Europe’s MedTech Landscape in 2025: 38,000+ Companies Driving Innovation
Europe is home to one of the world’s most dynamic and diverse medical technology ecosystems, with more than 38,000 MedTech companies operating across the continent. The vast majority—over 90%—are small and medium-sized enterprises (SMEs), playing a critical role in driving innovation, improving healthcare outcomes, and fueling economic growth .
What Defines Europe’s MedTech Industry?
According to MedTech Europe, the sector includes manufacturers of medical devices, in vitro diagnostics (IVDs), and digital health solutions, spanning everything from surgical tools to AI-powered diagnostic platforms. In total, the industry employs over 930,000 people directly, making it one of the largest employers in Europe’s life sciences space .
Why It Matters for Clinical and Regulatory Success
With the growing complexity of EU MDR and IVDR regulations, these companies—especially SMEs—face increasing pressure to:
Prove clinical evidence and safety of their technologies
Navigate Notified Body reviews and CE Marking
Manage post-market surveillance (PMS) and performance evaluations
That’s where MDx CRO steps in.
Supporting Europe’s MedTech Growth
At MDx CRO, we specialize in helping MedTech innovators—from start-ups to established manufacturers—successfully plan, execute, and submit their clinical and regulatory strategies across the EU and global markets. With proven expertise in:
We partner with both large diagnostic leaders and agile SMEs to deliver compliant, high-quality, and market-ready solutions.
A Pan-European Presence
With offices in Barcelona, Madrid, Lisbon, and London, and a network of CRAs and regulatory experts across Europe, MDx provides localized insight with global reach—helping MedTech companies meet requirements faster and smarter.
The Bottom Line
The European MedTech sector is growing—but so are its regulatory challenges. Whether you’re launching a new diagnostic product or preparing for a Notified Body audit, MDx CRO is here to support your success every step of the way.
Let’s talk about your next clinical or regulatory challenge.
How many new medical devices are developed per year?
October 1, 2025
In the fast-moving world of MedTech, innovators often ask: how many new medical devices are developed per year? There isn’t a single global number, but we can triangulate it using patent trends, regulatory authorizations, and industry signals grounded in current, authoritative data.
Innovation Signals: Patent Filings
Patent activity is a reliable early indicator of device development. According to the European Patent Office (EPO), medical technology led all fields in 2020 with 14,295 applications, a 2.6% increase over 2019—a reminder of the sector’s deep innovation pipeline.
More recently, medical technology remains a leading technical field. The EPO Patent Index 2024 confirms medical technology as one of the most active categories for invention. Industry analysis also highlights ~15,700 MedTech applications in 2024 across Europe’s patent system, reflecting sustained growth (MedTech Europe DataHub).
From Idea to Market: Regulatory Authorizations
Patents show invention; regulatory authorizations show how many devices actually reach patients. In the U.S., the FDA’s Center for Devices and Radiological Health (CDRH) publishes device approvals under rigorous pathways such as PMA (FDA 2023 Device Approvals).
2023 was a record year for novel authorizations, with the FDA approving 124 new devices, excluding emergency use authorizations. (MedTech Dive | Fierce Biotech). The FDA’s official CDRH Annual Report 2024 (PDF) confirms that momentum continued, with 120 novel devices authorized in 2024, keeping approvals among the highest ever recorded.
These authorizations form the conservative baseline of what counts as truly new medical devices entering the market.
Estimating “New Device Development”
Taken together, patents and regulatory approvals show the spectrum of innovation. Patent filings in the tens of thousands capture early-stage ideas and prototypes, while hundreds of annual regulatory authorizations reflect devices that complete the journey to patient use.
Depending on definition—prototype, clinical trial initiation, clearance, or market launch—the best evidence-based answer is that hundreds of new medical devices are developed per year, supported by a much larger innovation pipeline still in progress.
Why These Numbers Matter
This activity carries important implications. Competition in MedTech is intense, with medical technology consistently leading global patent activity. Yet translation remains the bottleneck: many promising inventions never reach the market due to regulatory and clinical hurdles.
For innovators, success depends not just on invention but on execution. That means robust design, evidence-driven clinical research, proactive regulatory strategy, and strong post-market surveillance. At MDx CRO, we guide teams through this entire journey—helping promising concepts become compliant, market-ready devices.
Conclusion
So, how many new medical devices are developed per year? The most defensible conclusion is that hundreds of novel devices achieve authorization annually, supported by tens of thousands of upstream inventions captured in patent data.
