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IVDR CE Marking

Know the process of IVDR CE Marking and the Technical Documentation Process.

Medical Device Technical File

The Regulation 2017 / 745 Annex II, Medical Device Technical File is a summary document prepared by the manufacturer in a clear, well-organized, readily searchable, and unambiguous manner to demonstrate the safety and performance of the device in question. Depending upon the device’s construction and intended use the file should be decided.

The medical device technical file must be submitted to the notified body or competent authority for review and approval. It should preferably be made in the English language or the official language of an EU Member state. It must be available on request for the whole life cycle of the medical device (5 years for low-risk and 16 years for high-risk devices). Non-EU manufacturers must keep the file with the European Authorized Representative.

Irrespective of a medical device class, intended use, construction, and or safe history of the device, the manufacturer must have and keep up-to-date technical file to demonstrate compliance with GSPR Annex I of medical device regulation 2017/745. Medical device regulation has given specific requirements on what to include in your technical documentation. You can get more information from the below sections.

How to build a Medical Device Technical Documentation as per MDR 2017/745? We have the answer and the right team to do it for you.

MDR TECHNICAL DOCUMENTATION PRICING

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Medical Device Technical File Selection Criteria

Selecting the appropriate medical device technical file is crucial for ensuring regulatory compliance and product safety. Here are some key criteria to consider when selecting a file. Quality Assurance and Regulatory consulting team members are always confused or find it difficult to identify the required number of technical file for the products planned for European CE Marking.

It is advised to remember that the medical device technical file is all about your device to establish safety and performance. It means you cannot combine products with different intended uses, different classes, different construction materials, or even different designs.

Device Intended use and Indication of use
Site of application
Design change or major constructional changes
State of the art
EMDN / GMDN code

How to build a medical device technical file as per MDR 2017/745? We have the answer and the right team to do it for you.

MDR Technical Documentation GAP Analysis

Medical Device Technical File Consultants

The MDR imposes stringent and detailed requirements that are often more complex than previous Medical Device Directive (MDD). A knowledgeable consultant and their team understand these requirements in depth, ensuring that all necessary elements are included in the medical device technical file before submitting to a notified body. The other benefits in appointing a consultant are the following:

An experienced consultant team I3CGLOBAL can streamline the medical device technical documentation process, helping to avoid common pitfalls, reduce the time using premade templates and tools that can accelerate the preparation of technical file, ensuring notified body approval.
Specially trained persons from I3CGLOBAL ensuring that the risk management documentation is comprehensive and aligned with the requirements of ISO 14971 and MDR.
A dedicated team members from I3CGLOBAL assist in setting up effective PMS systems and ensuring that the PMS documentation is aligned with the overall medical device technical file
Trained clinical writers and clinical evaluators from I3CGLOBAL ensuring that the clinical evaluation report (CER) documentation is comprehensive and aligned with the requirements of MDR article 61 and Meddev 2.7.1 rev 4.

By appointing a team from I3CGLOBAL helps avoid certification delays, product recalls, or market withdrawal by ensuring right things done on right time. The most important benefit by outsourcing the medical device technical file to a I3CGLOBAL, manufacturers can optimize their internal resources, focusing on core competencies such as product development and innovation.

Certainly! For more information about our Medical Device Technical File Services and how we can assist you with technical documentation preparation, please feel free to contact us at your convenience.

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EU MDR Technical Documentation Types

