Regulatory Open Forum

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  • 1.  Declaration of Conformity - Translation requirements

    Posted 23-Mar-2020 03:50
    Dear RAPS members,

    I  have a question regarding the translation requirements of EU MDR Declaration of Conformity (DoC). I am aware of the fact that DoC needs to be translated into the official languages of EU member states. However, I am not sure if it requires translation even if the device is not placed in certain EU member states. For example, if the device is not sold in Germany/Austria, do we still required to have DoC in the German language?

    Any guidance is highly appreciated.

    Best regards,

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    Soumya Rajesh
    Quality and Regulatory Affairs Manager
    Den Haag
    Netherlands
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  • 2.  RE: Declaration of Conformity - Translation requirements

    Posted 23-Mar-2020 06:04
    See MDR Article 19, Soumya, viz:

    "The EU declaration of conformity shall, as a minimum, contain the information set out in Annex IV and shall be translated into an official Union language or languages required by the Member State(s) in which the device is made available."

    Hope this helps.

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    Roger Gray
    VP Quality and Regulatory
    Donawa Lifescience Consulting
    Clinical Studies - Regulatory - Quality Systems
    Rome, Italy
    +39 06 578 2665
    rgray@donawa.com
    www.donawa.com
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  • 3.  RE: Declaration of Conformity - Translation requirements

    Posted 24-Mar-2020 04:44
    Hi all
    I fully agree with Roger.

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    Evangelos Tavandzis
    Lead Auditor, Consultant
    Praha
    Czech Republic
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  • 4.  RE: Declaration of Conformity - Translation requirements

    Posted 24-Mar-2020 05:50
    Often people write it in English at least and/or in the official language of the notified body. Then you have to translate it in every required national language (if demanded).

    Even if this should be upfront translated I know very few companies that are doing this. And national competent authorities like BE, DE, FR never ask us a translated one. Even if this should be translated.

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    Maud Giorgi
    QMS & RA Manager
    Lausanne
    Switzerland
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  • 5.  RE: Declaration of Conformity - Translation requirements

    Posted 24-Mar-2020 07:42
    Roger's citation is correct - the DofC needs to be in at least one official Member State language and then translated as needed.  In my experience, often if you have in English only is fine - the actual content of DofC is fairly standard so understanding what is there is fairly well known.  You would not need to translate to German if not sold in Germany/Austria.  As a note, in the future the DofC will be uploaded to EUDAMED, so multi-language translations might be needed at that point in time.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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