Section 4: Steps For a Successful EU MDR Implementation

1. Assign a dedicated team to oversee the MDR transition
2. Perform a gap assessment to determine the MDR impact on your existing product portfolio, quality management system (QMS), and internal resources:
   • Determine your responsibilities as an economic operator (i.e., manufacturer) under the new MDR
   • Confirm the classification of your devices. Do any of them require reclassification under the new regulation?
   • Determine if you will need to collect additional data to meet the new clinical evaluation and/or post-market surveillance requirements or conduct new clinical investigations
   • Identify any documentation or processes that need to be updated and/or added to your QMS and technical file
   • Review current supply chain activities and contracts. How will your supply chain be impacted by the new requirements? What changes are needed?
   • Assess time, resources, and costs that will need to be allocated to certifying your medical devices under the new regulation
   • Determine how the MDR compliance costs will impact your future revenue and return on investment (ROI)
3. Contact your respective notified body to gain an understanding of its MDR designation status. If it has not yet gained a designation, you may need to seek out a different notified body. If it is already designated, obtain some clarification regarding its scope of designation and timelines.
   • Does the scope of designation cover your entire product portfolio?
   • When will the notified body be ready to review your technical documentation?
   • How long will it take for the notified body to complete its review?
4. Formulate an MDR transition plan, timeline, and budget based on the findings from your gap assessment and notified body
5. Review the General Safety and Performance Requirements as outlined in Annex I of the MDR to determine the requirements that are applicable to your medical device
6. Develop and implement a risk management plan in accordance with ISO 14971
7. Plan and coordinate clinical investigations as needed
8. Establish your plan and processes for clinical evaluation and post-market clinical follow-up (PMCF)
9. Establish your plan and processes for post-market surveillance (PMS)
10. Ensure the proper labeling is in place for your medical device(s), including the creation of unique device identifiers (UDIs)
11. Access the EUDAMED database (Actor Registration Module) to register as an economic operator (e.g., manufacturer) and obtain a single registration number (SRN)
12. Ensure that the proper agreements between authorized representatives, importers, and distributors are in place
13. Update your technical file and QMS according to the new MDR requirements
14. Conduct company-wide training and involve key stakeholders in the MDR implementation and new QMS requirements. Build additional teams as needed.
15. Conduct a series of internal audits to verify that all requirements are met under the new MDR prior to your official inspection/recertification