Class I – Active Device, Non-Sterile with/without Software
Class I – Non-Active Device, Non-Sterile
Class I – Non-Active Device, Sterile / Measuring / Reusable
Class I – Active Device, Sterile / Measuring / Reusable
Class I – Software Device with or without Measuring Function
Class IIa – Active Device, Sterile / Non-Sterile / Measuring / Reusable /with/without Software
Class IIa – Non-Active Device, Sterile / Non-Sterile / Measuring / Reusable
Class IIa – Non-Active Device, Implant Sterile / Non-Sterile / Measuring / Reusable
Class IIa – Software Device, with or without Measuring Function
Class IIb – Active Device, Sterile / Non-Sterile / Measuring / Reusable with/without Software
Class IIb – Non-Active Device, Sterile / Non-Sterile / Measuring / Reusable
Class IIb – Non-Active Device, Implant Sterile / Nonsterile / Measuring / Reusable
Class IIb – Software Device, with or without Measuring Function
Class III – Active Device, Sterile / Non-Sterile / Measuring / Reusable with/without Software
Class III – Non-Active Device, Sterile / Non-Sterile / Measuring / Reusable
Class III – Non-Active Device, Implant Sterile / Non-Sterile / Measuring / Reusable
Class III – Active Device, Implant Sterile / Non-Sterile / Measuring / Reusable / with/without Software
Class III – Software Device, with or without Measuring Function
Special Rule – Class III – Devices incorporate medicinal products under Rule 14
Special Rule – Class IIa/IIb – Devices for contraception under rule 15
Special Rule – Class IIa/IIb – Disinfecting, cleaning or sterilizing devices under rule 16
Special Rule – Class III – Devices made using tissues/cells or their derivatives under rule 18
Special Rule – Class IIa/IIb/III – Nanomaterials under rule 19
Special Rule – Cass IIa/IIb – Devices for medicinal inhalation under rule 20
Special Rule – Class IIa/IIb/III – made of substances that are absorbed or locally dispersed rule 21

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Medical Device Technical File Selection based on Rule and Conformity Route

Below table explains how medical device technical file should be prepared based on class, rule and conformity assessment route.

