GLOBAL RA

ICMC (International Certification Management Center Co., Ltd.)

CE MDR

Medical Devices CE MDR

Europe Medical Devices Product Certification (CE MDR (Medical Devices Regulation (EU) 2017/745)

Europe Medical Devices Regulation



CE MDR Certification

Since 1999, all medical devices exported to Europe must be equipped with CE Mark, and the acquisition of CE Mark by domestic medical device manufacturers is a prerequisite for European exports, and the ICMC (International Certification Management Center Co., Ltd.) has provided many CE MDD/MDR technology advice to domestic medical device manufacturers.
CE MDD/MDR must meet the EU requirements for the product through product safety and reliability tests, and it takes longer than CE Mark for general products because certification review of the quality management system through production system verification (ISO13485:2016 certification) is a necessary condition. In order to acquire CE Mark, the quality system stipulated in ISO13485 standard is established and operated. The existing Directive 93/42/EEC for Medical Devices (MDD) Medical Device Guidelines have been fully enforced under the Medical Devices Regulation (EU) 2017/745) Medical Device Act since May 26, 2021.



Major Changes in CE MDR

  • Integrate Direct 93/42/EEC for Medical Device (MDD) and AIMDD (Direct 90/385/EEC for Active Implantable Medical Device)
  • Expanding the scope of application: Non-medical products (Annex XVI)
  • Reinforcement of standards for designation and supervision of a Notified Body
  • Disclosure of safety and clinical performance through the EUDAMED database, etc.
  • Reinforcement of post-market surveillance requirements for manufacturers
  • Enhanced traceability of medical devices (UDI and EUDAMED)
  • Reinforcement of clinical evaluation requirements
  • Update on the rating system update
  • Establishment of an MDCG agency that manages Notified Bodies (NB) and generates guidance documents as an independent EU agency


CE MDD / MDR Regulatory Comparison

Category CE MDD CE MDR
provisions of the law
23 Article
10 Chapter
123 Article
annex
12 Annex
17 Annex
form of law
Directive
Regulation


Application of UDI Introduction by Class

CE MDR Class III
Implantable Devices
Class Ⅱ a
Class Ⅱ b
Class I
Apply to label
From May 26th, 2021
From May 26th, 2023
From May 26th, 2025
Apply directly to
reusable devices
From May 26th, 2023
From May 26th, 2025
From May 26th, 2027


Considerations for obtaining CE MDR

  • Check that your product falls within the scope of medical devices as defined by the European Medical Device Act (EU), MDR 2017/745).
  • You must check whether your product belongs to in medical device classes (Class I, Class Im, Class Is, Class Ir, Class IIa, Class lb, Class III) defined in Annex VIII of European Medical Device Act (EU), MDR 2017/745).
  • Your product must follow the Conformity Assessment Procedure of Article 52 of the European Medical Device Act (EU), MDR 2017/745) applicable.



Effect of CE MDR Certification

CE MDR (Medical Device Regulation (EU) 2017/745) Medical Device Act consists of a total of 10 Chapters, 123 Articles and 17 Annexes. Definition, classification, certification procedures for medical devices, general safety and performance requirements (GSPR) for medical devices, regulatory requirements for shipment to the market, and matters to be reported to European authorities are published.
Therefore, CE Mark is essential to distribute medical devices in Europe. According to the risk of medical devices, in the case of Class Ⅰ, a Technical Documentation (TD) must be prepared and reported to the Food and Drug Administration of European countries. In the case of Class Ⅱ and Ⅲ, CE Mark can be affixed after being evaluated by a Notified Body designated by the European Ministry of Health and Welfare.
CE MDR includes documents, reports, and systems that must be submitted, reported, registered, or reviewed with European Competent Authority or Notified Body, in addition to regulations to be followed by in vitro diagnostic medical device manufacturers, Authorized Representative, importers, and distributors. If a medical accident occurs due to shipment of a product within Europe, a strict vigilance system is required from the initial report to the final report. Therefore, the following effects can be expected by obtaining CE Mark for companies related to medical devices.


