To the question about adding the UKCA symbol and UKRP:
If the device is UKCA marked, then you should have the information appropriately applied to your labeling, including updating your UK registration to note that the device is being marked on the basis of UKCA marking instead of CE Marking. Otherwise, if you plan to let your UKCA marking remain dormant, then you may want to confirm with your UK Approved Body and/or MHRA that it is acceptable to leave the UKCA marking symbol and other relevant information off your labeling and register and sell in Great Britain only referencing your CE marking. The UK's system currently allows for this confusion, so we would recommend confirming with them if UKCA marking supersedes CE marking, once obtained. And therefore, the registration should be updated to show the device is marketed on the basis of UKCA marking instead of CE Marking. Or, if the MHRA considers it the manufacturer's choice.
If you have registered your devices with the MHRA based on your CE-marking, and do not yet have UKCA marking, then you do not need to make any updates to the labeling, DoC, etc. And in fact, the UKCA symbol should not be used, since the device is not lawfully UKCA marked.
As mentioned above, UKCA marking has been pushed to July 2024, and the MHRA announced a further 3-5 year transition period will be granted for CE Marked devices. The MHRA announced it would also recognize the new extension to the MDR's transition period.
The MHRA has stated in a recent webinar, that they intend to release the transition arrangements earlier than the new regulation, sometime this spring. Here's the link to the webinar: https://www.youtube.com/watch?v=Px7SIk7bwzU and attached is the slide with the dates for release of the transitional arrangements, new PMS system and new medical device regulations.
So per the MHRA, CE marking is here to stay in the UK, for at least the next 5 years (shorter for MDD/AIMDD legacy devices). Though, we'll know the exact dates once the formal transitional provisions are released.
And, since the UK stated they plan to allow products from other well-reputed regulators, such as the US FDA, there will be more avenues for companies to market their devices aside from UKCA marking.
------------------------------
Sydney O'Connell
Director of Global Representation
www.casusconsulting.com
------------------------------
Original Message:
Sent: 25-Apr-2023 13:35
From: Anonymous Member
Subject: UKCA Marking Deadline
This message was posted by a user wishing to remain anonymous
Hi all,
I'm piggybacking on Arslan's post with a related question. Currently, the UKCA marking deadline is slated to be pushed back to June 2024. If a manufacturer has already obtained UKCA certification through a notified body, would this obligate the manufacturer to update their labeling to include the UKCA mark, UK responsible person, etc...or, would that manufacturer only be required to update their labeling by the expected June 2024 deadline?
Thanks!
Original Message:
Sent: 23-Apr-2023 14:49
From: Arslan Rahat
Subject: UKCA Marking Deadline
Could any one confirm me the deadline for UKCA marking.
As per my research, it was 1st July 2023. However, it is currently extended to 1st July 2024.
Could anyone confirm the date by providing reference from official website Medicines and Healthcare products Regulatory Agency - GOV.UK (www.gov.uk)
------------------------------
Arslan Rahat
QA Manager
Toronto ON
Canada
------------------------------