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EUDAMED UDI entry

  • 1.  EUDAMED UDI entry

    This message was posted by a user wishing to remain anonymous
    Posted 09-Sep-2022 09:23
    This message was posted by a user wishing to remain anonymous

    Hi All,

    I understand that EUDAMED UDI entries are done only under IVDR or MDR. 

    What happens when your device is self-declared under IVDD and is under transition for IVDR and you wish to enter UDI details in the EUDAMED database?

    Thank you


  • 2.  RE: EUDAMED UDI entry

    Posted 09-Sep-2022 12:19
    I think it could be viewed as misleading if a EUDAMED database entry is made for a device that isn't yet in full conformity with the IVDR or MDR.  Such an entry could be used, abused, or misunderstood to imply MDR/IVDR conformity when no such conformity assessment has yet been completed.  This would run contrary to one of the prime directives for the EUDAMED database, which is to enable the public to be adequately informed about the subject device and corresponding conformity assessment [See Article 33(1)(a)].  Sensitivity against inaccurate or misleading information about market authorization is a general tenet of successful medical device regulatory affairs.

    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, Canada, U.S.)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2022 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------



  • 3.  RE: EUDAMED UDI entry

    Posted 10-Sep-2022 01:29

    Hi,

     

    UDI entries/submissions to EUDAMED are allowed for MDR/IVDR (regulation devices) and MDD/AIMDD/IVDD (legacy devices). These are all separate records there is no transfer of data between the legacy and regulation devices.

     

    You can enter your IVDD record now, and when you are ready with the IVDR certificate then you can enter the IVDR record. If you are using the same UDI DI for both IVDD and IVDR then EUDAMED will check the properties entered to make sure they are the same. Incidentally, the risk class is not one of the properties checked as some devices increase their class under the regulations.

     

    One last point to remember is the market start date, when entering the regulation record for IVDR your market start date is the first date you put it on the European market after you receive the certificate. This is why to maintain the full history of the device we recommend, if applicable, entering both legacy and regulation devices as the full history is maintained by the legacy and regulation devices being entered in EUDAMED with the same UDI DI.

     

    If you need any assistance submitting your data to EUDAMED or EUDAMED training please do contact me or visit our site Eudamed.com

     

    Now I need your help and the help of anyone reading this message. We need 10 minutes of your time. We partnered with KPMG to create a survey which will help us understand the future use of EUDAMED, please complete our survey, Thank you. https://survey.us.kpmg.com/jfe/form/SV_6lLFeHQqwiNz0Lc

     

    Best regards,

     

    Richard Houlihan

    @eudamed.com

     

     

     

    EirMed Ltd

    Brussels, Belgium | Sofia, Bulgaria

    t:   +359 2 492 8458

    e:   richard.houlihan@eudamed.com

     

    EudaMed.com

          

     

    The content of this email is confidential and intended for the recipient specified in the message only. It is strictly forbidden to share any part of this message with any third party, without the written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. 

     

     






  • 4.  RE: EUDAMED UDI entry

    This message was posted by a user wishing to remain anonymous
    Posted 11-Sep-2022 10:26
    This message was posted by a user wishing to remain anonymous

    Even though an IVDD self-declared device isn't a legacy device, I would imagine what is in the guidance for legacy devices would be similar for non-legacy devices: legacy devices should register into Eudamed without a BUDI-DI and UDI-DI, instead a Eudamed DI (Eudamed or manufacturer generated) and a Eudamed ID (Eudamed generated) will be assigned to allow Eudamed to work. A certificate number wouldn't be required to be entered into Eudamed since this is a self-declared device that doesn't involve Notified Body conformity assessment.


  • 5.  RE: EUDAMED UDI entry

    Posted 12-Sep-2022 02:02

    Hi,

     

    You can upload legacy devices with an existing UDI DI from one of the four designated issuing entities.

     

    If you already have a real UDI DI then you can use this with the issuing entity, then for the Basic UDI you take the existing UDI DI and add a 'B-' in front of it with EUDAMED as the issuing entity. This way when you upload your IVDR/MDR devices you reuse the same UDI DI and EUDAMED creates a link between the two thus preserving your device history. If you are entering your data via the EUDAMED forms you enter your real UDI DI and press the generate button and it adds the B-. However, if you are submitting XML you must prepare this data yourself with the 'B-'.