The MedTech field remains one of the most dynamic and competitive arenas in global innovation. For developers, the opportunity has never been greater—but so too have the challenges. To succeed, innovators must match great ideas with great execution.
If you are developing a new device and want to navigate this journey with confidence, contact MDx CRO today.
ISO 13485 Implementation Guide: How to Stand Up a World-Class QMS (and Win Faster Market Access)
September 28, 2025
For MedTech and diagnostics companies, ISO 13485:2016 is the operating system for quality. It’s the globally recognized standard that regulators and notified bodies expect you to use to design, manufacture, and maintain safe, effective devices across the full lifecycle. Implement it well and you accelerate technical documentation, reduce rework, and shorten time-to-market. Implement it poorly and every audit, change, and submission becomes harder than it should be.
There’s an additional strategic reason to act now: the U.S. FDA’s Quality Management System Regulation (QMSR) formally converges 21 CFR 820 with ISO 13485:2016. The QMSR’s effective date is February 2, 2026, with a two-year transition from the legacy QS Reg—so a robust ISO 13485 QMS positions you for both EU and U.S. expectations. (QMSR overview PDF).
What ISO 13485 actually requires (and how to build it right)
At its core, ISO 13485 demands a documented, controlled set of interrelated processes that meet regulatory requirements for medical devices—from design and production to post-market activities. Success is not about templates; it’s about process architecture, risk-based decision-making, and evidence you can defend. (ISO 13485 handbook preview).
1) Map your process architecture
Start with a top-level map that shows how design & development, purchasing/supplier control, production & service provision, software validation (for QMS and process software), vigilance, and post-market processes interact. Keep ownership clear; keep inputs/outputs traceable.
2) Make risk management the backbone
ISO 13485 expects risk-based controls throughout realization and post-market feedback. Operationalize ISO 14971:2019 (and ISO/TR 24971 guidance) so hazards, risk controls, and residual risk tie directly into design inputs, verification/validation, and change control.
3) Design controls that satisfy NB and FDA reviewers
Build a single D&D framework that covers planning, inputs/outputs, reviews, verification, validation (including clinical/performance where applicable), transfer, and DHF/Design History File traceability. Link your design plans to intended purpose/indications so your technical documentation aligns with MDR/IVDR and (when applicable) FDA submissions.
4) Supplier & software rigor
Qualify and monitor critical suppliers with risk-based controls; embed incoming inspection and performance metrics. Validate QMS/production software proportional to risk and document configuration management so you can pass objective evidence reviews.
5) Document control that scales
Use a lean document hierarchy (policy → process → work instruction → form) and number it so auditors can navigate quickly. Automate change control and training effectiveness checks; link each controlled record to the process requirement it satisfies.
6) Post-market surveillance that drives improvement
Your PMS loop should systematically capture complaints, feedback, vigilance, field actions, and real-world performance. Close the loop with CAPA and management review using trend analysis and risk re-evaluation.
7) Internal audits and management review that add value
Audit for process performance (not just procedural conformance). Track effectiveness KPIs and feed them into management review alongside regulatory metrics (e.g., NB queries, submission outcomes, vigilance timelines).
EU alignment matters: harmonized EN ISO 13485 and MDR/IVDR
In Europe, EN ISO 13485:2016 (including A11:2021 and AC:2018) is recognized as a harmonized standard supporting MDR/IVDR requirements—useful for presumption of conformity where applicable. Aligning your QMS to the harmonized edition reduces friction in notified body assessments and surveillance.
Implementation roadmap (what works in the real world)
Phase 1 — Gap Assessment & Plan: Benchmark current practices against ISO 13485 clauses, ISO 14971 integration points, and your market strategy (EU MDR/IVDR, FDA QMSR). Produce a prioritized remediation plan with owners and dates.
Phase 2 — Process Build & Evidence: Draft/revise procedures; pilot them with one product line to generate real records (design plan, risk files, supplier files, software validation, training, internal audit).
Phase 3 — System Activation: Roll out across programs; execute internal audit cycle and management review with measurable outcomes.
Phase 4 — NB/FDA Readiness: Run a mock audit; fix systemic findings; align technical documentation index to QMS records; confirm personnel qualification and training effectiveness.
Avoid the top 5 pitfalls we see
Building dozens of procedures without a process map (auditors get lost; so do teams).