#	TECHNICAL FILE TYPE	RULES APPLIED	CONFORMITY ROUTE
CLASS I MEDICAL DEVICE TECHNICAL FILE
1.	CLASS I Non-Invasive Device	Rule-1 All Non-Invasive device are classified as class I	Conformity Assessment Article 52 (7). Manufacturers of class I devices, other than custom-made or investigational devices, shall declare the conformity of their products by issuing the EU declaration of conformity referred to in Article 19 after drawing up the technical file set out in Annexes II and III. Notified Body involvement is not mandatory. CE mark could be affixed by self-Declaration
		Rule 2 – All non-invasive devices intended for channeling or storing blood, body liquids, cells or tissues, liquids or gases for the purpose of eventual infusion, administration or introduction into the body not connected to a class IIa, class IIb or class III active device; or not intended for use for channeling or storing blood or other body liquids or for storing organs, parts of organs or body cells and tissues are in class I
		Rule 4 – All non-invasive devices which come into contact with injured skin or mucous membrane if they are intended to be used as a mechanical barrier, for compression or for absorption of exudates.
2.	CLASS I Invasive Device	Rule 5 – All invasive devices with respect to body orifices, other than surgically invasive devices, which are not intended for connection to an active device or which are intended for connection to a class I active device are Class I if they are intended for transient use (Transient’ means normally intended for continuous use for less than 60 minutes.)
2.	CLASS I Invasive Device	Rule 5- Device used in the oral cavity as far as the pharynx, in an ear canal up to the ear drum or in the nasal cavity and are not liable to be absorbed by the mucous membrane
3.	CLASS I Active device	Rule 10 – Active devices intended to illuminate the patient’s body, in the visible spectrum, in which case they are classified as class I
		Rule 11- All other software is classified as class I, other than those mentioned under Class IIa, Class IIb, and Class III active device.
		Rule 13- All other active devices are classified as class I.
4.	Class I Sterile and Measuring Device	Article 52 (Point 7)	Conformity Assessment Article 52 (7). For Reusable Surgical Instruments the manufacturer shall apply CA as per the procedures set out in Chapters I and III of Annex IX, or in Part A of Annex XI. The involvement of the notified body in below cases: (a) in the case of devices placed on the market in sterile condition, to the aspects relating to establishing, securing and maintaining sterile conditions. (b) in the case of devices with a measuring function, to the aspects relating to the conformity of the devices with the metrological requirements. -For Sterile medical device CE marking, Notified-body involvement is mandatory, and device must comply with Quality Management System. – For Measuring device those are supplied in sterile condition require notified body certification, non-sterile device don’t require notified body involvement.
5.	CLASS I Surgical Invasive Device	Rule 6 – All surgically invasive devices intended for transient use are reusable surgical instruments	Conformity Assessment Article 52 (7). For Reusable Surgical Instruments the manufacturer shall apply CA as per the procedures set out in Chapters I and III of Annex IX, or in Part A of Annex XI. The involvement of the notified body in the case of reusable surgical instruments, to the aspects relating to the reuse of the device, cleaning, disinfection, sterilization, maintenance and functional testing and the related instructions for use.
	CLASS IIa MEDICAL DEVICE TECHNICAL FILE
6.	CLASS IIa Non-Invasive Device	Rule 2 – All non-invasive devices intended for channeling or storing blood, body liquids, cells or tissues, liquids or gases for the purpose of eventual infusion, administration or introduction into the body are classified as class IIa., if they are connected to a class IIa, Class IIb, or class III active device or if they are intended for use for channeling or storing blood or other body liquids or for storing organs, parts of organs or body cells and tissues are in Class IIa.	Conformity Assessment Article 52 (6). Manufacturers of class IIa devices, other than custom-made or investigational devices, shall be subject to a conformity assessment as specified in Chapters I and III of Annex IX, and including an assessment of the technical file as specified in Section 4 of that Annex of at least one representative device for each category of devices. OR The manufacturer may choose to draw up the technical documentation set out in Annexes II and III coupled with a conformity assessment as specified in Section 10 or Section 18 of Annex XI. The assessment of the technical documentation shall apply for at least one representative device for each category of devices. Declaration of Conformity with a Notified body assessment before affixing CE mark
		Rule 3-All non-invasive devices intended for modifying the biological or chemical composition of human tissues or cells, blood, other body liquids or other liquids intended, the treatment for which the device is used consists of filtration, centrifugation or exchanges of gas, heat
		Rule 4- All non-invasive devices which meet injured skin or mucous membrane if they are principally intended to manage the micro-environment of injured skin or mucous membrane
7.	CLASS IIa Invasive Device	Rule 5- All invasive devices with respect to body orifices, other than surgically invasive devices, which are not intended for connection to an active device or which are intended for connection to a class I active device are class IIa if they are intended for short-term use (Short term’ means normally intended for continuous use for between 60 minutes and 30 days)
		Rule -5 Device used in the oral cavity as far as the pharynx, in an ear canal up to the ear drum or in the nasal cavity and are not liable to be absorbed by the mucous membrane, in which case they are classified as class IIa
		Rule 5 -All invasive devices with respect to body orifices, other than surgically invasive devices that are intended for connection to a class IIa, class IIb or class III active device, are classified as class IIa.
8.	CLASS IIa Surgical Invasive Device	Rule 6- All surgically invasive devices intended for transient use are classified as class IIa
8.	CLASS IIa Surgical Invasive Device	Rule 7 – All surgically invasive devices intended for short-term use are classified as class IIa (Short term’ means normally intended for continuous use for between 60 minutes and 30 days)
