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Brexit and Notified bodies

MDR/EU related Posted on Feb 26, 2019 18:05:17

We get many questions about what to do if you have an UK Notified body. For the 4 that still are around we typical gives the following advice:

BSi – are good in communication, all customers have been urged to transfeer to BSi Netherlands, the only questions are if the have the capacity to deal with all activities!

For customers of the other 3 life is more troublesome!

LRQA- their dutch entity have not been notified for MDD (or MDR) why the likelhood to be able to transfeer all customers before a possible hard brexit is low even though they would get the notification in march.

UL- plans to start activities in Ireland, but have not been notified and currently status are unclear. With that the likelhood to meet deadline at a hard brexit are low and even meet a possible two month delay of a hard brexit that has been discussd today (26 of February

SGS – they have to NBs in Belgium and Finland but there have not been any information coming out from the UK office that they can transfeer to these. Rathercthe opposite customers have got letter saying they cannot transfeer, probably because of the more narrow scope for the other two locations.

Advice:

Build up stock at distributors, urgently look for an new NB (even though getting late) or hope for the best are common advices given! And frankly there are not that many options!
There are a process for companies that loose their NB, in Practise this means that you have 12 months to find a NB, but you need to contact the authority where you have your business if in EU, for e.g. US companies the process is unclear since the authority in UK would cease to exist!



FDA CDHR Learn

FDA/USA related Posted on Feb 26, 2019 08:03:01

FDA publish many guides but also training material online. They have several videos explaining the regulation and implementations but also PPt in all kind of subjects. At below link you find some of the material. A good starting point! Unfortunately they withdraw the gudie for small manufacturers with examples on how to meet QSR. This can howeveer be found at other placed.
https://www.fda.gov/training/cdrhlearn/?utm_source=Eloqua&utm_medium=email&utm_campaign=DICE%20Quarterly%20Newsletter%20-%20Vol.%201%20Issue%201



Brexit and EUs Q&A for medical device manufacturers

MDR/EU related Posted on Feb 26, 2019 07:54:46

1st of February 2019 the EU comission published

QUESTIONS AND ANSWERS RELATED TO THE UNITED KINGDOM’S WITHDRAWAL FROM THE EUROPEAN UNION WITH REGARD TO

INDUSTRIAL PRODUCTS. In practise this means a lot of problems for many many manufacturers, but in the end probably could effect patients.

UK based Notified Bodies will loose their notifications that day meaning that even though you are not a UK company but have Loyds UK, BSi UK, UL UK or SGS UK you cannot CE mark after that date. These 4 stands for about 35% of all product in EU!

Read more here:

https://ec.europa.eu/info/sites/info/files/qa_brexit_industrial_products_en.pdf