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  • 1.  IVD Labeling

    This message was posted by a user wishing to remain anonymous
    Posted 07-Aug-2020 08:45
    This message was posted by a user wishing to remain anonymous

    Hi 

    Does the EU require the Rx Only symbol on IVD labeling?

    Are kit contents required to be on the kit box.  If so, is the test required to be in one of the national languages of the country the kit is sold.

    Thanks


  • 2.  RE: IVD Labeling

    Posted 10-Aug-2020 08:37
    Edited by Agnieszka Swiatek 10-Aug-2020 08:36
    Dear Anonymous,
    IVD Directive 98/79/EC, annex I, paragraph 8 does not list Rx as mandatory information the label. If your test is not calibrated to provide a n reactions in each kit, then there is no need to include this information on the label. 
     
    The following statements in IVDD are the closest to your question: 

    "Each device must be accompanied by the information needed to use it safely and properly, taking account of the training and knowledge of the potential users, and to identify the manufacturer."
    "The label must bear the following particulars which may take the form of symbols as appropriate (...) the details strictly necessary for the user to uniquely identify the device and the contents of the packaging"

    The applicable standard here is NBN EN ISO 15223-1:2016 Symbols to be used with medical device labels, which is designed to provide internationally  accepted symbols that do not require translation.  

    You do no need to list the entire composition on the kit label, if this is already explained in the IFU. The latter however must be in the national language of the country where the kit is sold.

    The kit components must be are clearly identifiable, so that the user can inspect that nothing in the kitbox is missing and cannot swap reagents during the procedure.

    Typically manufacturers use unique letters or symbols on each bottle/tube cap, and list those on the kit box label, eg. 2xE (= 2 vials of Enzyme X); 5xB ( = 5 vials of Buffer Y) Etc. 

    Regarding the nr of the reactions:
    - how does your customer know that the quantity delivered matched what was ordered? 
    - what is claimed on other marketing and technical materials? 
    - does your kit come in different sizes/volumes? 

    In my experience most kit users want to know in advance how many reactions/samples/tests they can squeeze out of the kit, when planning their purchase, so the manufacturer best either guarantees the Rx 
    https://www.iso.org/obp/ui/#iso:grs:7000:0518 or the volume of reagents in each container.  Otherwise they will complain.
    I hope this helps,
    Kind regards,
    Agnieszka  

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    Agnieszka Swiatek
    Regulatory Affairs Manager
    Niel
    Belgium
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  • 3.  RE: IVD Labeling

    Posted 10-Aug-2020 08:40
    Edited by Richard Vincins 10-Aug-2020 08:53
    Hello Anonymous,

    In the EU there is no definition or statement for prescription use only or Over the Counter use - so the Rx symbol is not really recognised in the EU.  There are medical devices and IVD medical devices, but they do not differ nor provide any information regarding prescription.

    If you read through Annex I GSPR specifically the labelling there is some references or inferences the kit contents need to be on the kit box.  This has actually been the situation for a while that any kit contents needs to be described on the box label.  Under the EU IVDR (and the EU MDR) any product sold in a Member State the "labelling" needs to be in the local official language.  So the simple answer to those questions is yes.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: IVD Labeling

    Posted 10-Aug-2020 09:37

    You didn't say whether the question is about the IVDD or the IVDR so I infer it is the IVDR.

    Does the EU require the Rx Only symbol on IVD labeling?
    Article 1(9) says, "This Regulation shall not affect national law concerning the organization, delivery, or financing of health services and medical care, such as the requirement that certain devices may only be supplied on a medical prescription, the requirement that only certain health professionals, or health care institutions may dispense or use certain devices or that their use be accompanied by specific professional counselling".

    The Rx Only symbol in the US restricts sales. In the EU, this is at the Member State level, not the Union level. You will need to determine any requirements from each Member State.

    The traditional sources of symbols (EN ISO 15223-1:2016, Use of Symbols to Indicate Compliance with the MDR – December 2019, and IVDR – MDR Labelling differences: what symbols apply to IVDs – November 2019) don't have a symbol for Rx or OTC. Under Annex I(20.1)(h), because the IVDR doesn't have any harmonized standard or CS, "the symbols and colors shall be described in the documentation supplied with the device".

    Are kit contents required to be on the kit box?
    Annex I(20.2)(t) says the following information must be on the label, "the devices and separate components shall be identified, where applicable in terms of batches, to allow all appropriate action to detect any potential risk posed by the devices and detachable components. As far as practicable and appropriate, the information shall be set out on the device itself and/or, where appropriate, on the sales packaging".

    Is the test required to be in one of the national languages of the country the kit is sold?
    I infer "the test" means the instructions to run the test. They would be in the IFU under Annex I(20.4)(v), "assay procedure including calculations and interpretation of results and where relevant if any confirmatory testing shall be considered; where applicable, the instructions for use shall be accompanied by information regarding batch to batch variation provided with relevant figures and units of measure".

    Article 10(10) says, "Manufacturers shall ensure that the device is accompanied by the information set out in Section 20 of Annex I in an official Union language(s) determined by the Member State in which the device is made available to the user or patient". This includes both eh label and the IFU.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 5.  RE: IVD Labeling

    This message was posted by a user wishing to remain anonymous
    Posted 11-Aug-2020 08:52
    This message was posted by a user wishing to remain anonymous

    Apologies for not being clear.  Requirements pertaining to the IVDD


  • 6.  RE: IVD Labeling

    This message was posted by a user wishing to remain anonymous
    Posted 11-Aug-2020 08:52
    This message was posted by a user wishing to remain anonymous

    I have not been able to locate a definition for label or labeling in the IVDD.  Does something exist similar to the FDA definition?