Changes
Changes compared to the Medical Device Directive include changes in device classification and device scope, stricter oversight of manufacturers by notified bodies, introduction of the "Person Responsible for Regulatory Compliance" (PRRC) and of the economic operator concept, the requirement ofScope and classification
Compared to the MDD, the scope of the MDR has been expanded to cover not only the active implantable medical devices previously covered by the Active Implantable Medical Device Directive 90/385/EWG (AIMDD) but also a range of ''products without an intended medical purpose''. This category includes devices similar to medical devices, as listed in Annex XVI. The classification rules of Annex VIII of the MDR have been expanded, compared to the MDD, to now 22 rules. Classification changes relate toReusable surgical instruments
''Reusable surgical instruments'' are now included in their own category, often called "I R". As per § 120(3) of the regulation, aspects relating to their re-usability, are under the scope of Notified Body review starting 26 May 2024. This includes aspects relating to reprocessing and (re-)sterilization. This means that, with regard to Notified Body oversight, reusable surgical instruments are now treated similarly to sterile class I products and class I devices with a measuring function.Products without an intended medical purpose
The scope of the MDR includes ''products without an intended medical purpose'', that are similar in principle to medical devices but without a specific medical intended purpose. Annex XVI of the MDR lists the six categories of products that are covered by this scope. The groups includes devices such as cosmetic contact lenses, tattoo removal lasers, equipment for liposuction, and others. Instead of showing a clinical benefit, manufacturers of such products are required to demonstrate their performance and safety in the clinical evaluation.Economic operator roles
The MDR in §2 (35) now defines several different roles for economic operators in relation to medical devices. The obligations of economic operators are detailed in the following sections: * §10 - Manufacturer * §11 - Authorised Representative * §13 - Importer * §14 - Distributor Manufacturers, authorised representatives and importers have to register in the EUDAMED database to receive a Single Registration Number (SRN); only distributors of medical devices do not have to register.Person responsible for regulatory compliance
The MDR in § 15 introduces the role of the "person responsible for regulatory compliance" (PRRC), that manufacturers and authorized representatives will have to have available within their organisation. The PRRC is assigned several duties and responsibilities, including making sure postmarketing surveillance obligations are fulfilled. Persons taking on the role and responsibilities of a PRRC have to meet certain qualitifcations with regard to education and experience. Further details on the PRRC are given in the EU guidance MDCG 2019–7.General safety and performance requirements
The "General Safety and Performance Requirements" (GSPR) of the MDR replace the "Essential Requirements" (ER) of the MDD. Annex I of the MDR lists 23 requirements, divided in three chapters: * General requirements (1–9) * Requirements regarding design and manufacture (10–22) * Requirements regarding the information supplied with the device (23) Compared to the MDD ER, the MDR GSPR have been expanded, e.g. with regards to devices for lay use, IT security, and devices without a medical purpose. Manufacturers are expected to utilize harmonized standards and common requirements to demonstrate conformance to the GSPR.European database on medical devices
The EUropean DAtabase on MEdical Devices (''EUDAMED'') is a database to collect and publish information on medical devices and in-vitro-diagnostica. EUDAMED has six modules: * Actors registration * UDI/Devices registration * Notified Bodies and Certificates * Clinical Investigations and performance studies * Vigilance and post-market surveillance * Market Surveillance Data on economic operators, devices registration and certificates are available to the public. The database will allow to link manufacturer's certification and ''Single Registration Number'' (SRN) as well as the ''Basic UDI''. The so-called "Summary of Safety and Clinical Performance" (SSCP), required for some high-risk medical devices, will also be accessible to the public through the database. More details on the operation of EUDAMED are given in Commission Implementing Regulation (EU) 2021/2078. A similar database is the ''Global Unique Device Identification Database'' (GUDID) of theMedical Device Coordination Group
In accordance with §103 of the MDR, the ''Medical Device Coordination Group'' (MDCG) has been established. The MDCG and its sub-groups publish guidances that provide clarification and support to national competent authorities, notified bodies and economic operators on the details of the implementation of the MDR and IVDR. The members of the MDCG are experts appointed by the EU member states.History
Origins and background
The previous legal framework included the 'New Approach' directive on medical devices (MDD) that had become an accepted industry standard and been updated by Directive 2007/47/EC. In 2010, the French authorities recalled breast implants manufactured by the French company Poly Implant Prothèse in what became known as the PIP scandal. The company had received a CE certificate by Notified Body TÜV Rheinland but used un-certified silicone for the products. This incident created significant public concern over the adequacy of the regulatory framework in ensuring medical device safety. This led to the development of an action plan (the so-called PIP Joint Action Plan) in 2012 by theImplementation date
The regulation was adopted, and came into force, in 2017. The date by which the Regulation was to be fully implemented by replacing the previous directives was originally defined as 26 May 2020. Following the international health emergencyOther changes and amendments
A requirement for manufacturers on notifying authorities digitally about (potential) medical device supply chain disruptions was added to the regulation in 2024 (§10a). In October 2024, theSee also
*References
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