With IVDR looming, EU prioritizes guidance on legacy devices and Eudamed transition

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Dive Quick:

• The European Commission’s medtech advisory team has extra steering documents on legacy units and Eudamed to the In Vitro Diagnostic Health care Devices Regulation (IVDR) transition program.
• With the IVDR date of application weeks away, the Clinical Device Coordination Group (MDCG) has recognized a pressing want for guidance on the regulation of legacy assessments that carry on to be put on the market place underneath the previous directive and for tips on the changeover to Eudamed, a health care unit databases becoming executed as aspect of the incoming regulations.
• MDCG, which set a 2nd quarter of 2022 timeline for the documents, also utilized the update to insert priority actions for “suitable surveillance” steerage and a general performance analyze template to the transition plan.

Dive Insight:

The change to a staggered implementation of IVDR has averted the prospect of the continued lack of notified bodies disrupting the source of assessments in the European Union, but left other issues unresolved and in some circumstances amplified. Notably, with the EU pushing back the date on which many in vitro diagnostics firms have to have to absolutely comply with the new polices, quite a few extra exams will be place on the market under the old directive than prepared originally. It is unclear just how the EU will regulate these legacy units.

As the MDCG advisory group discussed in its changeover prepare, IVDR states legacy equipment are issue to the new requirements on “article-market place surveillance, market place surveillance, vigilance, registration of economic operators and of equipment.” On the other hand, MDCG sees the wording as “fairly common,” main it to propose the generation of new steerage on legacy IVDR units.

MDCG released assistance on legacy MDR units very last calendar year. The team thinks diagnostics require their own direction doc for the reason that of “distinctions in between IVDs [in vitro diagnostics] and health care equipment (e.g. different classification programs), as well as the different transitional provisions.” A session on the direction is underway.

The other major improve to the transition approach is the addition of a area and priority action on Eudamed, the medtech databases the EU is producing to aid the restrictions. Simply because Eudamed will not be absolutely useful when IVDR can take result late subsequent month, MDCG reported “it would be helpful to have advice on harmonized administrative procedures and different technical answers for the exchange of info” until the databases is completely ready.

MDCG expects the assistance to allow member states and other stakeholders to satisfy IVDR obligations effectively “while reducing any prospective added burden.” The team needs the textual content to “handle in unique scenarios exactly where the trade of info would be hard, or even not doable, to obtain in absence of steering.”

As with the legacy gadget document, the Eudamed guidance is at the session phase and has a 2nd quarter publication timeline.

The up-to-date IVDR transition program also features two new priority steps in existing sections. MDCG is preparing assistance on “appropriate surveillance” by notified bodies for publication in the third quarter. The prioritization of the textual content displays a belief that “notified bodies, suppliers as effectively as designating authorities urgently need clarity on the meaning of ‘appropriate surveillance in respect of all applicable needs relating to the devices it has accredited.'” 

Ultimately, MDCG exposed a draft template for application or notification of overall performance experiments is in preparing for a next quarter release. Finally, software and notification will take spot as a result of Eudamed.

In the interim, MDCG thinks “a single EU-wide template for this, specifying a popular set of aspects to be presented and a typical format to present them, would be of substantial additional benefit to streamline the authorization or notification system.”