GP-027 Product requirements for UK market
Purpose
Define the process and requirements for placing the CE-marked software as a medical device on the UK market in compliance with applicable UK regulations.
Scope
This procedure applies to activities related to registering the CE-marked software as a medical device in the UK and ensuring compliance with UK-specific requirements for post-market activities.
Definitions
- UK: United Kingdom
- MHRA: Medicines and Healthcare products Regulatory Agency
- FSCA: Field Safety Corrective Actions
- FSN: Field Safety Notice
Responsibilities
JD-005
Ensure legal compliance and regulatory compliance of the medical devices registered in UK.
JD-003
Organize and manage development resources to achieve compliance with requirements.
JD-004
Ensures compliance with UK-specific requirements and oversees the registration process.
JD-001
Approve the procedure and provide with the required resources to perform the activities described on it.
Inputs
- UK requirements for placing in the market CE-marked devices
- UK requirements for post-market activities
Outputs
- UK registration of CE-marked devices
- Compliance with applicable UK requirements
Development
According to changes to the Medical Device Regulation 2002
and the transition period timelines, manufacurers based outside the UK can place their CE-marked medical devices in the UK market when certain conditions are met:
- a valid CE mark is available for the device to be registered in the UK
- compliance with applicable requirements set out in the
EU Medical Device Directive (MDD) 93/42/EEC
or theEU Medical Device Regulation (MDR) 2017/745
- appointment of a UK authorised representative
- registration in the MHRA database
UK authorised representative
An authorised representative based in UK shall be appointed for all manufactures based outside the UK and a written agreement shall be in place.
The responsibilities of the UK authorised representative are established in the Medical Device Regulation 2002 and include the following:
- register the device with MHRA
- ensure that the declaration of conformity and technical documentation have been drawn up
- keep available a copy of the technical documentation, a copy of the declaration of conformity and, if applicable, a copy of the relevant certificate
- in response to a request from the MHRA, provide the MHRA with all the information and documentation necessary to demonstrate the conformity of a device
- communicate to the manufacturer any request from the MHRA to provide samples or access to the device, and communicate to the MHRA whether the manufacturer intends to comply with that request
- cooperate with the MHRA on any preventive or corrective action taken to eliminate or mitigate the risks posed by devices
- immediately inform the manufacturer about complaints and reports from healthcare professionals, patients and users about suspected incidents related to the device
Labeling requirements
UK Responsible Person details do not need to be included on labelling for CE marked devices, unless the device bears both the CE and UKCA markings.
CE mark validity timelines
Once registered with MHRA, the CE-marked device
- certified under
MDD 93/42/EEC
can be placed in the UK market until 30 June 2028 - certified under
MDR 2017/745
can be placed in the UK market until 30 June 2030
Vigilance activities
Once the medical device is registered with MHRA and it is placed in the market, we have the responsibility, together with our UK authorised representative, to notify MHRA of any adverse incidents and/or field safety corrective action.
Incidents and field safety corrective action will be notified to MHRA according to the timelines established in the sections below and they will be documented, investigated and addressed according to the requirements set out in the procedures GP-004 Vigilance system
, GP-006 Non-conformity, Corrective and Preventive actions
.
Criteria for incidents to be reported
Any event which meets all three reporting criteria below is considered an adverse incident and must be reported to the MHRA:
- an event has occurred. This includes situations where testing performed on the device, examination of the information supplied with the device, or any scientific information indicates some factor that could lead, or has led, to an event;
- the manufacturer's device is suspected to be a contributory cause of the incident;
- the event resulted in, or might have resulted, in death or a serious deterioration in state of health of a patient, user or other person
Timelines for reporting an adverse incident
The maximum permitted time between the manufacturer first becoming aware of the incident and notifying the MHRA are given below:
- Serious public health threat: No later than 2 calendar days after the manufacturer becomes aware
- Death or unanticipated serious deterioration in state of health: No later than 10 calendar days after the manufacturer becomes aware
- Others: No later than 30 calendar days after the manufacturer became aware
Field Safety Corrective Actions (FSCAs)
FSCAs are actions affecting devices already distributed and which are taken by a manufacturer in order to reduce the risk of death or serious deterioration in health.
FSCAs should always be communicated to all affected customers using a Field Safety Notice (FSN), see also the process described in the procedure SP-004-001 Product withdrawal
.
We should notify the MHRA of FSCAs using the FSCA Report Form and the notification should be made before or when the FSCA action is implemented in the UK.
More details about the FSCA process in the UK are provided in the dedicated guidance: Effective field safety notices (FSNs): guidance for manufacturers of medical devices.
Associated documents
GP-004 Vigilance system
SP-004-001 Product withdrawal
GP-006 Non-conformity, Corrective and Preventive actions
Signature meaning
The signatures for the approval process of this document can be found in the verified commits at the repository for the QMS. As a reference, the team members who are expected to participate in this document and their roles in the approval process, as defined in Annex I Responsibility Matrix
of the GP-001
, are:
- Author: Team members involved
- Reviewer: JD-003, JD-004
- Approver: JD-001