Treating risk management as a document, not a process that drives design and post-market decisions.
Weak supplier controls for critical components and software.
Software validation that stops at IQ/OQ and misses real-world configurations.
“One-and-done” internal audits that don’t test effectiveness or feed CAPA.
How MDx CRO makes ISO 13485 implementation faster (and audit-proof)
MDx CRO designs right-sized 13485 systems for MedTech and diagnostics teams—from first-time implementations to remediation before NB or FDA inspections. We build the process architecture, author and train on lean SOPs, integrate ISO 14971 risk into day-to-day decision-making, and generate submission-ready evidence. Then we run mock audits that mirror NB/FDA styles so you walk into the real thing prepared.
A Step-by-Step Guide to IEC 62366 and Usability Engineering
September 28, 2025
The usability of medical devices is not just a matter of convenience. It is a matter of safety, effectiveness, and regulatory compliance. Poor design that confuses or frustrates users can lead to use errors, adverse events, and even patient harm. To address this, the international standard IEC 62366-1:2015/Amd 1:2020 establishes a structured framework for usability engineering in medical device development.
For medical device manufacturers, understanding and applying IEC 62366 is essential. Compliance demonstrates that usability risks have been identified, reduced, and documented, which is essential for all medical devices including IVDsand Software as a Medical Device (SaMD).
What Is IEC 62366?
IEC 62366 is the internationally recognised standard that defines how to integrate usability into the design and development process.
It has two main parts:
IEC 62366-1:2015/Amd 1:2020 Medical devices – Application of usability engineering to medical devices: The core standard describing the usability engineering process.
IEC/TR 62366-2:2016Medical devices – Guidance on the application of usability engineering to medical devices: A technical report providing guidance and examples to support implementation.
The goal is to ensure that usability engineering is applied consistently so that devices can be used safely and effectively by intended users, in intended use environments, while ensuring that use errors that could lead to harm are identified, reduced, and controlled through structured usability activities.
Why Usability Engineering Matters
Use-related errors are a leading cause of device-related adverse events. By embedding usability engineering into product development, manufacturers can:
Reduce use errors that could lead to harm
Improve patient safety and treatment outcomes
Satisfy regulatory requirements from the MDR, IVDR, and FDA
Increase user acceptance and market success
Lower long-term costs by avoiding redesigns or recalls
In short, usability is both a compliance requirement and a competitive advantage.
Step-by-Step Guide to Applying IEC 62366
The usability engineering process defined in IEC 62366 is systematic and iterative. It integrates into the overall product development lifecycle and risk management process in line with ISO 14971. Below is a step-by-step breakdown.
1. Establish the Usability Engineering File (UEF)
The UEF is the central documentation repository for all usability activities. It includes intended use, user profiles, use scenarios, hazard analysis, test results, and risk control measures. In practice, the records and other documents that form the UEF may also form part of the product design file (ISO 13485) or the risk management file (ISO 14971).
Think of the UEF as both a project management tool and evidence for regulators.
2. User Research
Prepare the Use Specification. This is where you define:
The intended medical purpose of the device
The user groups (e.g. clinicians, patients, laypersons, caregivers)
The use environments (hospitals, homes, ambulances, clinics)
Any training or expertise required
This forms the foundation of all subsequent usability activities.
3. Analysis
Once you know who will use your device and where, the next step is to analyse how things could go wrong.
Activities include:
Identifying safety-related user interface characteristics (e.g. readability of displays, button layout, alarm visibility).
Reviewing post-production data and public databases for known usability issues with similar devices.
Identifying hazards and hazardous situations.
Identifying and describing hazard-related use scenarios, which describe exactly how use errors might occur and what consequences they could have.
Selecting hazard-related use scenarios for Summative Evaluation.
These scenarios are then prioritised to decide which will be evaluated in summative testing.
4. Design and Formative Evaluation
This is where design and usability testing happen in iterative cycles.
Key steps:
Establish the User Interface Specification – the blueprint of all UI elements.
Develop the User Interface Evaluation Plan – define how formative and summative testing will be performed.
Iterative cycles of concept, prototype, and testing
The point of formative evaluation is to find usability issues early, before final validation, so changes are cheaper and less disruptive.
5. Summative Evaluation
The final stage is a summative usability validation. This is a formal test that demonstrates to regulators that the device can be used safely and effectively by the intended users.
Test the hazard-related use scenarios identified earlier.