9.	CLASS IIa Implantable device & Long Term Surgical Invasive Device	Rule 8- All implantable devices and long-term surgically invasive devices intended to be placed in the teeth.
10.	CLASS IIa Active Therapeutic Device	Rule 9- All active therapeutic devices intended to administer, or exchange energy are classified as class IIa
11.	CLASS IIa Active Device	Rule 10 – Active devices intended for diagnosis and monitoring are as class IIa Rule 10 Active devices if they are intended to supply energy which will be absorbed by the human body Rule 10 Active devices if they are intended to image in vivo distribution of radiopharmaceuticals. Rule 10 Active devices intended to allow direct diagnosis or monitoring of vital physiological processes
		Rule 11-Software intended to provide information which is used to take decisions with diagnosis or therapeutic purposes is class IIa, Rule 11- Software intended to monitor physiological processes is classified as class IIa
		Rule 12- All active devices intended to administer and/or remove medicinal products, body liquids or other substances to or from the body are classified as class IIa
12.	CLASS IIa Special Case	Rule 16- All devices intended specifically to be used for disinfecting or sterilizing medical devices are classified as class IIa
		Rule 17- Devices specifically intended for recording of diagnostic images generated by X-ray radiation are classified as class IIa
		Rule 19 – All devices incorporating or consisting of nanomaterial are class IIa if they present a negligible potential for internal exposure.
		Rule 20 – All invasive devices with respect to body orifices, other than surgically invasive devices, which are intended to administer medicinal products by inhalation are classified as class IIa
		Rule 21- Devices that are composed of substances or of combinations of substances that are intended to be introduced into the human body via a body orifice or applied to the skin and that are absorbed by or locally dispersed in the human body are classified as class IIa if they are applied to the skin or if they are applied in the nasal or oral cavity as far as the pharynx, and achieve their intended purpose on those cavities
	CLASS IIb MEDICAL DEVICE TECHNICAL FILE
13.	CLASS IIb Non-Invasive Device	Rule 2-Non-Invasive – Blood bags
		Rule 3 All non-invasive devices intended for modifying the biological or chemical composition of human tissues or cells, blood, other body liquids or other liquids intended for implantation or administration into the body are classified as class IIb	Conformity Assessment Article 52 (4). Manufacturers of class IIb devices, other than custom-made or investigational devices, shall be subject to a conformity assessment as specified in Chapters I and III of Annex IX, with assessment of the technical file as specified in Section 4 of that Annex of at least one representative device per generic device group OR The manufacturer may choose to apply a conformity assessment based on type examination as specified in Annex X coupled with a conformity assessment based on product conformity verification as specified in Annex XI. Article 61:-For all the class IIb devices referred to in point (b) of Article 54(1), the manufacturer may, prior to its clinical evaluation and/or investigation, consult an expert panel as referred to in Article 106, with the aim of reviewing the manufacturer’s intended clinical development strategy and proposals for clinical investigation. The manufacturer shall give due consideration to the views expressed by the expert panel. Conformity Assessments is required before affixing CE marking by Notified Body. Review of QMS implementation, technical file, Clinical Evaluation, Design review by notified body.
		Rule 4 All non-invasive devices which meet injured skin or mucous membrane if they are intended to be used principally for injuries to skin which have breached the dermis or mucous membrane and can only heal by secondary intent.
14.	CLASS IIb Invasive device	Rule 6- All invasive devices with respect to body orifices, other than surgically invasive devices, which are not intended for Connection to an active device or which are intended for connection to a class I active device are Class IIb if they are intended for long-term use (‘Long term’ means normally intended for continuous use for more than 30 days.)
15.	CLASS IIb Surgical Invasive device	Rule 6 All surgically invasive devices intended to supply energy in the form of ionizing radiation in which case they are classified as class IIb. Rule 6- All surgically invasive devices have a biological effect or are wholly or mainly absorbed are classified as class IIb Rule 6- All surgically invasive devices intended to administer medicinal products by means of a delivery system, if such administration of a medicinal product is done in a manner that is potentially hazardous taking account of the mode of application are class IIb.
15.	CLASS IIb Surgical Invasive device	Rule 7 – All surgically invasive devices intended to supply energy in the form of ionizing radiation Rule 7 – All surgically invasive devices intended to administer medicines, Rule 7 – All surgically invasive devices intended to undergo chemical change in the body, except if the devices are placed in the teeth
16.	CLASS IIb Active Therapeutic Device	Rule-9 All active therapeutic devices that they may administer energy to or exchange energy with the human body in a potentially hazardous way, taking account of the nature, the density and site of application of the energy are class IIb.
17.	CLASS IIb Active Device	Rule 9-All active devices intended to control or monitor the performance of active therapeutic class IIb devices or intended directly to influence the performance of such devices are classified as class IIb. Rule 9- All active devices intended to emit ionizing radiation for therapeutic purposes, including devices which control or monitor such devices, or which directly influence their performance, are classified as class IIb.
17.	CLASS IIb Active Device	Rule 10 – Active devices intended for monitoring of vital physiological parameters and the nature of variations of those parameters is such that it could result in immediate danger to the patient, for instance variations in cardiac performance, respiration, activity of the central nervous system, or they are intended for diagnosis in clinical situations where the patient is in immediate danger, in which cases they are classified as class IIb. Rule 10 – Active devices intended to emit ionizing radiation and intended for diagnostic or therapeutic radiology, including interventional radiology devices and devices which control or monitor such devices, or which directly influence their performance, are classified as class IIb.
