NEW MDR Regulatory Context
NEW MDR Regulatory Context MODERNIZED
NEW MDR Regulatory Context MORE ROBUST
NEW MDR BETTER PROTECTION Regulatory Context of public health and patient safety
1 TWO NEW 2017/745 3 YEARS Regulations Regulation (EU) 2017/745 of the European Parliament and the European Council of 5 April 2017 on MDs, amending Directive 2001/83/EC, Regulation (EC) No 178/2002, and Regulation (EC) No 1223/2009 and repealing European Council Directives 90/385/EEC and 93/42/EEC 3 YEARS Applies only after transitional period of
2 TWO NEW 2017/746 5 YEARS Regulations Regulation (EU) 2017/746 of the European Parliament and the European Council of 5 April 2017 on in vitro diagnostic medical devices (IVMDs) repealing Directive 98/79/EC and Commission Decision 2010/227/EU 5 YEARS Applies only after transitional period of
CONTEXT 1992 MDR Regulatory AIMD Directive (90/385/EEC) and ‘92 1992 Introduction of AIMD Directive (90/385/EEC) and MD Directive (93/42/EEC)
CONTEXT 2007 MDR Regulatory ‘ 2007 ‘92 Directive 2007/47/EC modified the Medical Devices Directive (MDD) and the active implantable medical device (AIMD) in an attempt to address the weaknesses and concerns of previous directives
CONTEXT 2010 MDR Regulatory ‘92 ‘07 2010 Scandal involving defective breast implants manufactured by Poly Implant Prothèse in France, which surfaced in 2010 and which demonstrated additional structural weaknesses in the system
CONTEXT 2012 MDR Regulatory ‘92 ‘07 ‘10 2012 September: European Commission published proposals for MDR 2017/745 and In Vitro Diagnostic Regulation (IVDR) (EU) 2017/746. Discussion between the European Commission, the European Parliament, and the European Council compromises text in June 2016 and translation into all European Union languages by September-October 2016
CONTEXT 2017 MDR Regulatory ‘92 ‘07 ‘10 ‘12 2017 New medical device regulations (MDRs) (2017/745) were formally published in the Official Journal of the European Union in May 2017, heralding the official transitional period
CONTEXT 2020 MDR Regulatory Full implementation of ‘92 ‘07 ‘10 ‘12 ‘17 2020 Full implementation of MDR 2017/745 in May 2020
CONTEXT High risk devices New MDR Regulatory Stricter ex ante control of High risk devices
CONTEXT Designation & processes New MDR Regulatory Reinforcement of the criteria covering Designation & processes for oversight by notified bodies
New MDR Regulatory CONTEXT Inclusion of certain Aesthetic devices
CONTEXT Classification SYSTEM New MDR Regulatory Introduction of a new risk Classification SYSTEM
New MDR Regulatory CONTEXT Improved transparency
New MDR Regulatory CONTEXT Introduction of an Implant card
CONTEXT Clinical evidence New MDR Regulatory Reinforcement of the rules on Clinical evidence
CONTEXT Surveillance Requirements New MDR Regulatory Strengthening of postmarketing Surveillance Requirements
New MDR Regulatory CONTEXT Improved Coordination mechanisms
New MDR Regulatory CONTEXT More Information available
Important modifications Stricter premarket control Inclusion of aesthetic products Data on real-life use of devices Oversight by notified bodies Implant card European Union database Rules on clinical data 7 Important modifications
Face more liability IMPACT of new regulations on manufacturers
data of higher quality IMPACT Acquire more clinical of new regulations on manufacturers
improve data management IMPACT Have to improve data management IMPACT of new regulations on manufacturers
IMPACT the full product life cycle Monitor quality and safety throughout the full product life cycle IMPACT of new regulations on manufacturers
Prepare supply chains for unannounced audits COMPLIANCE Addressing MDR
Distribution will have a role in vigilance and postmarketing surveillance Addressing MDR COMPLIANCE
Manufacturers should thoroughly assess entire device portfolios Addressing MDR COMPLIANCE
COMPLIANCE Addressing MDR Supports portfolio assessment and CE dossier preparation to ensure compliance with the MDR. Addressing MDR COMPLIANCE
COMPLIANCE EUDAMED planned go-live in 2019. Addressing MDR Obliged to report under the MDR should the EUDAMED not go live before the date of application in May 2020. Addressing MDR COMPLIANCE
COMPLIANCE STRATEGIES that plan for TRANSITION Addressing MDR Strongly recommended: Addressing MDR COMPLIANCE
COMPLIANCE Addressing MDR Expiration dates of their CE Marking certificates Notified bodies’ policies Availability of clinical data Expiration dates of devices Helps manufacturers BUILD STRATEGIES BASED ON: Addressing MDR COMPLIANCE
TIMELINE Complex MDR 05 May 2017 25 May 2017 25 Nov 2017 26 Nov 2017 Publication of new MDR-IVDR 25 May 2017 New MDR-IVDR comes into effect 25 Nov 2017 Early applicability of regulation concerning notified bodies: notified bodies may apply for MDR designation 26 Nov 2017 to 26 May 2020 Notified bodies may issue certificates under the MDD or the AIMDD, with a maximum validity of five years 25 May 2018 Cooperation of competent authorities and the commission
TIMELINE Complex MDR 25 May 2019 25 May 2020 27 May 2022 26 May 2024 Notified bodies for UDIs Certificates issued in accordance with AIMDD (Annex 4) and MDD (Annex IV); EC-type verifications that have not yet expired will become void 25 May 2020 Full applicability of regulation; other regulations are nullified 27 May 2022 MDD certificates expire (Annex IV) 26 May 2024 Other certificates issued under current directives that have not yet expired will become void 26 May 2025 Devices CE Marked under the MDD or AIMDD may no longer be marketed or put into service in Europe
EUDAMED MDR timeline also dependent on functionality of 25 May 2020 25 Regulation related to EUDAMED and the UDI database 25 Nov 2020 Registration obligation in EUDAMED (registration of product, test certificates) (18 months later) 25 May 2021 to 25 May 2025 UDI labelling obligation (timeline depending on risk class) 25 May 2023 to 25 May 2025 UDI direct marketing in reusable products
GREAT OPPORTUNITY AHEAD New MDR requires more action from industry = additional burden for companies = efficient regulatory & quality services across the MD life cycle GREAT OPPORTUNITY AHEAD
specialises in helping international life sciences organisations more effectively get their products and therapies to market by providing those clients with functional support across all of the regulated stages of the product life cycle—from development to launch, to postmarketing.