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78 docs tagged with "mdr"

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Advertising rules & permitted/prohibited claims

Regulatory basis - MDR Art. 7 (claims); MDR Art. 2(24) (intended purpose shaped by advertising); IVDR Art. 7 (IVDR claims). Advertising and promotional materials are part of the "information supplied by the manufacturer" and shape the legal intended purpose of the device.

Annex IX — QMS + Technical Documentation Assessment

MDR 2017/745, Annex IX and IVDR 2017/746, Annex IX. Annex IX is the most widely used conformity assessment route for Class IIa, IIb, III (MDR) and Class B, C, D (IVDR). It is the only permitted route for Class III (MDR) and Class D (IVDR).

Annex X — EU type examination

MDR 2017/745, Annex X and IVDR 2017/746, Annex X. Annex X defines the EU type examination procedure. It is used in combination with Annex XI (Part A or B) and is available for Class IIa, IIb (MDR) and Class B, C (IVDR). Not available for Class III (MDR) or Class D (IVDR), which must use Annex IX.

Annual reports & PSUR

Regulatory basis - MDR Art. 85 / IVDR Art. 80. The PSUR is required for higher-risk device classes and must be submitted to the notified body via EUDAMED. MDCG 2022-21 provides detailed guidance on PSUR content and format.

Borderline & combination products

Borderline product guidance is primarily in MDCG 2022-5. Drug-device combinations are addressed in MDR Art. 1(8)–(9), MDR Annex I §12.2, and relevant EMA guidance. ATMP combination products are governed by Regulation (EC) No 1394/2007.

Chapter I — General requirements

MDR 2017/745, Annex I, Chapter I (GSPR 1–5) and equivalent provisions in IVDR 2017/746, Annex I, Chapter I. These requirements are foundational — they apply to every device regardless of type or class.

Chapter II — Design & construction

MDR 2017/745, Annex I, Chapter II (GSPR 6–22) and equivalent provisions in IVDR 2017/746, Annex I, Chapter II. These are specific technical requirements for how devices must be designed and manufactured.

Chapter III — IFU & labelling

MDR 2017/745, Annex I, Chapter III, Section 23 and IVDR 2017/746, Annex I, Chapter III, Section 20. These are the labelling and IFU requirements as part of the GSPR. Post-market labelling obligations are covered separately in Labelling & advertising.

Class I · IIa · IIb · III — MDR classes

MDR 2017/745, Article 51 and Annex VIII. MDR uses a four-class system with Class I subdivided into sub-classes based on sterility, measuring function, and reusable surgical instrument status.

Class I self-declaration pathway

MDR Art. 52(7) and Annex IV. Class I devices (standard) do not require notified body involvement. The manufacturer self-declares conformity by signing an EU Declaration of Conformity after completing all required steps.

Classification rules 1–22

MDR 2017/745, Annex VIII. All 22 classification rules must be applied systematically. Where more than one rule applies, the highest resulting class prevails.

Clinical evaluation (Art. 61 + Annex XIV)

MDR Art. 61 and Annex XIV. Clinical evaluation is mandatory for all MDR devices regardless of class. It is a continuous, lifecycle process — not a one-time pre-market exercise.

Clinical Evaluation Report (CER)

MDR Annex XIV Part A, Section 4. The CER is the written output of the clinical evaluation process. It must be reviewed and updated throughout the device lifecycle and is a mandatory technical documentation element.

Clinical investigations (Annex XV)

MDR Art. 62–82 and Annex XV. Clinical investigations — structured studies in human subjects — are the gold standard for clinical evidence. They are mandatory for certain device classes and may be required when existing evidence is insufficient.

Compassionate use & special access — overview

Regulatory basis - MDR Art. 59 (compassionate use); MDR Art. 53 (humanitarian device exemptions via custom-made pathway); MDR Art. 62(4)(f) (compassionate use within clinical investigations); member state national provisions for named-patient / hospital exemption access.

Competent authority-initiated actions

Regulatory basis - MDR Art. 93–97 / IVDR Art. 88–92. National competent authorities have broad powers to investigate, restrict, and remove medical devices from the EU market. The European Commission can intervene at EU level where national actions are insufficient.

Conformity assessment — overview & route selection

MDR conformity assessment procedures are set out in MDR Art. 52 and Annexes IX–XI. IVDR equivalents are in IVDR Art. 48 and Annexes IX–XI. The EU Declaration of Conformity is required under MDR Art. 19 / IVDR Art. 17 and MDR Annex IV / IVDR Annex IV.

