Regulatory Open Forum

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  • 1.  CE marking of conformity

    Posted 05-Sep-2023 13:58

    Does anyone have creative arguments to support the claim that CE marking of conformity only on the IFU & sales packaging but neither on the device or its sterile pack, is still a compliant configuration (as per MDD Article 17 (3))?



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    Shirley
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  • 2.  RE: CE marking of conformity

    Posted 06-Sep-2023 03:10

    Hi Shirley,

    MDD articles 17.1 and 17.2 clearly state that the CE mark need to appear on the device. A deviation for small-scale devices is that the dimension can be less than 5mm per Annex XII. Maybe if your device is too small for the CE mark to be legible, you could justify to have it on the packaging and IFU.



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    Stephane Mazet
    Paris
    France
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  • 3.  RE: CE marking of conformity

    Posted 06-Sep-2023 04:00

    Shirley,

    The EU MDD and EU MDR are quite clear about the CE Mark representing the device.  If the device is single-use only, it does not need to be on the device itself.  Though it needs to be on the primary packaging of the (sterile) single-use device.  If the primary packaging is too small, then there should be secondary packaging which has not only the CE Mark, but all of the appropriate product identification as well.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: CE marking of conformity

    Posted 07-Sep-2023 01:32

    Thanks. Indeed the MDD language is clear but we were still trying to look for arguments to claim CE marking on the secondary package (vs the device/sterile barrier) fulfils Article 17 provisions…



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    Shirley
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  • 5.  RE: CE marking of conformity

    Posted 07-Sep-2023 01:37

    Thanks. The device in question is big enough to bare the CE marking but were trying to explore arguments to claim CE marking on the secondary package (instead of the device or its sterile barrier) still fulfils Article 17 provisions.

    This approach does not seem to be defendable 



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    Shirley
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  • 6.  RE: CE marking of conformity

    Posted 08-Sep-2023 10:55

    HI Shirley,

     

    I can tell you that our AR, class I device, would not sign-off on our TFs if there was enough space to mark the device.  They said that it did not meet the exception.

     

    Good Luck,

    Michelle

     

    D. Michelle Williams, CESCO

    VP – Operations

     

    Action Products, Inc.

    www.actionproducts.com

    301.797.1414 X1022

     

    https://www.linkedin.com/in/dmwilliamsvpopapiwvu88

     

     

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