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  • 1.  UK Responsible Person Labeling

    This message was posted by a user wishing to remain anonymous
    Posted 02-Feb-2023 09:20
    This message was posted by a user wishing to remain anonymous

    Hi all, 

    as you probably know. after 1 July 2024 we are required to re-label the medical devices for placemet them on Great Britatin market. UKCA mark with the number of the approved body is one of the label requirements.
    Additionaly, the UK-Rep Name and Address needs also to be indicated in the labeling. The UK Guidance is saying the following: 
    "However, the name and address of the UK Responsible Person, where applicable, needs to be included on product labelling or the outer packaging, or the instructions for use in cases where the UKCA marking has been affixed".

    So my question is, do UK-Rep data (name & address) have to be put on a product before leaving the country ? or is there an opportunity to affix an additional label locally by UK-REP?

    Thanks for your support.


  • 2.  RE: UK Responsible Person Labeling

    Posted 02-Feb-2023 09:37
    Hi,
    UK REP name and address is required to register the product on the database by the manufacturer or UK responsible person and is expected to be on the label when importing. The name and address of the UK Responsible Person, where applicable, must be included on the product labelling or the outer packaging, or the instructions for use in cases where the UKCA marking has been affixed.

    Thanks


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    Raje Devanathan
    Amerisource Bergen
    TPIreg, Innomar Strategies
    Senior Manager - Regulatory Affairs, Medical Devices
    rdevanathan@tpireg.com
    3470 Superior Court
    Oakville ON L6L0C4
    Canada
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  • 3.  RE: UK Responsible Person Labeling

    This message was posted by a user wishing to remain anonymous
    Posted 02-Feb-2023 11:01
    This message was posted by a user wishing to remain anonymous

    Hi Ran, 

    thanks a lot  for your input. You wrote that it is expected to have all data on the label when importing. Could you please advise if it can be just an extra small label next to the general one?

    Thank you.


  • 4.  RE: UK Responsible Person Labeling

    Posted 02-Feb-2023 19:18
    Great Britain's (GB's) revised UKCA and UKRP labeling requirements are linked to when the product is "placed on the market".  This may not coincide with "importing" the product.  Consequently, rather than linking the labeling requirement to the "importing" of the device, it is instead required that we carefully apply GB's actual designated language / criterion, which is "placing on the market".

    "Placing on the market" means the first making available of a device unit (not device type; not device model; but rather an individual device unit) for distribution, consumption or use on the GB market as part of a commercial activity. This can be in return for payment or free of charge. This happens after a product has been fully manufactured (i.e., labeled).  A product is placed on the market when an offer or agreement is made for the transfer of ownership, possession or any other property right. It does not require the physical transfer of the product.  Accordingly, if we focus our conformity target (be it regarding labeling or any other conformity requirement) on "importing" of the device, then we would not be in alignment with the MHRA's current nor its upcoming regulatory requirements.

    Moreover, historically, "placing on the market" hasn't been deemed to necessarily have happened upon the transfer of a device from a third country manufacturer outside GB to the manufacturer's own GB stocks/warehouse, nor to the third country manufacturer's GB authorized representative (i.e., now called the UKRP), and maybe even not to the GB importer, if the product is not yet being supplied for distribution, consumption or use.  In the MHRA's recent (June 2022) response to its public consultation about its proposed new regulations, I found nothing indicating that GB would alter this longstanding principle.

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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
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