Local Clinical Testing in Russia
When local testing is required
Local clinical testing in Russia is required when:
- The device is innovative — no registered equivalent exists in the GRLS
- The FGBU determines during Phase 1 review that existing clinical data is insufficient
- Roszdravnadzor has specific concerns about data quality or applicability to the Russian patient population
For Class IIb and Class III devices, local clinical testing is frequently required. For Class I and IIa devices with substantial existing clinical documentation, it may be waived.
The National Ethics Committee
Before any clinical investigation can begin in Russia, the investigation protocol must be approved by the National Ethics Committee under the Ministry of Health. This is a standalone approval step separate from the Roszdravnadzor registration process.
Key steps:
- Prepare clinical investigation protocol
- Submit to National Ethics Committee for review
- Obtain Ethics Committee approval
- Roszdravnadzor lifts the Phase 1 hold on the registration application
- Investigation conducted in approved Russian clinical centres
- Clinical data compiled and submitted to Roszdravnadzor (Phase 2)
Approved clinical centres
Clinical investigations must be conducted in clinical facilities approved by the Ministry of Health for this purpose. The manufacturer or RUS REP identifies and contracts appropriate clinical centres.
Laboratory testing
In addition to clinical investigations, laboratory and pre-clinical tests may also need to be conducted in Russian accredited laboratories. The FGBU National Institute of Quality may specify which tests must be performed locally.
Timeline impact
Local clinical testing typically adds 6–18 months to the overall registration timeline, depending on:
- Complexity of the investigation protocol
- Time to obtain Ethics Committee approval
- Patient enrolment speed at clinical centres
- Data analysis and reporting time
Pre-clinical and clinical testing regulations (March 2022): minzdrav.gov.ru