Use representative users in realistic environments.
Collect both objective performance data (task completion, error rates) and subjective feedback (ease of use, confidence).
Confirm that residual risks are acceptable in line with ISO 14971.
This stage provides the objective evidence regulators require to ensure compliance.
6. Maintain Usability Post-Market
Usability engineering does not end at product launch. Post-market surveillance should collect feedback on usability issues, adverse events, and complaints. Updates or design changes may be required if new risks emerge.
Common Challenges in Applying IEC 62366
Many manufacturers encounter difficulties such as:
Underestimating resources needed for usability testing
Recruiting representative users for formative and validation studies
Defining realistic use scenarios that reflect actual clinical environments
Integrating usability with development timelines
Documenting evidence properly in the UEF
Failing to address these challenges can result in regulatory rejection, delays, or costly redesigns.
Best Practices for Success
Start usability engineering early in the design process
Involve multidisciplinary teams including engineers, clinicians, and usability experts
Use a mix of qualitative and quantitative methods in evaluations
Prioritise hazard-related use scenarios in validation testing
Document everything thoroughly in the Usability Engineering File
Where possible involve regulators early for alignment
Leverage specialist expertise such as a Medical Device and IVD Consultancy with usability engineering experience
How MDx CRO Can Help
Implementing IEC 62366 in-house can strain resources. At MDx CRO we can provide:
Protocol development and study design for usability testing
Recruitment of representative users across geographies
Moderation of formative and validation studies
Integration of usability engineering with regulatory strategy
Preparation of all usability documentation required for submissions including FDA submissions
As a trusted Medical Device and IVD consultancy, we support manufacturers in implementing IEC 62366, running usability studies, and preparing documentation that satisfies both EU and US regulators. Whether you are starting a new project or updating an existing device, our team helps you achieve compliance and deliver safer devices to market.
FAQs
Does the FDA also recognise IEC 62366?
Yes. The latest versions of the IEC 62366 standards are recognised by the FDA as consensus standards. However, the FDA has also published specific human factors engineering guidances with minor differences to IEC 62366 so it is recommended that these are also considered for FDA submissions.
When should usability testing be performed?
Throughout development. Formative evaluations identify and correct issues early, while summative validation confirms safe and effective use before market approval.
Can simulated environments be accepted in usability validation?
Yes, provided they are representative of real-world conditions and cover all critical tasks and hazard-related use scenarios.
Written by:
Floella Otudeko
Senior QARA Specialist
Senior QA/RA consultant with MDR, IVDR, Usability/Human Factors and MDSW expertise, supporting MedTech and IVD innovation globally.
MDR Compliance Checklist: What You Need Before Submitting
September 28, 2025
A Comprehensive Pre-Submission Readiness Guide
Navigating the European Union’s (EUs) Medical Device Regulation (Regulation [EU] 2017/745; MDR) demands meticulous preparation. Submitting incomplete technical documentation to a Notified Body (NB) for review triggers lengthy review cycles and costly delays. This guide serves as a final gap analysis to ensure a robust, coherent, and compliant submission, paving a smoother path to Conformité Européenne (CE) marking.
Your technical documentation is an output of your quality management system (QMS). The NB will review your technical file and your QMS, in accordance with the requirements of Annex IX of the MDR. Other conformity assessment routes, such as those outlined in Annex X (based on type-examination) or Annex XI (based on product conformity verification), may also be selected, although they are less commonly used.
The foundational systems and roles required of all manufacturers, regardless of device classification, are as follows:
MDR-compliant QMS: Per MDR Article 10(9), a QMS for developing, manufacturing, and post-market monitoring is mandatory. Although certification to ISO 13485:2016 is not mandatory, it is commonly used to demonstrate compliance and is considered the most effective way to fulfil the requirements of Article 10(9) of the MDR. For all devices, the QMS should incorporate MDR-specific processes such as post-market surveillance (PMS), vigilance, and unique device identification (UDI) management.
For Class IIa, IIb, and III devices, as well as certain Class I devices placed on the market in sterile condition, with a measuring function, or intended to be reused, the QMS is typically assessed by a Notified Body as part of the conformity assessment. For other Class I devices, while a QMS is still required under Article 10(9), it does not require Notified Body involvement.
Risk management system: Mandated by MDR Annex I, risk management per ISO 14971 must be a continuous process implemented throughout the entire product lifecycle, ensuring risks are controlled and an acceptable benefit-risk ratio.
