Time strategies
Medical device manufacturers can use four basic strategies for the transition:
Option 1 is required and/or recommended if you:
? Know your device is currently Class I self-certified, but will be NB-certified under the MDR
? Know your product is currently not considered a medical device, but will be an NB-certified device under the MDR
? Have sufficient clinical evidence for your device
? Have CE marking now and expect to make design changes in the next few years
? Are introducing a new device
Option 2 is recommended if you:
? Plan to introduce new devices between 2020 and 2022
? Have sufficient clinical evidence
? Follow Annex IV of the MDD or AIMDD
? Expect your Notified Body will remain active in medical devices
Option 3 is recommended if you:
? Have CE marking now but do NOT expect to make design changes in the next few years
? Need more time to gather clinical data needed for existing CE marked devices
? Don’t expect the classification of your device will change
? Are unsure whether you will be changing Notified Bodies
Option 4 is recommended if you:
? Need to transition a wide variety of devices and do not have internal bandwidth to tackle them all at once
? Have a mix of devices: some with excellent clinical evidence, and others that need more data
? Are introducing new products in the next few years and working on recertification of existing legacy devices