Anything” webinar last week focused on the topic of Unique Device Identification (UDI). We had so many great questions that we couldn’t answer them all during the session! We have picked the most common questions and put them together here with the answers from our expert panel.

For additional information on this topic, see the following resources:

Q: I’ve heard that the EUDAMED timeline has been pushed back. Is that true?

Yes, that is true. The European Commission recently pushed back EUDAMED deadlines by one year. It is important to note that this does not affect UDI labeling requirements and timeframes, only the mandatory entry of UDI data attributes into  EUDAMED (now Q2 2026). The industry should not relax their efforts in regards to collecting and submitting UDI data. We make every effort to keep our Quick reference guide: global UDI requirements and timelines up-to-date and deadlines and regulations change.

Q: Are we expecting the FDA to be actively enforcing UDI regulations against class I manufacturers after September 2022?

Following this session, the FDA announced that they do not intend to enforce GUDID submission requirements for class I and unclassified devices, other than implantable, life-supporting, or life-sustaining devices.

Q. What governing body controls the correctness of GUDID data?

While the manufacturer is responsible for the accuracy of data they input into GUDID, the FDA is the agency that oversees the requirements.

Q: I have a UDI for a software device (SaMD) that includes features that will be included in a clinical study and features that will be part of the commercialized release version. Do I need to have separate UDIs or can I add the IDE label under a single UDI for the clinical version and keep the UDI for the market released version?

To fully answer this question, we might need a little more information. However, if the device involved in the clinical study is not released (i.e. marketed), then it would not require a UDI. If additional features are introduced during the clinical trial and a new product is released as a result, then a new UDI would be required.

Q: Can you provide insight into machine-to-machine transmission of UDI information?

Currently, the U.S. UDI database, GUDID, has the capability to accept machine-to-machine data transmission. More information can be found on the FDA website here. Most other major markets are working on providing this capability.

Q: How do I make a UDI implementation plan for the QMS process? What things need to be covered?

This is a broad question and there could be many different answers based on your product, QMS, and company structure.  Generally speaking:

  • UDI should be integrated within your Design Controls/Development processes, including the company product release process. You cannot market your device into a country without complying with their UDI requirements.  Some countries require UDI information as part of the device registration process (e.g., EU and China).
  • The company needs to establish accounts with the Issuing Agency (e.g., GS1) and with the country UDI databases (e.g., U.S. FDA GUDID)

Main things to consider: 

  • Labeling: Barcoding software and a process for creating the labeling 
  • Product UDI data attributes: All product related characteristics that are required to be recoded in the country UDI database. The specific characteristics/attributes can be found in the various country UDI guidance documents.
  • Define methods for capturing, storing, controlling, transmitting data attributes (e.g., a RIM system, PLM system or both).
  • Establish processes for maintaining the data including the country requirements (timeframes) for updates to the UDI data and periodic audits (reference country UDI guidance documents).

Q: How do I know what UDI information needs to be supplied to regulators?

The FDA regulations and data dictionary are mature and include information and required data fields to complete successful transmission of data. Data field details include information on whether data is required or conditional on other data, lists of standardized values, and guidance on the data that is expected for each field. EUDAMED has taken a similar approach, and also includes information that is expected  for BUDI. The EUDAMED data dictionary is still in flux. We expect a similar approach from other countries.

Q: When you are implementing UDI and have a kit or system pack, do you need to have a separate UDI for the device, accessories for that device, and a separate UDI for the kit (which would have those components)? 

Generally, the UDI is assigned at the lowest sellable product level. In the case of kits, procedure packs, or systems - each would be given a unique UDI as well.

Q: Is the GUDID barcode and the UDI barcode on the product label the same?

There is no GUDID barcode, but the information on the UDI barcode is contained within the GUDID database. The barcode or human-readable numbers provide high level information about the device. They act as an access key to all of the device attribute data within the GUDID database. The expected barcode on the product is the full UDI including the device identifier (DI) and the production identifier (PI). The GUDID is the FDAs regulatory database where labelers are required to submit information about the UDI DI.

MedTech
Blogs

Oh No! How to recover lost medical device certificates

By

Karen Cohn

July 22, 2022

4 min read

Imagine that you have started working in a new position at a medtech company, and you’re trying to organize your current knowledge of the products, registrations, and information now under your charge. However, something feels off, and you realize that you cannot find all of your company’s current medical device certificates.    