Person Responsible for Regulatory Compliance (PRRC): MDR Article 15 obliges manufacturers to designate at least one qualified PRRC permanently and continuously at their disposal. This ensures technical documentation and declarations of conformity (DoC) are prepared and maintained in compliance with the Regulation.
Understanding stakeholder obligations: Ensure that your organisation understands, and has communicated, the necessary information to distributors and importers, who have specific obligations under MDR Articles 13 and 14 regarding verification, storage, and complaint handling.
Your technical documentation is the core evidence dossier for your device, structured in accordance with MDR Annexes II (Technical Documentation) and III (Technical Documentation on PMS).
Technical documentation (Annex II)
Must provide comprehensive evidence that all General Safety and Performance Requirements (GSPRs) from Annex I are met.
Device description & specifications: Detailed description of the device, including trade name, intended purpose, users, patient population, principles of operation, and key functional elements (components, materials, software). Identification via Basic UDI-DI (per MDR Article 27 and Annex VI, Part C) or other traceable identifiers. Justification of device qualification, risk class, and applied classification rules in accordance with MDR Annex VIII. Overview of previous and similar generations of the device
Labelling & Instructions for Use (IFU): All labelling must comply with MDR Annex I, Chapter III. Claims made in the IFU or labelling must be consistent with, and supported by, the clinical evaluation, GSPRs, and RMF. Labels and Instructions for Use (IFU) in all applicable EU languages
Design and Manufacturing Information: Description of design stages, manufacturing processes, validation data, and control of critical suppliers/subcontractors.
GSPR checklist: Links each applicable safety and performance requirement of the device to the source of objective evidence (ie, verification & validation [V&V] reports, test data, or procedures); GSPRs not considered applicable should be justified. Reference to applied harmonised standards, common specifications (CS), or equivalent solutions.
Risk management file (RMF): Must demonstrate a complete lifecycle approach to risk per ISO 14971, including analysis, evaluation, control, and a report concluding a favourable benefit-risk profile.
V&V reports: Data supporting device safety and performance, including
Performance and safety testing relevant to intended use
Clinical Evaluation (Annex XIV)
Includes a clinical evaluation report (CER) based on a compliant clinical evaluation plan (CEP), providing sufficient clinical evidence to demonstrate device safety, performance, and a favourable benefit-risk ratio. It must also:
critically appraise data from manufacturer clinical investigations or an equivalent device (if claimed according to strict MDR criteria);
be updated continuously throughout the device’s lifecycle with post-market data.
PMS & vigilance (Annex III)
The Post-Market Surveillance (PMS) Documentation ensures continuous evaluation of device performance and compliance throughout its lifecycle, through the following documents.
A PMS plan: Proactively and systematically collects and analyses post-market data on device quality, performance, and safety.
A post-market clinical follow-up (PMCF) plan: Actively gathers clinical data post-market, required unless exclusion is justified.
Vigilance System: Robust procedures for reporting Serious Incidents and Field Safety Corrective Actions to competent authorities per MDR Article 87.
PMS reporting: Preparation of a Periodic Safety Update Report (PSUR) (Article 86) or Post-Market Surveillance Report (PMSR) (Article 85), depending on device class
Step 3: Pre-Submission – Administrative and Conformity Assessment Planning
Final checks before NB engagement.
Conformity assessment: Based on device classification, the correct conformity assessment procedure (detailed in MDR Annexes IX-XI) must be followed.
EU DoC (Annex IV): A draft DoC must be prepared, listing all applicable regulations and standards, signed after the NB grants CE certification.
Summary of Safety and Clinical Performance (SSCP): For implantable and Class III devices; must be written in clear, layperson language and must be consistent with the CER and IFU.
CRITICAL STEP – Internal Consistency Review: A cross-functional review to ensure the device name, intended purpose, indications, and key performance claims are consistent across documentation.
NB Engagement:
Designation Scope: Confirm your chosen NB is officially designated for your device type and classification.
HIGHLY RECOMMENDED – Pre-Submission Meeting: Discuss your strategy and the NB’s expectations through structured dialogues, de-risking the formal submission process.
