Regulatory Open Forum

 View Only
  • 1.  Repackaging

    This message was posted by a user wishing to remain anonymous
    Posted 16-Feb-2024 09:08
    This message was posted by a user wishing to remain anonymous

    Dear All,

    Hope you are doing well! 

    In Medical Device Class III products, is it allowed to repack the product if the outer box is damaged according to EU MDR? If it is there any specific criteria to repack the product?



  • 2.  RE: Repackaging

    Posted 19-Feb-2024 04:47

    Anon,

    It highly depends on the product, how the outer box configuration with the device is made, and any impact to the safety and performance of the device.  There are quite a few activities which should be reviewed as part of a "repack" which includes reviewing the specific instance, reviewing this against the shipping/transport validation, understanding how and why it happened, risk involved with repacking the device, and defining whether this is acceptable.  At a minimum, there should be a non-conformity raised to understand how and why the outer box is damaged.  If this something which can happen, maybe there is a work instruction created for review, examination of the product, any inspection, and then the process for repacking.  You will not find anything specific to this in the EU MDR regulation, but there are many "in between the lines" contained in Annex I, General Safety and Performance Requirements, to ensure the product packaging is suitable and complete.



    ------------------------------
    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Principal Strategy Consultant
    NAMSA
    ------------------------------



  • 3.  RE: Repackaging

    Posted 23-Feb-2024 10:36

    Dear Anon,

    could you specify who is doing the repackaging? Is that something the manufacturer does before placing the device on the market because they realize that the outer box was damaged before or during packaging? Or does the device arrive with a damaged packaging at a supplier and they want to perform repackaging?

    Best regards, Christoph



    ------------------------------
    Christoph Kiesselbach
    Schrack & Partner
    Reutlingen
    Germany
    ------------------------------



  • 4.  RE: Repackaging

    Posted 24-Feb-2024 01:56

    Hi all

    I agree with Richard what he says below. It is only necessary to know that this change (repackaging)  is needed to consult / report to your notified body as well..



    ------------------------------
    Evangelos Tavandzis
    Lead Auditor, Consultant
    Praha
    Czech Republic
    ------------------------------