Sufficient Clinical Data

Confused about Sufficient Clinical Data as per MDR Article 61. If the manufacturer can demonstrate the device is safe and achieves the intended benefits via data evaluation, it means the data is sufficient.


Clinical data is all information related to the safety and performance of the device that is generated by using the device. This could be data from
  1. clinical investigations of the device under evaluation
  2. clinical investigation or other studies reported in the scientific literature of a similar device for which equivalence to the device in question can be demonstrated
  3. published and/or unpublished reports on other clinical experiences of either the device in question or a similar device for which equivalence to the device in question can be demonstrated.

To further explain sufficient clinical data defined as data related to the safety, performance and side effects of the medical devices as per its intended use from the clinical trials conducted on humans for the subject device, similar device or equivalent devices.
Sources of sufficient clinical data include

1. Published data
• Scientific Literature Database
• PDQ Evidence
• Google Scholar
• Clinical
• Prospero international prospective register of systematic reviews
• Manufacturer website

2. Non-published data
• Label and IFU
• Implant Registries information
• Data presented in Congresses

If there is no adequate justification and clinical data not deemed to require for the demonstration of conformity with the GSPR and product not coming under point 1.7.
As per clause 10, Justification should be based on the consideration of the specifics of the device and the human body interaction, the intended clinical performance, manufacturer’s claims and risk management results.
In this case post marketing studies or PMS given weightage for the devices that are already in market.