Understanding EU MDR
Europe’s medical device regulations are changing, bringing about some of the most substantial shifts to the ways in which manufacturers bring their devices into the EU market, and how compliance must be maintained throughout the product lifecycle. The regulations strive to increase the traceability and safety of medical devices in the EU market, expanding on requirements including product classification, own brand labelling, regulatory submission evidence, and post-market surveillance. Although EU MDR came into place in May 2017, medical device organizations have until 2020 to transition completely. Despite this, there is still an overwhelming 78% of organizations who do not currently have sufficient understanding of the requirements. Failing to produce accurate, MDR-compliant labeling and patient information could cause delays in market entry or even product recall. It is imperative, therefore, that organizations begin reviewing their labelling ‘real estate’, documentation, and system processes to ensure compliance with new, more complex regulations. So, what are some of the key changes you need to be prepared for?
Device warnings and precautions
Previously, all written warnings and precautions relating to a device were detailed in the Information for Use (IFU), however, new regulations state that these must now be present on a label in text form. This will bring translation into the mix – requiring ‘clearly comprehensible’ labeling in the intended user or patient’s national language. In addition, this also brings about the issue of designing labels with adequate space for new information – especially with some languages requiring more than others.
EU UDI: tracking and tracing
As part of the MDR, a Basic UDI-DI is being introduced. This refers to the relationship between what is a family of products that may otherwise appear to be unique individual products e.g. if one product in a family has manufacturing defects and needs to be recalled, the Basic UDI-DI shows this relationship. The Basic UDI-DI itself doesn’t appear on the label, but an organisation must be able to identify and trace all other related products as a result of querying the UDI on the label via the EU UDI database (EUDAMED), in turn creating a more secure global supply chain. This relationship is something that medical device manufacturers will need to capture and make available for on-demand searches by patients, providers, and notified bodies with the ask made much simpler by connecting previously disparate labelling processes.
How can you prepare?
- See it as an opportunity - The challenge many organisations face is a lack of tools, systems, and processes to be able to dynamically identify and update product labelling in suitable timescales. All, of course, whilst retaining fluidity, compliance, and avoiding disruption of supply chains. Although challenging, the EU MDR should be seen as an opportunity for organisations to review the effectiveness of their current labelling and artwork processes, and how digitalising supply chains can strengthen compliance and simplify evolution toward e-Labelling.
- Develop a clear strategy - Creating a clear strategy across your organisation for implementation will make the process of preparing your labelling infrastructure simpler. It is important to carry out an assessment of your current processes and documentation to determine which elements must be modified to meet the new regulations – these may include Quality, Regulatory, Operations, Supply Chain, Legal, and R&D. Engaging all teams will ensure a collaborative, more streamlined strategy and robust implementation is achieved.
- Adapt your processes - Adopting a joined-up, cloud-based labelling and artwork management solution is a key way to ensure an organisation is prepared to manage the EU MDR’s regulation and compliance changes in a more efficient manner. A platform such as this allows all users to access labelling and artwork assets via a single, centralised system, giving them full line of sight across all data assets. In addition, this platform will allow for up-and-coming changes to be managed in a fast and efficient way, future-proofing an organisation’s labelling systems in all territories.
With May 2020 fast approaching, it is imperative you act now. Assess your labelling and artwork real estate and ensure you have the operational agility to prepare for change. The implications of the inability to market your medical device products in the EU can have huge ramifications on your organisation. The countdown has begun.