Regulatory Open Forum

 View Only
  • 1.  IFU language requirements in Canada

    Posted 23-May-2023 12:17

    Hello, 

    Our device has obtained approval in Canada, and we have received a few orders from there. Are there any language requirements for the Instructions for Use (IFU)? Do we need to translate the IFU into both English and French? Additionally, is an electronic version of the IFU acceptable (e-IFU)? Thank you for your assistance.
     
    Linda



  • 2.  RE: IFU language requirements in Canada

    Posted 23-May-2023 13:47
      |   view attached

    Hi Linda,

    Here is the relevant text from the CMDR regarding IFU language requirements:

    "...23 (1) Subject to subsection (3), the information required by subsection 21(1) shall, as a minimum, be in either English or French. (2) Subject to subsection (3), where the directions for use are supplied in only one official language at the time of sale, directions for use in the other official language shall be made available by the manufacturer as soon as possible at the request of the purchaser. (3) In respect of a medical device to be sold to the general public, the information required by paragraphs 21(1)(a) and (e) to (j) shall, as a minimum, be in both English and French..." [emphasis added]

    Here's a blog post addressing Health Canada's medical device e-labeling approach.  Although the Health Canada guidance document linked there may no longer be available on Health Canada's website (thus I've given it here in this thread for reference purposes), I haven't seen information from Health Canada to the contrary.



    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Canada, Europe, U.S.)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------

    Attachment(s)



  • 3.  RE: IFU language requirements in Canada

    Posted 23-May-2023 21:00

    Hi Kevin

    Health Canada's basic Guidance for the Labelling of Medical Devices now contains rules for e-labelling.



    ------------------------------
    Anne LeBlanc
    United States
    ------------------------------



  • 4.  RE: IFU language requirements in Canada

    Posted 23-May-2023 22:01

    Thank you Anne for your help which is always great. Please confirm if this is the guidance to which you refer.



    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Canada, Europe, U.S.)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------



  • 5.  RE: IFU language requirements in Canada

    Posted 24-May-2023 11:58

    Yes, it says:

    Section 21(2) - As it pertains to the electronic labelling (e-labelling) of certain medical devices not sold to the general public Health Canada considers e-labelling to refer to the information required by section 21(1) of the Regulations that would ordinarily be found in the directions for use. The directions for use may include a surgeon's instruction manual, operator's manual, or user's manual.

    For devices that are not sold to the general public, this information may be provided as downloadable from the internet and/ or on electronic data storage devices [for example (e.g.) compact disc, digital video disc, USB flash drive, etc.]. The electronic label or internet web address must accompany the device at the time of sale and/or delivery and be displayed in a manner that alerts the user to its purpose. The information provided electronically should be easily navigable. Manufacturers should ensure that the electronic label is identical in content to the paper format (where applicable) that is submitted with the device licence application. A sample Letter of Attestation is provided below. 

    Upon request, a paper copy of the label information should be provided as soon as possible to the user, at no additional cost. 



    ------------------------------
    Anne LeBlanc
    United States
    ------------------------------