Custom-made devices

MDR Art. 2(3) (definition); MDR Art. 52(8) (conformity assessment); MDR Annex XIII (documentation requirements for custom-made devices). Custom-made devices are subject to a specific, lighter-touch regulatory pathway but must still meet all applicable GSPR.

Design & manufacturing information

MDR Annex II, Section 3 and IVDR Annex II, Section 3. This section of the technical documentation covers how the device was designed and how it is manufactured — the information necessary to ensure reproducibility and traceability.

Device description & specification

MDR Annex II, Section 1 and IVDR Annex II, Section 1. The device description and specification is the foundational section of technical documentation — it defines what the device is, what it does, and for whom.

Device registration & UDI upload

Regulatory basis - MDR Art. 28–29 / IVDR Art. 25–26. Manufacturers must register all devices placed on the EU market in EUDAMED, linked to the Basic UDI-DI. Registration is a prerequisite for placing the device on the market within the applicable class timelines.

Devices incorporating a medicinal substance

MDR Annex VIII Rule 14 (classification); MDR Art. 1(8)–(9) (drug-device combination products); MDR Annex I §8 (GSPR). Integral drug-device combinations where the device action is principal are Class III under MDR and require EMA or NCA consultation.

Devices with human/animal tissues (Annex I §13)

MDR Annex VIII Rules 17–18 (classification); MDR Annex I §13 (GSPR); EN ISO 22442 series (animal tissue requirements); European Pharmacopoeia Chapter 5.2.8 (TSE risk minimisation). Devices made from non-viable human tissue are Class III; non-viable animal tissue devices are also Class III (with some Class IIb exceptions).

Distribution records

Regulatory basis - MDR Art. 10(8) / IVDR Art. 10(8) — manufacturers must maintain records that allow identification of all customers who received a device, enabling effective recalls and FSCAs. Importers and distributors have parallel obligations under MDR Art. 13(5) and Art. 14(5).

Distributors

Distributor obligations are defined in MDR Article 14 and IVDR Article 14. Definitions appear in MDR Article 2(34) and IVDR Article 2(31).

Economic operator registration (SRN)

Regulatory basis - MDR Art. 30 / IVDR Art. 27. All manufacturers, EU authorised representatives, importers, and (in some cases) distributors must register as economic operators in EUDAMED and receive a Single Registration Number (SRN).

Equivalence claims

MDR Art. 61(4)–(5) and Annex XIV §3. Equivalence is a tool for leveraging existing clinical data from a comparable device in lieu of a new clinical investigation. Its use is significantly more restricted under MDR than under the previous MDD.

EUDAMED registration — overview

Regulatory basis - MDR Art. 28–33 / IVDR Art. 25–30. EUDAMED is the European database on medical devices — the central information infrastructure underpinning MDR and IVDR. Manufacturers, EU REPs, importers, and distributors must all register as economic operators.

EUDAMED UDI registration

Regulatory basis - MDR Art. 27(3)–(4) and Art. 28–29 / IVDR Art. 24(3)–(4) and Art. 25–26. Manufacturers must register their devices in EUDAMED using the UDI as the primary identifier before placing devices on the EU market.

EUDAMED vigilance module

Regulatory basis - MDR Art. 92 and Art. 100–105 / IVDR Art. 87 and Art. 97–102. EUDAMED is the central EU information system for medical devices, including the vigilance module for reporting serious incidents and FSCAs.

Field safety notices (FSNs)

Regulatory basis - MDR Art. 89(3) / IVDR Art. 84(3). A field safety notice (FSN) is the communication issued by a manufacturer to inform customers, distributors, and users of an FSCA and what action they need to take. MDCG 2023-3 provides a template.

Glossary of key terms

MDR (Regulation (EU) 2017/745) and IVDR (Regulation (EU) 2017/746) — terms are drawn from official definitions in Article 2 of each regulation unless otherwise noted.

GSPR checklist & compliance

Both MDR 2017/745 and IVDR 2017/746. The GSPR checklist (cross-reference table) is a mandatory component of the technical documentation under Annex II of both regulations.

GSPR cross-reference

MDR Annex II, Section 4 and IVDR Annex II, Section 4. The GSPR cross-reference table is a mandatory component of technical documentation linking each applicable general safety and performance requirement to the evidence of conformity.