		Rule 11- Software intended to provide information which is used to take decisions with diagnosis or therapeutic purposes that may impact a serious deterioration of a person’s state of health or a surgical intervention, it is classified as class IIb. Rule 11- Software intended for monitoring of vital physiological parameters, where the nature of variations of those parameters is such that it could result in immediate danger to the patient, in which case it is classified as class IIb.
		Rule 12- All active devices intended to administer and/or remove medicinal products, body liquids or other substances to or from the body that is potentially hazardous, taking account of the nature of the substances involved, of the part of the body concerned and of the mode of application in which case they are classified as class IIb.
18.	CLASS IIb Special Rules	Rule 15- All devices used for contraception or prevention of the transmission of sexually transmitted diseases are classified as class IIb.
		Rule 16- All devices intended specifically to be used for disinfecting, cleaning, rinsing or, where appropriate, hydrating contact lenses are classified as class IIb. Rule 16- disinfecting solutions or washer-disinfectors intended specifically to be used for disinfecting invasive devices, as the end point of processing, in which case they are classified as class IIb.
		Rule 19 – All devices incorporating or consisting of nanomaterial if they present a low potential for internal exposure.
		Rule 20 – All invasive devices with respect to body orifices, other than surgically invasive devices, which are intended to administer medicinal products by inhalation, unless their mode of action has an essential impact on the efficacy and safety of the administered medicinal product or they are intended to treat life- threatening conditions, are classified as class IIb.
		Rule 21- Devices that are composed of substances or of combinations of substances that are intended to be introduced into the human body via a body orifice or applied to the skin and that are absorbed by or locally dispersed in the human body are classified as class IIb in all other cases except then those specified in Class III, Class IIA Special case.
19.	CLASS IIb Implantable device & Long Term Surgical Invasive Device	Rule 8- All implantable devices and long-term surgically invasive devices are classified as class IIb (‘Long term’ means normally intended for continuous use for more than 30 days.)	Conformity Assessment Article 52 (4). For class IIb implantable devices, except sutures, staples, dental fillings, dental braces, tooth crowns, screws, wedges, plates, wires, pins, clips and connectors, the assessment of the technical file as specified in Section 4 of Annex IX shall apply for every device.
	CLASS III MEDICAL DEVICE TECHNICAL FILE
20.	CLASS III- Non-Invasive Device	Rule 3- All non-invasive devices consisting of a substance, or a mixture of substances intended to be used in vitro in direct contact with human cells, tissues or organs taken from the human body or used in vitro with human embryos before their implantation or administration into the body.	Conformity Assessment: – Article 52 (3) Manufacturers of class III devices, other than custom-made or investigational devices, shall be subject to a conformity assessment as specified in Annex IX. Alternatively, the manufacturer may choose to apply a conformity assessment as specified in Annex X coupled with a conformity assessment as specified in Annex XI. Notified body review device design, technical file as per Annex II before affixing CE logo. For Rule 14: In addition to above CA Article 52 (3), Procedure specified in Section 5.2 of Annex IX or Section 6 of Annex X shall also be applicable. For Rule 18:- In addition to above CA Article 52 (3), Procedure specified in Section 5.3 of Annex IX or Section 6 of Annex X shall also be applicable. Article 61(2)- For all class III devices referred to in point (b) of Article 54(1), the manufacturer may, prior to its clinical evaluation and/or investigation, consult an expert panel as referred to in Article 106, with the aim of reviewing the manufacturer’s intended clinical development strategy and proposals for clinical investigation. The manufacturer shall give due consideration to the views expressed by the expert panel.
21.	CLASS III Surgical Invasive Device	Rule 6- All surgically invasive devices are intended specifically to control, diagnose, monitor or correct a defect of the heart or of the central circulatory system through direct contact with those parts of the body, in which case they are classified as class III Rule 6- All surgically invasive devices are intended specifically for use in direct contact with the heart or central circulatory system or the central nervous system, in which case they are classified as class III.
21.	CLASS III Surgical Invasive Device	Rule 7 – All surgically invasive devices intended specifically to control, diagnose, monitor or correct a defect of the heart or of the central circulatory system through direct contact with those parts of the body. Rule 7 – All surgically invasive devices intended specifically for use in direct contact with the heart or central circulatory system or the central nervous system Rule 7 – All surgically invasive devices having a biological effect or are wholly or mainly absorbed are classified as class III
22.	Class III Implantable device & Long Term Surgical Invasive Device	Rule 8 – All implantable devices and long-term surgically invasive devices are class III if: 1) intended to be used in direct contact with the heart, the central circulatory system or the central nervous system 2) have a biological effect or are wholly or mainly absorbed 3) are intended to undergo chemical change in the body, except if the devices are placed in the teeth. 4) are intended to administer medicinal products, 5) are active implantable devices or their accessories 6) are breast implants or surgical meshes, 7) are total or partial joint replacements, with the exception of ancillary components such as screws, wedges, plates and instruments 8) are spinal disc replacement implants or are implantable devices that meet the spinal column, with the exception of components such as screws, wedges, plates and instruments.
