MDR Article 117 vs. GSPRs: Dates of Application
Few requirements in of the EU MDR [Regulation (EU) 745/2017] are as impactful as those related to single integral products combining a medicinal product part and a device part. For those products described in the second paragraph of Article 1(9) in particular, such as syringes and non-usable auto-injectors, the impact of the EU MDR is indeed massive. As the use of such integral products has become widespread for medicinal products, the new requirements pose a double challenge for Pharmaceutical companies: by May 26 2020, MAHs need to comply with the new General Safety and Performance Requirements of Annex I, and in addition they must get such products “cleared” by notified bodies for future applications to EMA.
Juan Martín Carriquiry
October 10, 2019