Before your products can be placed on the
European market they must meet the requirements of
the relevant product directives. We will guide you
through the CE Marking process for medical devices.
Product directives are joint rules that have been
put in place to simplify trade to and between the
member countries of the European Union. Before the
CE Mark may be affixed to a medical device and
legally sold within the European Union, the
manufacturer or exporter must complete the
following:
- Prepare Technical Documentation (Technical
File) to show the product’s compliance with
applicable essential requirements and conformity
assessment procedures of the applicable device
directive
- Register their device with the appropriate
Competent Authorities
- Receive a device-specific CE
Certificate from a Notified Body (Class I
devices do not require a certificate from a
Notified Body)
Navigating the CE marking process does not have
to be painstaking. In fact, RASOO makes it as
easy as the following steps:
1. Classify your product - Class I, IIa, IIb,
and III according to the classification rules in
Annex IX of the MDD:
- Class I. Devices with low risk such as
external patient support products.
- Class IIa/b. Devices with medium risk such
as electro-medical devices.
- Class III. Devices with high risk such as
cardiovascular catheters.
*Note that: Some Class I and all Class IIa,
IIb, and Class III devices require Notified Body
approval.
2. Determine your certification process
based on your device class
3. Fulfill the essential requirements
- Ensure that your medical device fulfills the
essential requirements in Annex I of the Medical
Device Directive.
4. Establish a monitoring system
- As a manufacturer, you are required to monitor
your products once they are on the market, in case
accidents involving your products occur.
5. Establish an accident reporting system
- If an accident or near-accident involving any of
your products takes place, you are obligated to
report this to the authorities.
6. Issue a Declaration of Conformity
7. Save the documentation for five years
- The new revision of the MDD requires that records
for implantable devices be kept for 15 years.
Declaration of conformity, technical documentation,
reports, and certificates from the Notified Body
etc. must be kept for at least five years after the
product has been taken out of production.
8. Register with the appropriate
authorities in Europe
The Medical Device Directive 93/42/EEC (MDD) is
filled with confusing rules, device classifications,
and conformity requirements. RASOO has helped
countless medical device manufacturers gain market
access into the European Union. Our experts know
your product and the requirements you must meet -
from the MDD certification process to the standards
related to your device class.
In order to market your medical device within the
member states of the European Union, your product
must comply with the essential requirements of the
MDD. Compliance with harmonized standards (such as
EN 60601-1-2:2001 for EMC, and EN 60601-1 for
electrical safety) can provide assumption of
conformity to specific requirements.
In simple terms, the aim of the MDD is:
-
To define the essential requirements that
medical devices must meet before being
placed on the market
-
To establish conformity assessment
procedures based on device classifications
-
To create tracking and reporting mechanisms
available to national authorities to ensure
and protect public health
As part of the MDD’s essential requirements
(Annex I), you must also provide the following:
-
Technical Documentation (Technical
File) - Technical documentation
should contain full construction details and
validation/verification data for your
medical device. This will prove that you
comply with the essential requirements of
the MDD.
-
Risk Assessment - Your
product’s risk assessment must include a
construction evaluation, materials used,
bio-compatibility analysis, infection and
cross-infection risks, and potential risks
during use. The resulting documentation
becomes part of the Technical File.
-
Quality System - Your
organization must meet the quality system
requirements of the MDD. Conformity to ISO
13485, which is a harmonized standard in the
EU, is a way to demonstrate conformity to
the quality system requirements of the MDD
for those annexes applicable.
Depending on your product classification, you may
also need Notified Body approval. We are the
European Union based Notified Bodies to the MDD
Once you have met all applicable requirements, it
is your responsibility to show conformity with the
Medical Device Directive by affixing the Ce Mark to
your device.
RASOO has the expertise to help you navigate the
IVDD quickly, cost effectively, and successfully.
With three Notified Bodies in Europe, RASOO has helped
countless in-vitro diagnostic device manufacturers
gain market access into the European Union.
The In-Vitro Diagnostic Directive (IVDD) 98/79/EC
addresses the essential requirements that an
in-vitro diagnostic device must meet before being
marketed within the European Union. The requirements
called out within the IVDD are essentially a
grouping of requirements covered within the Active
Implantable Medical Devices Directive and Medical
Devices Directive (MDD) 93/42/EC.
The scope of the IVDD covers all in-vitro diagnostic
devices and their accessories. An in-vitro device is
defined as any medical device which is a reagent,
reagent product, calibrator, control material, kit,
instrument, apparatus, equipment, or system to be
used in-vitro for the examination of blood or tissue
specimens.
In comparison to the MDD, the IVDD places greater
emphasis on the potential risk involved during the
use of the product. With that, the intended use and
the potential risks must be outlined in a risk
assessment. In addition, the IVDD calls out specific
design, manufacturing, packaging, and labeling
requirements.
Meeting the IVDD standards is as easy as the
following simple steps:
1. Determine your product group based on its
function
Self testing devices; such as those products deemed
for home use
Reagents and reagent products, including calibrators
and control materials for determining blood groups
or the detection and confirmation of HIV or
Hepatitis infection - Annex II, List A Device
Reagents for blood typing and self-diagnosis devices
- Annex II, List B Device
Products that do not fall into the first three
groups
2. Determine the essential requirements based on
your product group
3. Fulfill the essential requirements - Depending on
your product group, you will need to
provide/complete a combination of the following
essential requirements:
Provide technical documentation (technical file)
containing full construction details of your
in-vitro diagnostic device.
Show compliance to the essential requirements and/or
applicable harmonized standards.
Provide a risk assessment, including construction
evaluation, materials used, bio-compatibility
analysis, infection, and cross-infection risks.
Meet the quality system requirements of the
Directive.
4. Establish a monitoring system - As a
manufacturer, you are required to monitor your
products once they are on the market in case
necessary updates must be made according to updated
requirements of the IVDD.
5. Establish an incident reporting system - If an
incident or near-incident involving any of your
products takes place, you are obliged to report this
to your local governing body for medical devices.
6. Prepare a Declaration of Conformity / Apply CE
Marking
7. Register with the local governing body for
medical devices
Contact us to see how RASOO can help your
organization with CE Marking for Medical Devices. |