How classification works

MDR classification rules are in Annex VIII of MDR 2017/745. IVDR classification rules are in Annex VIII of IVDR 2017/746. Classification determines the conformity assessment route, notified body involvement, and post-market obligations.

How to report — national competent authorities

Regulatory basis - MDR Art. 87 / IVDR Art. 82 require reports to be submitted to the NCA of the member state(s) where the incident occurred. EUDAMED is the primary reporting platform; some NCAs also accept or require national-format reports.

Implantable devices & implant card

MDR Art. 2(5) (definition); MDR Annex VIII Rule 8 (classification); MDR Art. 18 and Annex XV §2.12 (implant card); MDR Annex I §22–23 (GSPR for implantables). Active implantable devices are governed by the same regulation (AIMDs are now Class III under MDR).

Implementing acts, delegated acts & harmonised standards

The legislative framework beneath MDR and IVDR comprises implementing acts (Commission), delegated acts (Commission), Common Specifications (Commission via implementing act), and harmonised European standards (CEN/CENELEC under Commission mandate).

Importers

Importer obligations are defined in MDR Article 13 and IVDR Article 13. Definitions appear in MDR Article 2(33) and IVDR Article 2(30).

Labelling requirements

Regulatory basis - MDR Annex I §23 / IVDR Annex I §20 (GSPR labelling requirements); MDR Art. 10(11) (labelling obligations on manufacturers). Language requirements vary by member state. Post-market labelling obligations extend to maintaining current labelling as the device and evidence evolve.

Legacy & grandfathered devices

MDR Art. 120 (transitional provisions for MDD/AIMDD devices); IVDR Art. 110 (transitional provisions for IVDD devices); Regulation (EU) 2023/607 (amended MDR transitional dates); Regulation (EU) 2024/1860 (amended IVDR transitional dates).

Manufacturers

MDR Article 10 and IVDR Article 10 set out the general obligations of manufacturers. Definitions appear in MDR Article 2(30) and IVDR Article 2(27).

Market surveillance & enforcement — overview

Regulatory basis - MDR Art. 93–97 / IVDR Art. 88–92. Market surveillance is the system of NCA activities that ensures devices on the EU market comply with MDR/IVDR requirements. It is distinct from — but complementary to — the manufacturer's own post-market surveillance system.

MDR Annexes — all 17

Annexes I–XVII of Regulation (EU) 2017/745 (MDR). The annexes contain the detailed technical, procedural, and administrative requirements that implement the principles set out in the articles.

MDR vs IVDR — which applies?

Regulatory basis - MDR = Regulation (EU) 2017/745 | IVDR = Regulation (EU) 2017/746. Both regulations are mutually exclusive — a product is governed by one or the other, never both simultaneously.

Non-EU & third-country access

Both MDR 2017/745 and IVDR 2017/746. This section covers requirements for non-EU manufacturers placing devices on the EU market, EU REP obligations, and how EU MDR/IVDR relates to non-EU regulatory systems.

Overview — Annex I (GSPR)

Both MDR 2017/745 and IVDR 2017/746. Each regulation contains its own Annex I (GSPR), with mostly parallel structure and some IVDR-specific elements.

Overview & ongoing obligations

Both MDR 2017/745 and IVDR 2017/746. Post-market obligations begin the moment a device is placed on the market and continue until the device is withdrawn from service.

PMS requirements by class

Regulatory basis - MDR Art. 83–86 / IVDR Art. 78–81. PMS is a proactive, systematic process that all manufacturers must implement. The depth and reporting frequency scale with device risk class.

Post-market data in technical documentation

MDR Annex III and IVDR Annex III define the post-market technical documentation requirements. Key documents are the PMS plan, PMS report / PSUR, and PMCF plan and evaluation report (MDR) or PMPF plan and evaluation report (IVDR).

Recalls — classification & coordination

Regulatory basis - MDR Art. 89 and Art. 95 / IVDR Art. 84 and Art. 90. EU medical device recalls are a subset of FSCAs. Unlike some other regulatory systems, the EU does not have a single standardised recall classification system — instead, the risk assessment under ISO 14971 and NCA discretion determine the urgency and scope.

Recent amendments & corrigenda

MDR 2017/745 and IVDR 2017/746 and their amending regulations. This page tracks significant amendments; always verify current status in the Official Journal.

Reclassification & SCENIHR opinions

MDR Art. 51(2) and IVDR Art. 47(2) empower the European Commission to reclassify devices or device categories by implementing act. Scientific opinions informing reclassification were historically provided by SCENIHR (now replaced by SAG-MD and the MDCG).

