Focus on Medical Devices

In Vitro Diagnostic Medical Devices
(IVD MD)

Since December 7, 2003, in vitro diagnostic medical devices (IVD medical devices) have been regulated under Directive 98/79/EC for access to the European market. However, Regulation (EU) 2017/746, also known as the IVDR, introduced major changes for manufacturers, distributors, and other stakeholders in the IVD market. The IVDR became mandatory on May 26, 2022. As a result, manufacturers must now meet stricter requirements for IVD medical device certification, conformity assessment, compliance, and market placement in the European Union.

Under Directive 98/79/EC

What is an in vitro diagnostic medical device (IVDMD)?

Directive 98/79/EC, Article 1, defines an in vitro diagnostic medical device (IVDMD) as any medical device used alone or in combination. This includes reagents, reagent products, calibrators, control materials, kits, instruments, apparatus, equipment, and systems.

These devices are intended by the manufacturer for in vitro examination of specimens taken from the human body, including blood and tissue donations. They are used mainly to provide information about:

– a physiological state or pathological state
– a congenital abnormality
– the safety and compatibility of potential recipients
– the monitoring of therapeutic measures

Directive 98/79/EC also applies to IVD accessories. These accessories are treated as in vitro diagnostic medical devices in their own right. In addition, the Directive covers self-testing devices, specimen receptacles, and devices for performance evaluation.

Manufacturer responsibilities

The manufacturer is legally responsible for placing a compliant device on the market. To do this, the manufacturer must ensure that the IVDMD meets the essential requirements listed in Annex I of the Directive.

Before placing the device on the European market, the manufacturer must also:

– affix the CE marking
– draw up an EC declaration of conformity
– If the manufacturer is located outside Europe, it must appoint an Authorized Representative. This representative must be established within the European Union.

Notified body involvement

A notified body must participate for the devices listed in Annex II of Directive 98/79/EC. This requirement also applies to self-testing devices, regardless of their intended purpose.

IVDMD classification under Directive 98/79/EC
IVDMD classification is set out in Annex II, which includes List A and List B.

Annex II, List A includes devices that present a high risk to public health and to the patient.
Annex II, List B includes devices that present a moderate risk to public health and a high risk to the patient.
Examples of device types and classification

Annex II, List A:

– devices for screening
– devices for determining ABO blood group, rhesus factor, and anti-Kell blood types
– devices for detecting markers of HIV infection, HTLV, and hepatitis B, C, and D

Annex II, List B:

– devices for detecting congenital infections such as rubella and toxoplasmosis
– devices for diagnosing hereditary disease such as phenylketonuria
– devices for determining human cytomegalovirus and chlamydia infections
self-testing devices for measuring blood sugar

GMED as a notified body

GMED is a notified body under Directive 98/79/EC and Regulation (EU) 2017/746. It is registered under number 0459.

The scope of GMED’s notification is available on the European Commission’s NANDO database: New Approach Notified and Designated Organisations.

IVDR Notified Body for Regulation (EU) 2017/746

Regulatory changes for IVD medical devices

The regulatory changes for in vitro diagnostic medical devices (IVDMDs) have a major impact on manufacturers. In addition, they create new obligations for economic operators, IVDR notified bodies, Member States, and the European Commission.

These changes are set out in Regulation (EU) 2017/746. The Regulation was published in 2017 and became mandatory on May 26, 2022, for placing in vitro diagnostic medical devices on the European Union market.

The recent IVDR extension 2024/1860 also affects the transition timeline for certain devices. As a result, manufacturers must follow the current IVDR requirements carefully.

Impact on manufacturers

Nearly 80% of IVDMD manufacturers will need an IVDR notified body for IVDR certification and CE marking. This is a major increase compared with the previous directive for in vitro diagnostics.

Therefore, manufacturers and economic operators must understand the certification process. They must also know their regulatory obligations and the role of IVDR training.

Wider definition under the IVDR

One of the most important changes is the wider definition of in vitro diagnostic medical devices under Article 2 of Regulation (EU) 2017/746.

The definition now includes:

– software devices
– predisposition to a medical condition or disease
– prediction of treatment response

Definition under Article 2

An in vitro diagnostic medical device is any medical device, such as a reagent, reagent product, calibrator, control material, kit, instrument, apparatus, piece of equipment, software, or system. It may be used alone or in combination.

The manufacturer intends it for in vitro examination of specimens from the human body, including blood and tissue donations. It must provide information about one or more of the following:

– a physiological or pathological process or state
– congenital physical or mental impairments
– predisposition to a medical condition or disease
– safety and compatibility with potential recipients
– prediction of treatment response or reactions
– definition or monitoring of therapeutic measures

The Regulation also covers:

– specimen receptacles
– accessories
– self-testing devices
– devices used for services offered to lay persons
– near-patient testing devices
– companion diagnostics

New manufacturer obligations

The IVDR introduces several new obligations for manufacturers. For example, under the IVDR extension 2024/1860, manufacturers must appoint a person responsible for regulatory compliance.

