You must assign at least one person responsible for regulatory compliance. Having a PRRC is mandatory.  The expertise of the person(s) responsible for MDR compliance will have to be demonstrated. You will need to document the qualifications of this/these individual(s). The person(s) responsible for regulatory compliance cannot also be the EU authorized representative.

According to Article 120 (2-4), an additional conditional transition period is possible, but only for devices which still have a valid (MDD) Notified Body that was certified by May of 2020. Those devices can continue to be placed on the EU market and put into service as long their certificate is valid. This additional transition period is limited: Placing on the market date for MDD certified devices ends in May 2024, putting MDD certified devices into service ends in May 2025.

There are conditions: Not only must the manufacturer have a valid MDD certificate for the device. The manufacturer must also comply with the new EU MDR requirements for post-market surveillance, vigilance and registration.

Time and resources/staffing are two of the biggest issues we’ve seen with clients regarding EU MDR preparedness. Companies often assume that EU MDR won’t differ much from current certifications, and thus, it can be pushed to a later due date or further down a priority list. There’s also a tendency to put only a handful of people on the project, especially if there’s no way to create a dedicated EU MDR task force or team.

The new EU MDR definition of “medical device” expands the term and includes more devices than before. For example, the expanded definition now includes items like colored contact lenses, cosmetic devices, and devices for the purpose of “prediction and prognosis” of disease.

In short, it will vary depending on device classification. All devices need proper tech docs for EU MDR compliance, and those documents must be maintained per compliance needs. Companies should consider the respective costs with respect to sale volumes and estimated time/cost investment in maintaining the documents. Notified Bodies will treat each submission as if it’s the first time they’ve seen the documents.

Under MDR, your Notified Bodies will have more authority in post-market surveillance. Now, Notified Bodies can have the ability to perform unannounced audits at certain checkpoints throughout the compliance process.