Regulatory Open Forum

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  • 1.  Clinical Investigation

    Posted 22-Apr-2022 01:33
    If a manufacturer had obtained FDA 510k clearance on class II medical device 10 years ago, is it mandatory to perform another clinical investigation to comply with EU MDR requirements? 

    Christopher Chin


  • 2.  RE: Clinical Investigation

    Posted 23-Apr-2022 12:31
    Hi Christopher

    The basic EU MDR requirement is that there should be sufficient clinical evidence. Your clinical evaluation plan and clinical evaluation report can refer to the 10 years ago investigation and to a review of published literature and to a decade of postmarket surveillance data. You will have to review the adequacy of all the available information and determine if more is needed.

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    Anne LeBlanc
    United States
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  • 3.  RE: Clinical Investigation

    Posted 24-Apr-2022 11:07
    Hello Christopher,

    The United States and European regulatory systems are different and they look at clinical data from investigations/trials differently.  If a clinical investigation was performed 10 years ago, you will need to determine if as part of the clinical evaluation process this is sufficient clinical evidence.  As Anne said, you will need to review the adequacy of all available clinical data to determine whether sufficient clinical evidence supports the safety and performance of the device for CE Marking in the European Union.

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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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