In addition, the Regulation introduces joint liability for the Authorized Representative in the event of defective devices. It also sets out more detailed responsibilities for distributors and importers.

Risk-based classification

The IVDR uses a risk-based classification system. It is based on the seven rules in Annex VIII. The Regulation defines four classes of IVDMDs, from Class A to Class D.

Class A = low risk
Class D = high risk

A notified body is required for:

Class D devices
Class C devices
Class B devices
sterile Class A devices
self-testing devices
near-patient testing devices
companion diagnostics

Examples of classification

Class D: HIV screening for blood donations
Class C: HLA typing, blood sugar self-testing
Class B: antinuclear antibodies, pregnancy self-testing
Class A: specimen receptacles

Clinical evidence and performance evaluation

Manufacturers must document clinical evidence in a performance evaluation report for IVDR certification. This report must include:

– scientific validity
– analytical performance
– clinical performance

This evaluation helps show that the device meets the required standards. It also supports the overall evidence needed for compliance.

Ongoing compliance

The IVDR also requires continuous performance evaluation. This process helps ensure ongoing safety and performance.

Manufacturers must regularly reassess clinical evidence. They must use data from:

– post-market surveillance
– post-market performance follow-up (PMPF)

Therefore, regular review is essential. Manufacturers must also keep up with IVDR training, regulatory requirements, and certification obligations.

FAQ

1.What does IVDR mean?

IVDR stands for In Vitro Diagnostic Regulation, specifically Regulation (EU) 2017/746. This European regulation governs in vitro diagnostic medical devices and has been mandatory since May 26, 2022. It replaced the previous Directive 98/79/EC.

2.What is the difference between IVD and IVDR?

IVD (In Vitro Diagnostics) refers to the medical devices themselves, which companies use to examine human body specimens outside the body. The IVDR (In Vitro Diagnostic Regulation) sets the European regulatory framework and governs how companies certify, manufacture, and place these devices on the market.

3.What is an IVDR certificate?

A notified body issues an IVDR certificate as an official document confirming that an in vitro diagnostic medical device meets the requirements of Regulation (EU) 2017/746. Manufacturers need this certificate for Class B, C, and D devices, sterile Class A devices, self-testing devices, near-patient testing devices, and companion diagnostics to obtain CE marking.

4.What is the difference between IVDR and MDR?

IVDR (Regulation EU 2017/746) covers in vitro diagnostic medical devices that you use to examine specimens outside the human body, such as blood tests and diagnostic kits. By contrast, MDR (Regulation EU 2017/745) covers other medical devices that interact with the human body or that you use on it, such as implants, surgical instruments, and imaging equipment. Although both regulations share similar principles, they apply different classification systems and requirements.

5.When is a notified body required for IVDR certification?

Under IVDR, manufacturers must work with a notified body for Class D, Class C, and Class B devices, as well as sterile Class A devices, self-testing devices, near-patient testing devices, and companion diagnostics. As a result, this requirement affects approximately 80% of IVDMD manufacturers, which is four times more than under the previous Directive.

6.How are IVD medical devices classified under IVDR?

IVDR uses a risk-based classification with four classes: Class D (highest risk, e.g., HIV screening for blood donations), Class C (e.g., HLA typing, blood sugar self-testing), Class B (e.g., antinuclear antibodies, pregnancy self-testing), and Class A (lowest risk, e.g., specimen receptacles).

7.Why choose GMED for IVDR certification?

GMED is a notified body under both Directive 98/79/EC and Regulation (EU) 2017/746 (number 0459). Our multidisciplinary team provides expertise across all device categories, offering integrated certification, CE marking, and quality management system assessments backed by the LNE Group.

Why choose GMED?

GMED is a leading notified body that supports medical device manufacturers worldwide with regulatory certification, CE marking, and quality management system assessments. Our multidisciplinary team helps manufacturers meet the latest regulatory requirements. We also provide expertise for all device categories, including innovative products and high-risk medical devices.

Backed by the LNE Group, GMED offers integrated certification and testing services throughout the product lifecycle, from design to market placement. In addition, we actively follow regulatory developments and standardization work. This helps ensure that your devices meet current safety and performance requirements.

Learn more about GMED’s certification process and capabilities.

CE Marking

GMED is a well-known notified body thanks to its experience and state of the art knowledge of all types of medical devices including high-risk and innovative devices.

MDSAP Certification

IVD manufacturers can achieve multi-market access through MDSAP certification, gaining recognized compliance across five major regulatory jurisdictions with a single audit process.