The European Medical Device Coordination Group published a joint implementation plan ahead of the May 2020 deadline for the full implementation of the EU MDR. The plan addresses the concern that the implementation of the MDR has proven to be a challenging task for the medical device industry, European member states, and the EU commission and further mentions that the involved stakeholders must step up their efforts to achieve the May 2020 deadline.1
The joint implementation plan sets the priorities and contingency actions that are essential to have a fully operational EU MDR compliant system in place by May 2020. The plan prioritizes the following elements pertaining to the medical device regulations:
EUDAMED
Roll out of the EUDAMED database has been delayed, however, the plan endorses that a delay in implementation of the database should not prevent the timely application of the MDR. The EU Commission is prioritizing the release of the actor module of the EUDAMED by 26th May 2020 and gradually releasing the other modules with a target completion date set in May 2022.1
Placing safe devices on the market after May 26, 2020
The biggest challenge that the industry will have to face with the implementation of the MDR is a shortage of medical devices due to the limited number of notified bodies available to certify medical devices, as well as companies that are pulling out their devices off the market. Though 11 notified bodies are accredited by the EU to carry out conformity assessments, the concerns remain on the capacity of the notified bodies.1
Switzerland’s exit from the EU
If the EU-Switzerland Mutual Recognition Agreement is not updated by 26 May 2020, then the conformity certificates issued by the Swiss notified bodies will become invalid. To place a medical device in the EU market, the manufactures will have to transfer their certificates to an EU based notified body. In addition to that, Switzerland will be considered a third country and Swiss-based manufacturers will need an authorized representative in the EU.1
Clarification regarding clinical evaluations and expert panels
With the stringent requirements established in the MDR for clinical data, clinical evaluation, post-market clinical studies, manufacturers are in need of clarifications to understand what an adequate approach would be to apply for their products. The work to set up an expert panel to evaluate the clinical requirements of the regulations as well as making guidance documents available to the industry to support in implementing these requirements is advancing.1
Monitoring
The EU Commission intends to request regular updates from the industry and the NBs to monitor the implementation and the transition progress ahead of May 2020 and beyond.1
These priorities have been identified based on the objectives of public health, patient safety, and transparency. The EU Commission’s efforts to work on the priorities mentioned above is ongoing. It is worth noting that focusing on a limited set of agreed-upon priorities could result in temporarily fewer resources being placed into other areas. However, patient access to safe and efficient medical devices will be at the forefront of all the implementation efforts.1
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1Medical Device Coordination Group (March 2020) retrieved on 03/17/2020 from https://ec.europa.eu/docsroom/documents/40286?locale=en
