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  • 1.  Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 17-Nov-2022 08:28
    Dear All,
    I was wondering does anyone have a concept for the markings on UKCA labelling transition from CE marked to UKCA.

    Please note I am not requesting anyone to disclose their concepts as I know how confidential the matter is however a simple Yes or No.

    The reason I ask is, I understand this is a big issue for the labels to meet the MDR regulatory requirements.

    I believe its an issue surrounding the entire industry, that is, having no space for marking every label type.

    However this is something I believe I may possibly be able to contribute to or to throw out an idea as a minimum. 

    I know its very brave of me if I post my idea on the board however no harm or worries.

    Thank you for reading my post. 

    Best Regards,

    John






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    John Barry
    Project Engineer
    Mullingar
    Ireland
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  • 2.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 19-Nov-2022 10:24
    Dear John,

    I've seen a few approaches...
    • Put all the required markings for all the intended markets on the product, if they fit. That requires a little care in managing transition dates.
    • Design separate markings and labels for each intended market. That makes managing the supply chain more complicated.
    • Stop offering products in markets where the potential sales volume isn't high enough to justify the extra effort.


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    Anne LeBlanc
    United States
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  • 3.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 19-Nov-2022 12:24
    Edited by John Barry 19-Nov-2022 12:30
    Dear Anne,
    Firstly thank you for the response, its very considerate of you to reply. 

    Yes, what I had in mind is for any product distributed to the UKCA market is to "Watermark" the labels if there is no space.

    This leaves the same space on the labels to add batch no., lot no. expiry date, description etc. 

    Thank you once again for the courtesy of replying.
    Thanks once again dear Anne LeBlanc. 
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    John Barry
    Project Engineer
    Mullingar
    Ireland
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  • 4.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 20-Nov-2022 14:35
    Dear John,

    I like it!  The rule specifies the font, but not the color. It only says it has to be easily visible and legible. And watermarks are often quite readable, along with whatever is over or under them. I wonder how much information a graphic designer could layer and have it still meet standards of legibility.

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    Anne LeBlanc
    United States
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  • 5.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 21-Nov-2022 04:18
    Dear Anne LeBlanc,
    Thank you for holding the door open!!!

    Best Wishes,

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    John Barry
    Project Engineer
    Mullingar
    Ireland
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  • 6.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 21-Nov-2022 04:03
    Definitely an interesting idea John, and one maybe to pursue further. For many devices, it would also need the UK Approved Body number, and for devices from a manufacturer based outside of the UK it would need the name and details of the UK Responsible Person. Not insurmountable, but to Anne's point, it depends on how much detail could be included as a watermark whilst still passing 'acceptance criteria' for legibility and also understanding (watermark content may be perceived differently from the main label by users, but I feel less of an issue here as it would be 'regulatory' conformity information rather than information for safe use). The MHRA are supposedly setting up several working groups to help aid the final definition of the new UK regulations for medical devices etc. and so this could be a suggestion for that forum.

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    Edward Ball
    Manager, Intelligence & Innovation
    United Kingdom
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  • 7.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 21-Nov-2022 04:16
    Edited by John Barry 21-Nov-2022 04:18
    Dear Edward,
    Thank you for the reply - yes, the posted image was as an example only, that hopefully others can develop on.

    With the "acceptance test" being the tipping point of the concept for use of a "Watermark" once the label details are added.

    I firmly believe this concept can be managed easily using a "Watermark" approach. 

    Example again for illustration purpose only as follows!!!! If it helps anyone as it did not post via the inbound auto-thread email  last time.
    Watermark
    I really appreciate your feedback, so thank you Edward.

    Best Regards,
    ------------------------------
    John Barry
    Project Engineer
    Mullingar
    Ireland
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  • 8.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 21-Nov-2022 11:55
      |   view attached
    Further to Edward's comments, I would likewise raise the question of whether a watermarked UKCA mark can pass the "visibility" / prominence test when it requires an Approved Body number (which thus complicates the appearance when overladen with other information).

    But I don't believe that the UK Responsible Person (UKRP) information is considered to be part of the UKCA mark.  Instead, the UKRP labeling requirement is a separate (but related) issue.  Indeed, the UKRP information does not need to be affixed in direct association with, nor proximity to, the UKCA mark.

    Another point for consideration is that, although the MHRA has stated that the UKCA mark may take "...different forms (for example, the colour does not have to be solid)...", it nonetheless requires that the letters forming the UKCA marking must be in proportion to the version I've attached where the "UK" aspect is stacked on top of the "CA" aspect.  Accordingly, I would personally be hesitant to stray from that UKCA mark stacked design.

    You might also find useful the MHRA's relatively recent implementation guidance that provides additional easements regarding the placement of the UKCA mark.


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    Kevin Randall, ASQ CQA, RAC (Europe, Canada, U.S.)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
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  • 9.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 22-Nov-2022 03:29
    "But I don't believe that the UK Responsible Person (UKRP) information is considered to be part of the UKCA mark.  Instead, the UKRP labeling requirement is a separate (but related) issue.  Indeed, the UKRP information does not need to be affixed in direct association with, nor proximity to, the UKCA mark."

    Kevin, agreed. Apologies if I gave anyone the wrong impression. I was just highlighting the UK specific content for the labelling.

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    Edward Ball
    Manager, Intelligence & Innovation
    United Kingdom
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  • 10.  RE: Conformity Transition on Markings from CE to UKCA on Labels for Use as per MDR Compliance

    Posted 22-Nov-2022 05:08
    Dear Kevin,

    Thank you for this insight, much appreciated!!!! 

    Best Regards,

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    John Barry
    Project Engineer
    Mullingar
    Ireland
    ------------------------------