23.	Class III Active Device	Rule 9- All active devices that are intended for controlling, monitoring or directly influencing the performance of active implantable devices are classified as class III.
23.	Class III Active Device	Rule 11-Software intended to provide information which is used to take decisions with diagnosis or therapeutic purposes have an impact that may cause death or an irreversible deterioration of a person’s state of health, in which case it is in class III;
24.	Class III Special Rules	Rule 14-. All devices incorporating, as an integral part, a substance which, if used separately, can be considered to be a medicinal product, including a medicinal product derived from human blood or human plasma, and that has an action ancillary to that of the devices, are classified as class III.
		Rule 15 – Devices used for contraception or prevention of the transmission of sexually transmitted diseases that are implantable or long-term invasive devices are classified as class III.
		Rule 18 – All devices manufactured utilizing tissues or cells of human or animal origin, or their derivatives, which are non- viable or rendered non-viable, are classified as class III unless devices intended to come into contact with intact skin only.
		Rule 19 – All devices incorporating or consisting of nanomaterial if they present a high or medium potential for internal exposure.
		Rule 21- Devices that are composed of substances or of combinations of substances that are intended to be introduced into the human body via a body orifice or applied to the skin and that are absorbed by or locally dispersed in the human body are class III if they, or their products of metabolism, are systemically absorbed by the human body in order to achieve the intended purpose. Rule 21- Devices that are composed of substances or of combinations of substances that are intended to be introduced into the human body via a body orifice or applied to the skin and that are absorbed by or locally dispersed in the human body are class III if they achieve their intended purpose in the stomach or lower gastrointestinal tract and they, or their products of metabolism, are systemically absorbed by the human body;
		Rule 22- Active therapeutic devices with an integrated or incorporated diagnostic function which significantly determines the patient management by the device, such as closed loop systems or automated external defibrillators, are class III.
25.	Systems and procedure packs	Article 22 Systems: – ‘system’ means a combination of products, either packaged together or not, which are intended to be inter- connected or combined to achieve a specific medical purpose. Procedure Packs: – ‘procedure pack’ means a combination of products packaged together and placed on the market with the purpose of being used for a specific medical purpose.
		Para1. Natural or legal persons shall draw up a statement if they combine devices bearing a CE marking with the following other devices or products, in a manner that is compatible with the intended purpose of the devices or other products and within the limits of use specified by their manufacturers, in order to place them on the market as a system or procedure pack: (a) other devices bearing the CE marking. (b) in vitro diagnostic medical devices bearing the CE marking in conformity with Regulation (EU) 2017/746. (c) other products which are in conformity with legislation that applies to those products only where they are used within a medical procedure or their presence in the system or procedure pack is otherwise justified.	Para 2: In the statement made pursuant to paragraph 1, the natural or legal person concerned shall declare that: (a) they verified the mutual compatibility of the devices and, if applicable other products, in accordance with the manufacturers’ instructions and have carried out their activities in accordance with those instructions. (b) they packaged the system or procedure pack and supplied relevant information to users incorporating the information to be supplied by the manufacturers of the devices or other products which have been put together. (c) the activity of combining devices and, if applicable, other products as a system or procedure pack was subject to appropriate methods of internal monitoring, verification and validation. Article shall be kept at the disposal of the competent authorities, after the system or procedure pack has been put together, for the period that is applicable under Article 10(8) to the devices that have been combined. Where those periods differ, the longest period shall apply. The systems or procedure packs referred to in paragraph 1 of this Article shall not themselves bear an additional CE marking but they shall bear the name, registered trade name or registered trade mark of the person referred to in paragraphs 1 and 3 of this Article as well as the address at which that person can be contacted, so that the person’s location can be established.
		Para 3: – Any natural or legal person who sterilizes systems or procedure packs referred to in paragraph 1 for the purpose of placing them in the market shall,	At their choice, apply one of the procedures set out in Annex IX or the procedure set out in Part A of Annex XI. The application of those procedures and the involvement of the notified body shall be limited to the aspects of the procedure relating to ensuring sterility until the sterile packaging is opened or damaged. The natural or legal person shall draw up a statement declaring that sterilization has been carried out in accordance with the manufacturer’s instructions
		Para4:-Where the system or procedure pack incorporates devices which do not bear the CE marking or where the chosen combination of devices is not compatible in view of their original intended purpose, or where the sterilizations has not been carried out in accordance with the manufacturer’s instructions.	The system or procedure pack shall be treated as a device and shall be subject to the relevant conformity assessment procedure pursuant to Article 52. The natural or legal person shall assume the obligations incumbent on manufacturers.
26.	Custom Made Device	ANNEX XIII of EU MDR 2017/745	Authorized representative shall draw up a statement specified in section 1 of Annex XIII Conformity Assessment: – Article 52 (8) Manufacturers of class III custom-made implantable devices shall be subject to the conformity assessment as specified in Chapter I of Annex IX. Alternatively, the manufacturer may choose to apply a conformity assessment as specified in Part A of Annex XI.
27.	Investigational devices	Follow requirements set out in Article 62 to 81

