General Safety and Performance Requirements (Annex I) in the New Medical Device Regulation
Comparison with the Essential Requirements of the Medical Device Directive and Active Implantable Device Directive
As compliance with the ‘Essential Requirements (ERs)’ is the keystone for establishing conformity with the Medical Device Directive (MDD, 93/42/EEC) and Active Implantable Medical Device Directive (AIMDD, 90/385/EEC), so too is compliance with the ‘General Safety and Performance Requirements (SPRs)’ in establishing conformity with the recently published Medical Device Regulation – EU Regulation 2017/745 (MDR). The Regulation’s date of publication was 5 May 2017 and date for Entry into Force was 25 May 2017 with a 3-year transition period (postponed 25 May 2021).
The purpose of this white paper is to compare the ERs in the MDD and AIMDD to the SPRs in Annex I of the new MDR. Where there are 13 ERs in the MDD and 16 in the AIMDD, there are 23 SPRs in the new MDR. The overall text and requirements are expanded, but the scope and topics are consistent overall with the previous directives with a few notable exceptions. Some topics such as clinical evaluation and medicinal consultation have moved from the requirements list into the articles, while other topics are new to the requirements list, including devices without a medical purpose and requirements for devices used by lay persons. A number of areas now have increased emphasis and more explicit requirements, which in many cases align with harmonized standards and industry guidances. Importantly, all of these points will now become European law under this Regulation.
The areas in Annex I considered to have highest impact to manufacturers are:
- medicinal substances (and substances absorbed or locally dispersed);
- devices incorporating materials of biological origin;
- substances of concern;
- labelling requirements;
- emphasis on cybersecurity.
Other key areas of impact in the MDR outside Annex I include:
- clinical data and evaluation requirements;
- reclassification of some device types;
- post-market requirements.
These topics outside Annex I are beyond the scope of the current white paper, but manufacturers should be aware that these important areas are also changing in comparison to the directives. An updated white paper will follow focusing on the implications of the MDR and MEDDEV 2.7.1 Rev. 4 for clinical data and evaluation.
The paper is organized in order of the new safety and performance requirements by number, with the goal that the readers begin to become familiar with the new numbering and organization. The intent is not to reproduce each requirement, but to highlight areas of particular similarity and difference between the ERs and SPRs.
While many of the SPRs (namely numbers 10-23) have explicit headings or titles, others have been added here in an attempt to highlight the theme of each requirement. Cross-references to ERs and other documents with similar text have been identified for each requirement.
In addition, each SPR has been graded (low, medium or high) relative to the expected impact of the changes to the manufacturer (see Appendix 1 for SPR/ER Cross-reference Mapping Guide). Understanding the SPRs will be an important aspect of manufacturers’ transition plans from the directives to the MDR.
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