Non conformities: how to answer them?

Published Date :
Tuesday, May 20, 2025
Tags :
Newsletter
Medical device
MDR
ISO 10993-1

Non conformities: how to answer them?

Daniele Lioi, Senior Consultant and Business Unit Manager,
Eurofins Medical Device Consulting, Italy.

Medical device manufacturers face diverse challengesin complying with the European Union Medical Devices Regulation (EU MDR 2017/745). The MDR aims to ensure high standards of quality, safety, and performance for medical devices, thereby safeguarding the health of patients and users. To access the European market, manufacturers must obtain the CE mark by fully complying with the regulation.

One primary challenge is navigating the evolving regulatory landscape, which includes meeting stringent product safety requirements, adhering to technical specifications, and maintaining a robust quality management system with extensive documentation. Transitioning from previous directives to the new MDR framework has proven particularly challenging: manufacturers encounter a lot of difficulties in ensuring complete submissions and maintaining updated certifications.

Incomplete documentation is a significant reason for submission rejections. For example, preclinical data must comply with ISO 10993-1, which mandates thorough biological evaluations. If degradation products are identified, a detailed toxicological risk assessment must be provided. Clinical documentation also presents challenges, as manufacturers must demonstrate device safety and performance across various patient populations with recent, comprehensive data.

Additionally, the MDR mandates the appointment of a “Person Responsible for Regulatory Compliance” (PRRC), who must have appropriate qualifications. Their role must be clearly defined in organisational documentation; failure to do so can hinder regulatory compliance.

It is of primary importance that MDR requirements and Medical Device Coordination Group guidelines are understood. Common pitfalls include insufficient preclinical, clinical, and quality documentation. Continuous training and regular updates are essential for manufacturers to remain compliant with evolving regulatory standards, and a proactive approach is crucial to navigating the complexities of the MDR and successfully bringing medical devices to market.