Regulatory Open Forum

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  • 1.  Mexico registration

    Posted 26-Jul-2017 17:20
    Hi colleagues,

    We are currently looking into expanding our market share in Mexico.  As is required by COFEPRIS, we will need to have a Mexico Registration Holder to facilitate the approval of our devices and act as the liaison between us and COFEPRIS.  In any event, to date we simply go through our supplier here who has a distributor of their own in Mexico.  The goal in the long run is to go independent of the supplier, having our own MRH and appointing a specific importer/distributor.  Does anyone know what is required, costs involved, timing etc.? How difficult or easy is it to appoint another distributor/importer in the long run, and whether it varies per type of device, i.e. medical vs domestic use (small appliances) etc.?


    Any feedback would be appreciated.


    Regards,
    Laura


    ------------------------------
    Laura HoShue
    Regulatory Compliance Specialist
    Las Vegas, Nevada
    USA
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  • 2.  RE: Mexico registration

    Posted 04-Aug-2017 06:33

    Hi Laura,

    It is mandatory to have an in country regulatory representative for Mexico. However in most of the cases the distributors are not clear about all the responsibilities of the local regulatory rep and try to take this responsibility so as to continue controlling on the market for your device/s. The major focus for distributors is on selling the devices and might not be up to date on the regulatory changes and happening for your products.

    Also while you would want to change your supplier/distributor, you would again have to bear the cost for the re-registration. All the technical documents for your devices would be in the name of the current distributor, so when you would want to switch, you will have to get the new manuals, labels and technical documents printed in the new distributors name and also it will create some ambiguity when you have devices with different information when you switch the distributor. 

    Also in case of any recalls/incidence reporting would the distributor/supplier be able to take the ownership and defend.

    Let me know if you would like to get further information on having a regulatory partner for Mexico. 

    Regards



    ------------------------------
    Sunitha
    Freyr Software Services Pvt Ltd
    Princeton NJ, United States/ Hyderabad, India
    +91 9100 941 932
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  • 3.  RE: Mexico registration

    Posted 04-Aug-2017 09:55
    ​Hi Laura,

    I could provide you with some information about Consultants in Mexico, to help you with this project.
    Some colleagues in our Company have also used EMERGO for this purpose.   

    In Mexico there is a mandatory norm which requires to have a Tecnovigilance unit, which will take care of Complaints/recalls (to say it summarized). That is also a role for the Distributor you choose.   

    Another consideration for Mexico... if eventually you may be interested also in manufacture here, a GMP certificate is mandatory by COFEPRIS for all medical devices/pharma manufacturers located in Mexican territory. That is needed at site level, besides the sanitary registration required at product level.

    Best regards.
    Celia.

    ------------------------------
    Celia Encinas
    Regulatory Affairs Specialist
    Medtronic Mexico
    Tijuana, B.C.
    Mexico
    celia.encinas@medtronic.com
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  • 4.  RE: Mexico registration

    Posted 07-Aug-2017 13:29
    Thank you both Celia and Sunitha for the information.  I have been in touch with someone in Mexico who has been a great resource and will assist moving forward.  

    I thank you both and will reach out in the event that this does not work out.

    Regards,
    Laura

    ------------------------------
    Laura HoShue
    Regulatory Compliance Specialist
    Las Vegas, Nevada
    USA
    ------------------------------



  • 5.  RE: Mexico registration

    Posted 08-Aug-2017 10:52
    HI Laura!!!

    Hope all is well in Vegas!!! Remember to leverage any US approvals, especially for Class II products that can be "fast-tracked" using the new regs from COFEPRIS...

    Regarding registration requirements, you can use a 3rd party to hold the registration and then choose multiple distributors - not tying you Registro Sanitario with any one distributor that can one day hold it for ransom.

    Good Luck!

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    Jose Cabrera
    Regulatory Consultant
    Palm Beach Gardens FL
    United States
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  • 6.  RE: Mexico registration

    Posted 09-Aug-2017 11:22
    Hi Jose,

    Great hearing from you! Thank you so much for your response.  Yes indeed I have communicated to the team that we can leverage the US approvals as a "fast track" option, as well as recommended that we not tie ourselves to one distributor since they may not be inclined to release our registrations in the event that we want to add more in the future.

    Great feedback as always.  Hope all is well in sunny Florida!


    Regards,
    Laura 



    ------------------------------
    Laura HoShue
    Regulatory Compliance Specialist
    Las Vegas, Nevada
    USA
    ------------------------------