Regulatory Open Forum

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  • 1.  UK Authorized Representative Referrals?

    Posted 22-Oct-2020 08:38
    I have a small dental medical device client that wants to register in the UK and is seeking referrals for the "UK Responsible Person".  Can anyone refer some names/representatives for me to share with my client so they can begin interviewing? Thanks very much for your assistance and you can contact me at STCSmith@aol.com.....or call my office at 941 460-8849 (EST) and leave me a message.....Thank You! Susanne

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    Susanne Smith MSN
    Biomedical Clinical and Regulatory Device Consultant
    Englewood FL
    United States
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  • 2.  RE: UK Authorized Representative Referrals?

    Posted 23-Oct-2020 04:25
    Susanne,
    There was a lively discussion in the forum in the past days.

    In any case if you need a starters package on the UK REP please email info@qservegroup.com

    If you want to follow a free webinar on the subject, https://www.qservegroup.com/eu/en/e777/free-webinar-ennbsp-uk-responsible-person


    More news to follow,

    Martin Debruin
    Qserve Group Ltd., London.
    https://www.qservegroup.com/eu/en/market-access/uk-market-access---ukca.



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    martin.de.bruin@qservegroup.com
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  • 3.  RE: UK Authorized Representative Referrals?

    Posted 23-Oct-2020 06:19
    Dear Susanne,
    thank you for sharing this at RegEx.

    MDSS-UK LTD is open for business as we prepare our clients for the UKRP requirements. However …

    The requirements are not finalized. The guidance provided by the MHRA reflects nicely the DRAFT legislation. The draft law was published just a few days ago and still needs to go through the parliament.

    A contract may be signed but can only go in effect in January. Up to December 31 the entity in the UK is still an EC REP and if there is another EC REP in the EU then this may be difficult.

    I am pointing this out since I am seeing others are quite aggressively forthcoming pushing for it. I would be careful with that and someone should obtain full understanding of the requirements. A lot of costly mistakes can be made in the transition.

    The UKRP should be installed as soon as possible according to the MHRA guidance and must be in place with the registration of products. It is the UKRP who must register the products. There is transition period installed for the registration staggered according to the risk class. With also being the EC REP we are able to coordinate the process and we work with our clients and mutual goal is to get everyone registered on time in the UK.

    Here is the link to the MHRA guidance:
    https://www.gov.uk/guidance/regulating-medical-devices-from-1-january-2021

    And here is the direct link to the draft legislations:
    https://www.legislation.gov.uk/ukdsi/2020/9780348213805/contents

    And here is our offer:
    https://mdssar.com/services/uk-responsible-person

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    Ludger Moeller
    President, MDSS GmbH
    l.moeller@mdssar.com
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  • 4.  RE: UK Authorized Representative Referrals?

    Posted 24-Oct-2020 06:10
    Just one further point to add to Ludger's comment: MHRA has stated that the UKRP should be designated from 1 January 2021. Even though formal identification of the UKRP may not be required until the time of device registration, in accordance with the classification-dependent timescale, should MHRA need to contact a non-UK manufacturer after 1 January 2021, they will expect to be able to do this via a UKRP, so companies need to act quickly to set up the appropriate agreements.

    As it states on the MHRA webpage providing guidance on what is expected after 1 January 2021: "Manufacturers should aim to appoint their UK Responsible Persons as soon as possible".

    In addition, it makes sense for non-European manufacturers who have already designated an Authorized Representative (AR) to use the same organization to act as UKRP, if possible, to eliminate any duplication of effort in making technical documentation, etc., available. Many consultancies who specialize in AR services are setting up companies in the UK to offer parallel UKRP services, including my company, Donawa Lifescience.

    Under the currently drafted proposals, European manufacturers are allowed to continue to place CE marked devices on the UK market until 30 June 2023, but after this, they too will need to designate a UKRP.

    Of course, all the above is based on a 'no deal' Brexit, but even if a deal is reached in the next few days, do not expect any significant changes.

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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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  • 5.  RE: UK Authorized Representative Referrals?

    Posted 24-Oct-2020 08:46
    Having just posted this response, I realize that one of my statements is incorrect. I said:

    "Under the currently drafted proposals, European manufacturers are allowed to continue to place CE marked devices on the UK market until 30 June 2023, but after this, they too will need to designate a UKRP."

    What I should have said is that:

    "Under the currently drafted proposals, European manufacturers are allowed to continue to place CE marked devices on the UK market until 30 June 2023, but after this, they will need to include UKRP details on the labeling of devices intended for the UK market, together with the UKCA mark."

    The requirement for non-UK manufacturers to designate a UKRP from 1 January 2021, and have the UKRP register their devices in accordance with the classification-dependent timescale, includes European device manufacturers.

    Apologies for the confusion!


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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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