     

    If you do not have an existing UDI DI from one of the four designated issuing entities then you need to generate the B-UDI etc. You effectively need to generate a fake Basic UDI and UDI DI whose only purpose is to get your data into EUDAMED. It never appears on labels etc. If you are adding your data via the EUDAMED forms you follow the instructions and click the "Generate" button OR you can pre-generate your own codes following a very long algorithm from the European Commission, when using XML you must pre-generate the B-UDI/UDI DI, again this is only if you do not have an existing UDI DI. To save you a lot of trouble with this generation of codes we prepare an excel template where you can create as many as you like. This template is available for free: https://eudamed.com/index.php/eudamed-legacy-device-di-generator/

     

    Best regards,

     

    Richard Houlihan

    @eudamed.com

     

     

     

    EirMed Ltd

    Brussels, Belgium | Sofia, Bulgaria

    t:   +359 2 492 8458

    e:   richard.houlihan@eudamed.com

     

    EudaMed.com

          

     

    The content of this email is confidential and intended for the recipient specified in the message only. It is strictly forbidden to share any part of this message with any third party, without the written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. 

     

     






  • 6.  RE: EUDAMED UDI entry

    This message was posted by a user wishing to remain anonymous
    Posted 12-Sep-2022 14:08
    This message was posted by a user wishing to remain anonymous

    Thank you all, really appreciate your insights into this.

    The only option we can see in the EUDAMED to register our device (self-certified, Risk class - IVD General) under IVDD is under "Register a Legacy Device". However, as our device is self-certified it cannot be termed as legacy device.

    It's quite confusing by EUDAMED...

    We may have to send an enquiry to them.

    Thanks,


  • 7.  RE: EUDAMED UDI entry

    Posted 13-Sep-2022 01:42

    Hi again,

     

    For clarity, I spoke with the European Commission yesterday and I put this question to them:

     

    For EUDAMED are self-declared IVDD devices treated any differently than other legacy devices? Or do they just register in EUDAMED the same way as any other legacy device? 

     

    They responded:

    There is no difference.

     

    Best regards,

     

    Richard Houlihan

    @eudamed.com

     

     

     

    EirMed Ltd

    Brussels, Belgium | Sofia, Bulgaria

    t:   +359 2 492 8458

    e:   richard.houlihan@eudamed.com

     

    EudaMed.com

          

     

    The content of this email is confidential and intended for the recipient specified in the message only. It is strictly forbidden to share any part of this message with any third party, without the written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. 

     

     






  • 8.  RE: EUDAMED UDI entry

    Posted 13-Sep-2022 04:28
    Edited by Erica Conway 13-Sep-2022 04:42

    Hi Anon

    I defer to the previous response for expertise on Eudamed – however just to follow up on your comment re that a self-certified device cannot be termed as legacy.

    Please refer to MDCG 2022-8 (Regulation (EU) 2017/746 - Application of IVDR requirements to 'legacy devices' and to devices placed on the market prior to 26 May 2022 in accordance with Directive 98/79/EC) for an explanation of the term 'legacy'. This provides an explanation of terminology, which clarifies that self-certified IVDD devices with a signed Declaration of Conformity signed before the Date of Application (DoA), that are placed on the market after the DoA under the transition provisions (ie will need a NB under the IVDR) are 'legacy'.

    Here's the section from the guidance:

    'Legacy devices under the IVDR (hereafter 'legacy devices') should be understood as devices referred to in the 2nd or 3rd subparagraph of Article 110(3) IVDR, which are placed on the market or put into service after 26 May 2022 (i.e. the IVDR's date of application) and until the end of the respective transition period set out in the 2nd or 3rd subparagraph of Article 110(3), if the conditions laid down in the 1st subparagraph of Article 110(3)3 are fulfilled. Those devices can be:

    a) devices covered by a valid EC certificate issued by a notified body in accordance with Directive 98/79/EC on in vitro diagnostic medical devices (IVDD) prior to 26 May 2022; or 

    b) devices for which a declaration of conformity was drawn up prior to 26 May 2022 in accordance with the IVDD and for which the conformity assessment procedure pursuant to the IVDR (contrary to the IVDD) requires the involvement of a notified body.