MEDDEV 2.7/1 Rev. 4 (Clinical Evaluation: A Guide for Manufacturers and Notified Bodies)
MDCG 2020-6 (Clinical evidence needed for medical devices previously CE marked under Directives 93/42/EEC or 90/385/EEC: A guide for manufacturers and notified bodies)
MDCG 2020-7 (Post-market clinical follow-up [PMCF] Plan Template: A guide for manufacturers and notified bodies)
MDCG 2020-8 (Post-market clinical follow-up [PMCF] Evaluation Report Template: A guide for manufacturers and notified bodies)
MDCG 2019-9 (Summary of safety and clinical performance: A guide for manufacturers and notified bodies)
Key Takeaway
MDR compliance transcends document creation. It is about building a coherent, evidence-based narrative weaving together quality management, risk analysis, clinical data, and post-market vigilance into a single, compelling story of your device’s safety and performance. Using this comprehensive checklist to perform a final, critical gap analysis ensures your story is not only complete but also clear, consistent, and readily verifiable, paving a smoother path to successful CE marking under the MDR.
Contact us today for a consultation with our medical devices team.
Written by:
Grace Chia, PhD
RA Specialist
Regulatory Affairs Specialist in MDR & IVDR with expertise in CERs, SVRs, literature review, and regulatory compliance.
Clinical Development for Medical Devices: From Strategy to Submission
September 28, 2025
Clinical development for medical devices is a complex and continuous process under Regulation (EU) 2017/745 (MDR), requiring robust clinical evidence to demonstrate safety and performance. Regardless of whether your product is a novel technology or an updated version of an existing device, regulators demand comprehensive evaluation across every phase. This guide walks you through the key steps, from early strategy to final submission, to help you achieve MDR compliance.
Step 1: Strategy & Planning – Building the Foundation
To begin with, this phase is critical for defining the scope, evidence routes, and overall resource allocation for your clinical efforts. A well-constructed strategy at this stage prevents costly errors and oversights, setting the trajectory for a successful submission. As a result, this phase produces the clinical evaluation plan (CEP), your core strategic document.
Key strategic actions:
Comprehensive gap analysis: Assess all existing data against the MDR requirements applicable to your device’s risk class and intended purpose. This includes preclinical data (biocompatibility, electrical safety, software validation, usability engineering) and potential sources of clinical data.
Defining the evidence route map: Decide if conformity with the general safety and performance requirements (GSPRs) set out in Annex I of the MDR can be demonstrated through existing data or if a new clinical investigation is required.
Waiver of clinical data: Under MDR Article 61(10), a justification for omitting clinical data may be possible if deemed “not appropriate.” This is reserved for low-risk devices where safety and performance can be demonstrated through comprehensive preclinical testing (e.g., bench testing, non-clinical performance evaluation). You must justify the waiver through risk management and support it with clear technical documentation.
Clinical investigation route: For novel devices or when equivalence cannot be sufficiently proven, a new clinical investigation is unavoidable, especially for Class IIb implantable and all Class III devices.
Equivalence route: Alternatively, if you rely on data from another device, you must provide rigorous proof of technical, biological, and clinical equivalence as per the MDR’s strict criteria. Notified Bodies (NBs) apply these requirements strictly, which makes this path to clinical evidence more difficult.
Developing the Clinical Development Plan (CDP): This overarching document integrates pre-market and post-market clinical activities, ensuring a seamless transition from pre-market approval to post-market surveillance.
Using the CEP as the roadmap:
The CEP must define the device and its intended purpose. It should also establish specific clinical safety and performance objectives that are aligned with the device’s intended clinical benefits and risk profile. It must outline clear clinical questions, list relevant data sources, and explain the literature search strategy. A well-crafted CEP is the strategic backbone of clinical development for medical devices, ensuring your evidence generation aligns with MDR expectations.
Need expert guidance navigating MDR clinical development? Partner with MDx CRO to streamline your clinical strategy, generate robust evidence, and ensure regulatory success. Contact us today.
Step 2: Investigation & Execution – Generating Robust Data
While the clinical evaluation identifies evidence gaps, a clinical investigation may be required to generate the data needed to address them.
Clinical investigation set-up and conduct:
Investigation plan and protocol development: You must ensure the protocol is scientifically rigorous and ethically sound, in line with ISO 14155:2020. It should clearly define endpoints, sample size, and study methodology.
Navigating regulatory approvals: Secure necessary approvals from Competent Authorities and favourable opinions from Ethics Committees in each target member state.
Trial conduct, monitoring and oversight: Additionally, ensure all sites are adequately trained and monitored in study procedures. Use robust data systems to ensure data integrity and accuracy.