1
Provide consumers with safe products by meeting general safety performance requirements (GSPR)
2
No restrictions on export to EU member states (EU requirements – CE Mark mandatory for all products within EU member states)
3
By attaching the CE Mark to products, export attempts to countries other than the EU and export competitiveness are strengthened
4
Eliminate the risk of litigation through product safety
5
Improving company, product and brand image and credibility



Conformity assessment procedure for Class I

1
Check the applicable EN, ISO, IEC standards of the product
2
Establishment of quality system (ISO 13485, Post Market Surveillance (PMS) and reporting system (Vigilance))
3
Reflect the standard in the design
4
Product risk analysis (EN ISO14971)
5
Testing and Verification
6
Preparation of technical documentation (TD)
7
EU Declaration Of Conformity
8
CE Marking
9
European representative selection and contract
10
Report to Europe
11
Registration number
12
EUDAMED registration


EC DOC(EU Declaration of conformity)

Class I products are regulated by Article 19 and Annex IV to comply with their own certification procedures, so after completion of the technical document, the name, address, classification rules, product name, corresponding certification authority, date, and representative's signature, and CE mark can be attached.
At this time, you must designate a Authorized Representative with an address in Europe and report it to the European Food and Drug Administration.



Conformity assessment procedure for Class IIa and Class IIb

For medical devices of Class Im, Class Is, Class Ir, and Class II or higher, quality system certification procedures are added to the procedures corresponding to the first-class procedures.
Although there are no regulations on these specifications in CE MDR, most certification agencies require DMFs for certification of these specifications, so you must prepare for them and apply for examination.



COC(Certificate of conformity)

In case of Class Im, Class Is, Class Ir and Class II or higher, the system certificate and CE mark certificate are issued by the relevant Notified Body after the evaluation by the Notified Body.




Write Technical Documentation (TD)

Just as a “technical document” must be prepared in accordance with the Medical Device Act to manufacture medical devices in Korea, “technical documentation” must be prepared to attach the CE mark to medical devices. Therefore, the manufacturer must prepare a technical documentation (TD) according to Annex II. In addition, the manufacturer and the Authorized Representative must retain the technical documentation for at least 10 years regardless of the expiration date after the medical device(at least 15 years for implantable devices) to which the EU Declaration of Conformity has been applied is placed on the market, and must be able to submit it to the competent European authorities. The content regulations to be included in the technical documentation are as follows.


1
General requirements
State that the contents are technical confidential information of the company, document management status, preparation/approval and date, revisions, table of contents, company introduction and related standards

2
Product Description
Product overview/name/model name/classification/grade/purpose of use/user/UDI information/action principle/comparative data of equivalent items, etc.

3
General Safety Performance Requirements
Documents and reports in accordance with the requirements of GSPR (General Safety and Performance Requirements) (Risk Management (EN ISO14971), Labels and Markings (EN 1041, EN ISO 15223-1), Electrical Common (EN 60601-1, EN 60601-1-2), Software Validation (EN IEC 62304), Sterilization Common (EN 556) Biocompatibility (EN ISO10993) , usability(EN IEC 62366) etc.)

4
Raw Material List
Raw material name, grade, format, specifications (ISO, EN, IEC, KS) Chemicals (MSDS, Technical Data), Electronic Components (Spec approval status-CE, UL), Test repor

5
Manufacturing/QC process chart
Flowchart preparation, related document number and storage location

6
Test report
Data that the applicable standards are met, and that the requirements are met when used in combination with other devices

7
Validation result
Sterilization, software validation

8
Risk analysis
Risk analysis report according to EN ISO 14971

9
Clinical data
Consists of safety and efficacy documents (thesis, academic journals, etc.) according to MEDDEV 2.7.1, MDR Annex XVI, XV, comparison with similar products, sales and customer complaint records, etc.

10
Labels and Packaging
Prepared in consideration of EN 1041, EN ISO 15223-1, applicable product standards, and Annex V, and also describe the dimensions and material of the packaging box

11
Declaration of Conformity
EC Declaration of Conformity according to Annex IV



CE MDR Medical Device Classification System

Classification system : Class I, (Class Im, Class Is, Class Ir), Class IIa, Class llb, Class III
* Im (Measurement), Is (Sterile), Ir (Reuse)
Based on the potential risk, it is divided into four classes.

