A Q&A document was published outlining the practical aspects of the gradual roll-out of EUDAMED pursuant to the MDR and IVDR (as amended by Regulation (EU) 2024/1860 amending Regulations (EU) 2017/745 and (EU) 2017/746). The document contains Q&A for clarification of each module in EUDAMED, providing clear instructions on the obligations of users and potential users of the database.
EUDAMED Q&A Document Key Takeaways:
-
- Article 34 MDR amended by Regulation 2024/1860 allows gradual roll-out of EUDAMED: MDCG will be informed when the functionality of a module following independent audit (s). This phased approach aims to ensure a smoother implementation and transition for stakeholders.
- Transition periods for mandatory use of Actor: UDI/DEV modules is 6 months after the publication in the OJEU of the notice confirming that the module(s) is functional.
- Explanation of how to register as an Actor in the Actor Module which is now voluntary in EUDAMED: It is recommended for manufacturers, importers, authorized representatives and SPPP’s to register without delay.
- Clarification of the mandatory use of UDI/DEV module for legacy devices and MDR approved devices: Custom-made devices, investigational devices and devices for performance studies are exempt from registration in the UDI/DEV module. It is advised to register devices and SPP’s as soon as possible.
- The Vigilance module will be released when it becomes mandatory and must be used straight away: Manufacturers and Authorized representatives will be required to submit PSUR’s and vigilance reports in EUDAMED as soon as the module is available with no voluntary use or transitional timeline.
As a Manufacturer, What Should I Do Now?
-
- Register in EUDAMED and obtain the Single Registration Number (SRN).
-
- Register applicable devices in the UDI/DEV module.
-
- Continue to report Vigilance according to MDCG 2021-Rev.1 and MDCG 2022-12.
-
- Check MDCG and OJEU for updates on transitional timelines and mandatory use of the individual modules.
_____________________________________________
With the gradual roll-out of EUDAMED, manufacturers and other stakeholders must stay proactive and informed. If you need guidance or support during this process, don’t hesitate to contact us for expert assistance.