Vigilance and Safety Reporting: Establish clear processes for capturing, assessing, and reporting all adverse events and device deficiencies in accordance with regulatory timelines. You must ensure these processes comply with MDR requirements, particularly Articles 80–89 and Annex III Section 1.1(c). In addition, where applicable to clinical investigations, compliance with ISO 14155:2020 is also required.
Step 3: Analysis & Clinical Evaluation – Synthesising Data into Evidence
At this stage, you must transform raw data into compelling evidence. The data must be critically appraised, synthesised, and contextualised within the current state of the art.
Understanding clinical data:
Per MDR Article 2(48), clinical data are information concerning safety or performance of a device that are generated from the use of a device, and are sourced from one or more of the following:
Clinical investigations of the device under evaluation (DuE).
Clinical investigation(s) or other studies reported in scientific literature, involving a device for which equivalence to the device in question can be demonstrated.
Peer-reviewed scientific literature reporting other clinical experience with the device in question or with a device for which equivalence can be demonstrated.
Clinically relevant information from post-market surveillance (PMS), particularly post-market clinical follow-up (PMCF).
Core components of data analysis and compiling the clinical evaluation report (CER):
Systematic literature review and data appraisal: Execute the literature search as defined in the CEP. The process must be fully transparent, systematic, and reproducible. Evaluate each data source critically for validity, quality, and relevance—whether from your study or existing literature. Standardised appraisal tools should be used to assess the risk of bias and the strength of the evidence.
Demonstrating conformity with GSPRs: You must clearly link your clinical evidence to the GSPRs in the CER. It should clearly state how the collected data verifies that each applicable clinical requirement is met.
State-of-the-art comparison: Compare your device’s performance, safety, and benefit-risk profile against the current standard of care and available alternatives. This contextualises your device’s value within the medical landscape.
Writing a comprehensive and well-structured CER: The final report should clearly justify the device’s clinical safety and performance. It must affirm that the overall benefit-risk conclusion is favourable for the intended target population and clinical setting. Your evaluator(s) must sign the CER to confirm responsibility, and all data, appraisals, and conclusions must be traceable.
Synthesising data into a Clinical Evaluation Report (CER) is a critical milestone in clinical development for medical devices, connecting raw data to a clear regulatory conclusion.
Step 4: Lifecycle Management – Closing the Loopand Ensuring Continuity
Under MDR, clinical evaluation is a continuous process. In fact, certification is not the finish line—it’s the midpoint of an ongoing cycle of evidence generation.
Ongoing post-market obligations:
PMS: Proactively collect and evaluate real-world data from various sources, including user feedback, complaint handling, literature screening, and registries. This system helps detect emerging risks or performance issues.
PMCF studies: Where required by the risk profile or as outlined in the CDP, conduct targeted PMCF studies to investigate the long-term performance and safety of the device, or to address any residual uncertainties from pre-market clinical evaluation.
CER updates: Treat the CER as a living document. Therefore, update it annually for Class III and implantable devices, or every 2–5 years for lower-risk classes. An immediate update is warranted upon the discovery of significant new information that could impact the benefit-risk assessment, such as newly available clinical data, emerging risks, or advancements in the state-of-the-art.
Navigating Challenges
Data quantity and quality: Data must be sufficient for statistical significance and come from reputable sources. Manufacturers must demonstrate a thorough search of relevant databases (e.g., PubMed, EMBASE) and a critical appraisal of the data’s scientific validity.
Justifying a waiver: However, waiving clinical data is risky. You must justify it scientifically and ethically, rooted in strong risk management
Proving equivalence: The bar for demonstrating technical, biological, and clinical equivalence is high. Because NBs assess equivalence strictly, a new clinical investigation is often the better option.
Successful clinical development for MDR compliance is not a series of isolated tasks but an integrated, lifecycle-spanning process with clinical evaluation as its continuous core. To sum up, by planning strategically with a thorough gap analysis and a robust CEP, executing clinical investigations with rigor, synthesising data into compelling evidence in the CER, and embracing the ongoing cycle of PMS and CER updates, you demonstrate more than just compliance. You build and maintain a strong, evidence-based case for your device’s enduring value, safety, and performance in the marketplace.
Written by:
Grace Chia, PhD
RA Specialist
Regulatory Affairs Specialist in MDR & IVDR with expertise in CERs, SVRs, literature review, and regulatory compliance.
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