  • ClassⅠ
  • ClassⅡ a
  • ClassⅡ b
  • ClassⅢ
CE MDR

Classification of medical devices : Classification based on 22 rules according to Annex VIII


  • Non – Invasive device : Rule 1~4
  • Invasive Device : Rule 5~8
  • Active Device : Rule 9~13
  • Special Rule : Rule 14~22

Criteria and terms for classifying medical devices
Duration
Transient (within 60 minutes), Short Term (within 30 days), Long Term (within 30 days)
Invasivenes Invasive Device, Body Orifice, Surgically Invasive, Implantable Device
Reuse Reusable Surgical Instrument
Area to use Central Circulatory System, Central Nervous System
Active or not Active Medical Device, Active Therapeutical Device



CE MDR Explanation of terms

1
EUDAMED
In CE MDR, the European database is introduced to ensure traceability of in medical devices and to facilitate the flow of information between medical device manufacturers and users, as well as certification bodies, the European Union and the European Commission. EUDAMED's management scope includes not only a unique number called UDI (Unique Device Identification) for product registration, but also device registration, certification bodies and certificates, clinical trials, economic operator registration, Vigilance, PMS, and Market Surveillance.

2
GSPR (General Safety and Performance Requirements)
For general safety performance requirements, the Essential Requirement Checklist of Annex I of CE MDD has been updated to GSPR according to Annex I of CE MDR.

3
PRRC (Person Responsible for Regulatory Compliance)
The person responsible for regulatory compliance is a person responsible for compliance with the required expertise in the field of in vitro diagnostic medical devices for each manufacturer, and must have at least one person in the organization. That is, in common with the manufacturer and the European representative, they must have quality, RA experience or related qualifications.

4
Economic Operator
Economic operator is a new concept introduced in MDR and refers to manufacturers (legal manufacturers), Authorized Representative, importers, and distributors.

5
UDI (Unique Device identification)
It is a medical device unique identification code that provides a consistent and standard way for medical service providers and patients to identify devices during distribution and use, and consists of three main areas.
Basic UDI – DI Basic UDI-DI (Device Identifier) is the primary identifier of the device model, and is DI assigned to the device usage unit level. It is the primary key of UDI database records and is referenced in relevant certificates and EU declarations of conformity.
UDI-DI (Device Identifier) is a unique numeric or alphanumeric code specific to the device model and is also used as an ‘access key’ for information stored in the UDI database.
UDP-PI (Production Identifier) is a numeric or alphanumeric code that identifies a device production unit. This includes serial number, lot number, software identification and date of manufacture or expiration.

6
NB (Notified Body)
As a body conducting conformity assessment made in accordance with CE MDR, it is a third-party body that has obtained approval from the governments of EU member states and has been registered (notified) with the European Commission for each directive, and issues EU type certificates. These bodies are published by the European Commission.

7
Competent Body
It is used only in specific guidelines such as EMC guidelines. After the guidelines take effect, it is responsible for issuing technical reports as a designated institution from the country that conducts tests in domestic standards, etc., until harmonization standards are stipulated.

8
Accredited Body
It is an inspection agency that has been audited and certified by a state-recognized agency.

9
Authorized Representative
means any natural or legal person established within the Union which has received and accepted a written mandate from a manufacturer outside the EU to act on behalf of the manufacturer in relation to the specified work in relation to the manufacturer's obligations under this Agreement under the MDR Regulations.

10
Conformity Assessment Procedure
Refers to the process of demonstrating whether the requirements of the MDR regulation relating to a device have been met.

11
EC Declaration of Conformity
The declaration of conformity is a declaration made by the manufacturer, and the manufacturer declares that the product is suitable for EU MDR. The document describing the declaration is called the Declaration of Conformity.

12
TD (Technical Documentation)
Technical documents are documents prepared when a manufacturer or agent executes a declaration of conformity and must be prepared and possessed by the relevant authorities. Design and manufacturing methods or methods used to meet essential requirements should be described.

13
CE Marking of Conformity
means a mark by the manufacturer indicating that the device complies with the applicable requirements set forth in the MDR Regulations and other applicable co-operative harmonized laws providing for such attachments.

14
PMS (Post-Market Surveillance)
Post-marketing investigation, aimed at confirming the need for manufacturers, in collaboration with other economic actors, to apply the necessary corrective or preventive measures immediately. means any activity undertaken to establish and keep up-to-date with systematic procedures for actively collecting and reviewing experiences to be gained from devices placed on the market, sold or put into use.

15
Market Surveillance
Market monitoring, refers to activities and measures undertaken by competent authorities (health authorities, CA) to identify and comply with the requirements set out in EU member state harmonization laws and to avoid impairing aspects of health, safety or public interest protection.




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