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Integral Drug-Device Combinations and Medical Device Regulation Article 117: The European Medicines Agency
Pascal Venneugues1,2, Christelle Bouygues3,4, Thomas Girard3,4
1European Medicines Agency, Domenico Scarlattilaan 6, 1083 HS, Amsterdam, The Netherlands. Pascal.Venneugues@ema.europa.eu.
Integral drug-device combinations (iDDCs) in the EU face complex regulations. Article 117 of the Medical Device Regulation (MDR) shifts device assessment to notified bodies, posing challenges for all stakeholders involved in iDDC approval.
Area of Science:
- Regulatory Science
- Pharmaceutical Medicine
- Medical Device Regulation
Background:
- Integral drug-device combinations (iDDCs) are regulated under EU medicinal product laws, requiring adherence to medical device framework requirements.
- The transition from the Medical Device Directive (MDD) to the Medical Device Regulation (MDR) introduced significant changes, particularly Article 117.
- Previously, the European Medicines Agency (EMA) and National Competent Authorities (NCAs) evaluated both the medicinal product and the device component.
Purpose of the Study:
- To outline the European Medicines Agency's (EMA) perspective on the implementation challenges of Article 117 of the MDR.
- To identify opportunities for addressing the complexities arising from the new regulatory framework for iDDCs.
- To enhance understanding and facilitate smoother regulatory processes for iDDCs.
Main Methods:
- Analysis of the regulatory shift introduced by Article 117 of the MDR concerning iDDC assessment.
- Review of the European Medicines Agency's (EMA) guidance and engagement activities to support stakeholders.
- Presentation of EMA's viewpoint on challenges and potential solutions for Article 117 implementation.
Main Results:
- Article 117 of the MDR designates notified bodies as responsible for assessing the integral medical device component against stringent General Safety and Performance Requirements (GSPRs).
- This shift has created regulatory complexities and challenges for the pharmaceutical industry, EMA, EU NCAs, and notified bodies.
- EMA has actively engaged in providing guidance and facilitating discussions to support implementation and mutual understanding.
Conclusions:
- The implementation of Article 117 necessitates a collaborative approach among all stakeholders to navigate the complexities of iDDC regulation.
- Addressing the identified challenges is crucial for strengthening regulatory oversight and increasing confidence in the iDDC regulatory system.
- Continued dialogue and shared experience are vital for the successful lifecycle management of integral drug-device combinations.
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