Frequently Asked Questions

How long must MDR technical file be retained?

All CE certified manufacturers must maintain the latest versions and obsolete versions of medical device technical file for at least 10 years after the last device has been placed on the market. For implantable devices, this period extends to 15 years.

Can electronic formats be used for technical file storage?

Yes, electronic formats are acceptable for medical device technical file as long as they are secure, easily accessible, and can be provided to Notified Bodies or regulatory authorities upon request.

What is the role of Notified Bodies in reviewing medical device technical file?

Notified Bodies are independent organizations designated by the EU to assess the conformity of medical devices. They review the technical file as part of the conformity assessment process to ensure the device meets MDR requirements before it can be placed on the market.

Who is responsible for maintaining the Technical File?

The manufacturer of the medical device is primarily responsible for creating and maintaining the MDR technical file, generally called PRRC. For imported devices, the authorized representative in the EU have responsibilities in ensuring the documentation is compliant.

What are the requirements for Clinical Evaluation Reports in the MDR Technical File?

The CER must demonstrate the clinical safety and performance of the device. It should include clinical data from pre-market and post-market surveillance, and a thorough literature review.

How often must the medical device technical file be updated?

Medical device technical file should be maintained throughout the lifecycle of the device and updated regularly, especially when there are changes to the device, manufacturing processes, or when new safety information becomes available. Post-market surveillance activities also require ongoing updates.

What is the estimated timeframe for preparing an MDR Technical File?

Generally, with the cooperation of the manufacturer, it may take 3-4 months for class IIa and below risk class devices and others will take more than 5-6 months.

Do you provide CER Documentation service along with medical device Technical File?

Yes, we provide clinical evaluation report documentation as per MDR article 61 and MEDDEV 2.7.1 REV 4

What are the key components of Technical File?

The medical device technical file should include the following key topics:

- Device description and intended use
- Design and manufacturing information
- Risk management plan and report
- Clinical evaluation report (CER)
- Biocompatibility and safety test reports
- Verification and validation data
- Labeling and instructions for use
- Post-market surveillance plan
- Declaration of conformity (DOC)

What are the QMS procedures related to the medical device Technical File?

Quality Management System (QMS) procedures related to the Medical Device Regulation (MDR) are crucial for ensuring compliance with the technical file requirements. The following are important

Procedure for Device Classification
CE Marking Procedure
Labelling Procedure
Vigilance Procedure
Significant Change Notification Procedure
PRRC Appointment
Language Translation
Advisory Notice

What is the difference between MDD and MDR Technical Files?

The MDR requires more detailed and rigorous documentation compared to the Medical Device Directive (MDD). MDR introduces new requirements for clinical evaluation, post-market surveillance, post market clinical follow-up and risk management, as well as stricter conformity assessment procedures.