Regulatory Open Forum

 View Only
  • 1.  Labelling accessories

    Posted 08-Aug-2019 08:58
    Edited by Pooja Rathor 08-Aug-2019 09:21
    Hello,
    We are in the process of making the Marketing material (IFU,labels,reference cards) for our products.
    We have a Product 1 (a medical device system) and Product 2(accessory to the medical device system). This accessory will not have a IFU of its own as its use will be stated in Product 1's IFU. We are considering adding a  symbol on the Product 2's Box which references the use of an IFU. If we add this symbol will we still need to put a reference sheet in the packaging of Product 2 which notes" Reference the systems ( Product 1 ) IFU"???
    Product I will be classified as class IIa in EU and Product 2 will be classified as Class I .
    Any suggestions on this would be helpful.
    Thank you.

    ------------------------------


    United States
    ------------------------------


  • 2.  RE: Labelling accessories

    Posted 08-Aug-2019 12:55
    Pooja,

    Per Annex I of EU MDD 13.1, "Instructions for use must be included in the packaging for every device. By way of exception, no such instructions for use are needed for
    devices in Class I or IIa if they can be used safely without any such instructions.". However if your Class 1 is either a sterile or measuring device (or both), it may need a IFU.
    Also, is product 2 always sold with product 1? Then, you may add a "Consult IFU" harmonized symbol that can direct user to Product 1's IFU. If they're sold separately, this linking will not make sense for every user.

    ------------------------------
    Vidya
    USA
    ------------------------------



  • 3.  RE: Labelling accessories

    Posted 09-Aug-2019 08:10
    Thank you,Vidya. I appreciate you providing this information.

    ------------------------------
    Pooja Rathor
    Regulatory Affairs Coordinator
    Bowdoin ME
    United States
    ------------------------------