Regulation (EU) 2017/745 — MDR key articles

The full text of MDR 2017/745 is available in the Official Journal of the EU: OJ L 117, 5.5.2017, p. 1–175. All article references on this site refer to the MDR as amended, including amendments made by Regulation (EU) 2020/561 and Regulation (EU) 2023/607.

Reporting timeframes

Regulatory basis - MDR Art. 87(5)–(8) / IVDR Art. 82(5)–(8). Timeframes run from the date the manufacturer becomes aware of the incident. EUDAMED is the reporting platform for EU vigilance reports.

Risk management (ISO 14971)

Risk management is required by GSPR §1 and §2 of MDR Annex I and IVDR Annex I. The harmonised standard EN ISO 14971:2019 provides the implementation framework and creates a presumption of conformity with the relevant GSPR when applied.

Serious incidents & near-misses

Regulatory basis - MDR Art. 2(65) and Art. 87 / IVDR Art. 2(67) and Art. 82. The definitions of serious incident and near-miss determine the scope of mandatory vigilance reporting.

Single-use devices & reprocessing rules

MDR Art. 2(8) (single-use definition); MDR Art. 17 (reprocessing of single-use devices); MDR Annex I §23.4(h) (IFU requirements for single-use designation). Reprocessing of single-use devices is regulated — not prohibited — but the reprocessor takes on full manufacturer obligations.

Software & SaMD classification

MDR software classification is governed by Annex VIII, Rule 11 of MDR 2017/745. IVDR software follows the same class assignment rules as other IVDs under IVDR Annex VIII. MDCG 2021-24 provides authoritative guidance on MDR Rule 11 application.

Software as a Medical Device (SaMD)

MDR Art. 2(1) (software included in definition); MDR Annex VIII Rule 11 (classification); MDR Annex I §17 and §21 (GSPR for software). MDCG 2019-11 and MDCG 2021-24 provide detailed guidance. For IVD software: IVDR Annex VIII Rules 1–7.

Systems & procedure packs

MDR Art. 22 governs systems and procedure packs — combinations of products that are assembled together for a specific medical purpose. The person assembling a system or procedure pack takes on specific regulatory obligations.

Technical documentation — overview

MDR 2017/745, Annex II (technical documentation) and Annex III (technical documentation on post-market surveillance). Equivalent provisions in IVDR 2017/746, Annex II and III. Technical documentation must be compiled before CE marking and maintained throughout the device lifecycle.

UDI labelling requirements

Regulatory basis - MDR Art. 27(4)–(6) / IVDR Art. 24(4)–(6) and MDR Annex VI Part C / IVDR Annex VI Part C. These provisions specify where and how the UDI carrier must appear on device labelling.

UDI overview & structure

Both MDR 2017/745 and IVDR 2017/746. UDI requirements are set out primarily in MDR Art. 27 / IVDR Art. 24 and MDR Annex VI / IVDR Annex VI.

UDI-DI & UDI-PI explained

Regulatory basis - MDR Annex VI Part B and C and IVDR Annex VI Part B and C. The UDI consists of a Device Identifier (UDI-DI) and a Production Identifier (UDI-PI). Understanding the distinction is fundamental to UDI system compliance.

Using international clinical data

Both MDR 2017/745 and IVDR 2017/746. International clinical data — generated outside the EU — can be used in clinical evaluations and performance evaluations, subject to certain conditions.

What is a medical device?

Regulatory basis - This page is based on Article 2(1) of Regulation (EU) 2017/745 (MDR). The definition is central to determining whether your product requires MDR compliance.

What is not a medical device?

Regulatory basis - Exclusions from the MDR are set out primarily in Article 1(5) and 1(6) of Regulation (EU) 2017/745. Equivalent IVDR exclusions appear in Article 1(4) and 1(5) of Regulation (EU) 2017/746.

What must be reported

Regulatory basis - MDR Art. 87 and IVDR Art. 82 define the reporting obligations for serious incidents and field safety corrective actions. Manufacturers must report to the National Competent Authority of the member state(s) where the incident occurred or the FSCA is being taken.

When an FSCA is required

Regulatory basis - MDR Art. 2(68) and Art. 89 / IVDR Art. 2(70) and Art. 84. An FSCA is any corrective action taken by a manufacturer to reduce a risk of death or serious deterioration in health associated with a device already placed on the market. FSCAs must be notified to NCAs.