Lost medical device certificates are a more frequent occurrence in our industry. In fact, it’s my experience with the frustration of recovering lost medical device certificates that finds me writing this brief post about what it’s like to lose a medical device certificate and the strategies I’ve used to recover the lost information. We’ll even discuss what you can do to prevent having to live “The Tales of the Lost Document” in the future. 

How do certificates get lost?

The most common factor in misplaced or lost certificates is human error stemming from lax filing systems with disjointed practices and team member departures. Many large medtech companies have a complex structure of emails and document storage sites (such as Sharepoint or Dropbox). These storage sites are often siloed, with different regulatory teams having varying excel spreadsheets, folder structures, and naming conventions to organize their regulatory submission workload. 

In many companies, managing global medical device certificate information is a manual and burdensome process. The problem could be as simple as a file-naming mixup, or it could be a document your company hasn’t needed the certificate in so long that they simply lost track of it. Now let's talk about ways you can recover your lost certificates or information that’s missing from them.

How can you recover lost certificates?

The good news is that you can recover your lost documents in many cases, though it may take a bit of legwork. There are two primary strategies for finding lost medical device certificate information, and utilizing both is the best way to ensure you recover your lost certificates and information. 

The first and often most successful pathway is to search through your internal resources. 

Strategies for Searching through internal resources:

  • Have you found every Sharepoint site used in the past five years?
  • Have you checked previously recorded submissions of that medical device?
  • Have you contacted IT to see if they can recover emails from a departed colleague? They might have sent emails with the certificate attached to them. Many regulatory professionals email a copy of the certificate to announce to the marketing teams they can begin product sales.  
  • Are you working with a distributor? Contact them and request knowledge on all of the current medical device certificates. 

Other channels are available if you can’t find what you’re looking for in your company’s local storage. 

The second strategy is to use governmental medical device registration databases. For example, if you’re registration information for a class 2 medical device, you could look it up in the FDA 510(k) database. Here are some examples of the international regulatory databases that may help in your situation: 

United States - FDA

Canada - Health Canada

European Union

Australia

Belgium

Brazil -  ANVISA

Singapore - Health Sciences Authority

Saudi Arabia - SFDA

If you are looking for a certificate that was approved by a notified body and not in a current database, you can contact the notified body, but you should expect to pay a fee for their services. It’s also important to note that not all countries and regulatory bodies have a database that allows companies to look up their certificates. 

You may also have to accept that you can’t recover your medical device certificate or information. Not every country has a medical device database, and even those with a database often don’t contain the certificate itself. That’s why it’s critical to the efficacy of your RA operations that your team has the tools necessary to store, track, and share regulatory information and documents securely and efficiently. 

How do you make sure this never happens again?

We understand that trying to find missing certificates is an administratively heavy burden. When you can’t find a certificate or its missing information, there’s no way to tell whether it’s lost forever until you’ve exhausted all possibilities and channels, which is why it’s much better to prevent losing documents altogether. 

With the right tools, your RA team can store, locate, and share documents in a secure and largely automated environment. That means no more awkward conversations where you have to tell your boss you can’t find the expiring certificate for your company’s flagship medical device. 

Rimsys is regulatory information management (RIM) software created by RA professionals from the medtech industry with RA professionals in mind. It empowers RA teams to store and track all certificates by product and country and even provides a portal where you can see all of your regulatory documents in a centralized view. Furthermore, you’ll receive emails when a certificate is about to expire, allowing you to act in ample time to prevent lapses in compliance and continue market access per your company’s global device strategy. 

Learn more about how a RIM system can help your organization keep track of all its regulatory information in our “RIM Buyer’s Guide.”


Karen Cohn is a Regulatory Specialist at Rimsys Regulatory Management Software. With a passion for new and emerging regulations, Karen has focused on improvements in international submission processes, regulatory intelligence, MDSAP audit preparedness and managing regulatory compliance projects for the NMPA, HSA, MFDS, ANVISA and other major international regulatory bodies. Prior to joining Rimsys, she was a regulatory specialist at Philips and helped to drive a corporate-wide program to streamline international submission processes to reduce the time to market.

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