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.
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Erica Conway
Vice President, IVD Regulatory Affairs - Europe
MCRA UK
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Original Message:
Sent: 13-Sep-2022 01:42
From: Richard Houlihan
Subject: EUDAMED UDI entry
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
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@eudamed.com
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EirMed Ltd
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Brussels, Belgium | Sofia, Bulgaria
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t: +359 2 492 8458
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e: richard.houlihan@eudamed.com
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EudaMed.com
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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.
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Original Message:
Sent: 9/12/2022 7:26:00 AM
From: Anonymous Member
Subject: RE: EUDAMED UDI entry
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,
Original Message:
Sent: 12-Sep-2022 02:01
From: Richard Houlihan
Subject: EUDAMED UDI entry
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
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@eudamed.com
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EirMed Ltd
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Brussels, Belgium | Sofia, Bulgaria
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t: +359 2 492 8458
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e: richard.houlihan@eudamed.com
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|
EudaMed.com
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|
|
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.
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Original Message:
Sent: 9/9/2022 11:45:00 PM
From: Anonymous Member
Subject: RE: EUDAMED UDI entry
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.
Original Message:
Sent: 09-Sep-2022 06:17
From: Anonymous Member
Subject: EUDAMED UDI entry
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