    'Old' devices are those devices that were placed on the market or put into service before 26 May 2022 in accordance with the IVDD or the applicable national rules before the IVDD had become applicable and which are still on the market or in use after 26 May 2022.

    IVDR devices are those devices that are placed on the market as being in conformity with the IVDR other than 'legacy devices'. In order to be placed on the market or put into service from 26 May 2022 all class A non-sterile devices and all devices not benefitting from the transitional provisions laid down in Article 110(3) IVDR, i.e. all 'new' devices, must be IVDR-compliant.

    ------------------------------
    Erica Conway
    Vice President, IVD Regulatory Affairs - Europe
    MCRA UK
    ------------------------------



  • 9.  RE: EUDAMED UDI entry

    This message was posted by a user wishing to remain anonymous
    Posted 14-Sep-2022 10:07
      |   view attached
    This message was posted by a user wishing to remain anonymous

    Thank you very much for your response.

    Richard - I really appreciate you going an extra mile to pose a question to the commission. I asked the same question to EUDAMED helpdesk who have advised us to wait until the device is fully compliant to IVDR and then register on EUDAMED , so it seems a contradictory from EUDAMED. It would be nice if they could release some sort of guidelines around this.

    Erica - Thank you for providing definitions of the legacy devices. However, looks like EUDAMED might be running slightly differently as compared to the MDCG guidelines.

    I have attached a screenshot for better clarity in which I have selected device under legacy device. As you go along further in the registration menu, you can see the device can be registered under IVDD - general i.e. self-certified without a certificate which makes Richard's comment through EUDAMED valid?

    Thanks




  • 10.  RE: EUDAMED UDI entry

    Posted 14-Sep-2022 10:21

    Hi,

     

    You are very welcome. Concerning the EUDAMED support, I have major doubts about the quality of the information they are providing. I do not think they are being trained in all things EUDAMED which is another reason why we are offering support to companies.

     

    Your screenshot looks accurate to me.

     

    Good luck with EUDAMED.

     

    Best regards,

     

    Richard Houlihan

    @eudamed.com

     

     

     

    EirMed Ltd

    Brussels, Belgium | Sofia, Bulgaria

    t:   +359 2 492 8458

    e:   richard.houlihan@eudamed.com

     

    EudaMed.com

          

     

    The content of this email is confidential and intended for the recipient specified in the message only. It is strictly forbidden to share any part of this message with any third party, without the written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. 

     

     






  • 11.  RE: EUDAMED UDI entry

    This message was posted by a user wishing to remain anonymous
    Posted 15-Sep-2022 09:11
    This message was posted by a user wishing to remain anonymous

    Thank you Richard, it appears to be that self-declared IVDD devices are registered in EUDAMED the same way as any other legacy device. However, we will wait until we get a final confirmation.

    Thanks again




  • 12.  RE: EUDAMED UDI entry

    This message was posted by a user wishing to remain anonymous
    Posted 15-Sep-2022 09:12
    This message was posted by a user wishing to remain anonymous

    Hi,

    For some reason it is taking quite a long time for my messages to be posted.

    Thank you Richard once again for sharing your wisdom.



  • 13.  RE: EUDAMED UDI entry

    Posted 15-Sep-2022 14:02
    With the B- UDI addition do we need to update our product labeling with the B- prefix?

    ------------------------------
    Edward Panek
    VP, QA/RA
    Med Device
    USN Veteran
    Research into Neural Nets - https://www.twitch.tv/edosani
    ------------------------------



  • 14.  RE: EUDAMED UDI entry

    Posted 15-Sep-2022 14:57
    Edited by Richard Houlihan 15-Sep-2022 15:08
    No no no, definitely not. The B- is only for EUDAMED, this is effectively a fake basic udi but again it is only for EUDAMED not for labels etc.
    Best regards,
    Richard Houlihan