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Important Update Regarding UK Medical Device Vigilance Reporting _MORE Portal

We would like to bring your attention to a significant change in the UK Vigilance reporting process that will be mandatory after August 31, 2023 in the UK (see our Newsletter dated April 26, 2023). 

The AICXML mailbox, which has played a vital role in reporting adverse incidents related to Medical Devices to the MHRA, will no longer be operational beyond August 31, 2023. It is being replaced by the MORE (Manufacturer Online Reporting) portal. It is essential to highlight that any submissions sent to after August 31, 2023, will not reach the MHRA. This could result in a failure to report, which is a critical noncompliance.

MDSS has been entrusted with the mandate to report Vigilance events by most of our clients. For these clients we have consistently utilized the MORE platform for reporting since its inception. During the transition, the MHRA actively sought feedback from users, and we are pleased to share that our inputs were taken into consideration to enhance the platform. 

For those of you who report directly as manufacturers, reporting via the MORE portal requires mandatory registration. Detailed instructions for both registration and submission through the portal, along with relevant guidance and useful links, can be found on the official GOV.UK website. We advise strict adherence to these guidelines. Furthermore, if you choose to report directly, it is crucial to keep MDSS, if we are your UK Responsible Person, informed of the submissions, as outlined in the guidance: "The manufacturer should also ensure that these guidelines are made known to their UK Responsible Person ..., who should be kept informed of incident reports. This will enable their UK Responsible Person ... to fulfil their obligations.

We are excited that we introduced the new portal seamlessly in our QM System for our clients to transition to the MORE portal, aligning with the guidelines to ensure a smooth and uninterrupted submission process. MDSS will continue to offer the submission of vigilance reports to the MHRA through the MORE portal specifically for its clients. 

We value your feedback and would greatly appreciate your thoughts on the helpfulness of this Newsletter in the comment section below.

Categories: News

UK MDR Update published!

It is finally official! The Medical Devices (Amendment) (Great Britain) Regulations 2023 - statutory instrument 2023 No. 677 will come into force on July 1, 2023.

You can find the legal text on this link.

The UK government has extended the acceptance of CE marked medical devices on the Great Britain market. This legislation will provide that CE marked medical devices may be placed on the Great Britain market to the following timelines:

  • general medical devices compliant with the EU medical devices directive (EU MDD) or EU active implantable medical devices directive (EU AIMDD) with a valid declaration and CE marking can be placed on the Great Britain market up until the sooner of expiry of certificate or 30 June 2028
  • in vitro diagnostic medical devices (IVDs) compliant with the EU in vitro diagnostic medical devices directive (EU IVDD) can be placed on the Great Britain market up until the sooner of expiry of certificate or 30 June 2030, and
  • general medical devices, including custom-made devices, compliant with the EU medical devices regulation (EU MDR) and IVDs compliant with the EU in vitro diagnostic medical devices regulation (EU IVDR) can be placed on the Great Britain market up until the 30 June 2030.

The legislation provides that you can place self-declared CE marked Class I medical devices on the GB market beyond 30 June 2023 if they are:

  • self-declared against EU MDR requirements (until 30 June 2030), or
  • self-declared against MDD requirements before 26 May 2021 where Notified Body involvement in their assessment is not required under MDD but is under EU MDR (until 30 June 2028). This includes upclassified devices and reusable surgical instruments.

It also provides that you can place a Class I medical device which has a sterile or measuring function with a valid MDD certificate on the GB market until 30 June 2028.

Class I medical devices and general IVDs under the Directives, for which the conformity assessment under the EU MDD or EU IVDD did not require a notified body, can only be placed on the Great Britain market if the involvement of a notified body would be required under the EU MDR or IVDR (i.e., if it is an upclassified device or a reusable surgical instrument Class I device). 

You can download the timelines for placement of CE marked medical devices on the Great Britain market under the Medical Devices (Amendment) (Great Britain) Regulations 2023 here.

Categories: News

MHRA guidance on Regulating medical devices in the UK has been updated!

The MHRA has updated their guidance on "Regulating medical devices in the UK" with changes to some key topics: ‘Summary of key requirements for placing a device on the Great Britain market’, ‘Registrations in Great Britain’, ‘UKCA marking’, ‘CE marking and Notified Bodies’, ‘Labelling requirements’ and ‘Regulation of medical devices in Northern Ireland’ Reference Guides.

We want to draw your attention to "Register medical devices to place on the market", which provides a very detailed guidance on "Registration of certain medical devices that have expired/expiring CE certificates" and "Registration of certain medical devices which are EU MDD Class I reusable surgical instruments or EU MDD Class I medical devices upclassified from Class I". 

You can access the guidance document for these specific situations here.

If you find yourself in any of these scenarios, please do not hesitate to reach out to us, and we will provide you with the necessary assistance to navigate this process.

Comment on youregulate...

Categories: News

MHRA update!

It is now official - twelve-month extension to the current standstill period on the future regulation of medical devices in the UK.

Here is the official communication.

Join our Seminar on Thursday and get your questions answered and all the latest updates!

Comment on

Categories: News


Brexit and Medical Devices


What we already evaluated was strongly confirmed by a representative of the UK MHRA.  

And more importantly it was stated that no independent UK RP is possible.

Please see the latest UK law here to verify this for yourself. In order to come to that conclusion, someone should not only read the requirements for the UK RP (schedule 77). In particular, the definitions for importer, UK RP and the definition for placing products on the market are needed. Then by nature the importer is placing products from a third country on the UK market, and in Schedule 95 states: “… the person placing products on the market is to be regarded as the UK responsible person…”

It was indeed intended that the importer is the UK RP, without leaving the possibility for an independent service provider to take over this role.

This will not only change the regulatory landscape significantly, but more importantly, the overall business approach to selling products in the UK needs to be thoroughly reviewed.  

For example, the importer (your distributor, your precious customer) is now the UK RP and shall act on your behalf, with you being the manufacturer. However, the interest of a distributor may NOT coincide with the interest of the manufacturer. It starts already with the pricing, and how often was it necessary to change the distributor because you were not happy with their performance or demands?

It was clearly indicated that the manufacturer should act in order to prepare for this Brexit situation, but it was confirmed that the time line  for implementing will be granted (4, 8 and 12 month).

A more thorough evaluation will follow shortly, and there is only one really safe solution to secure the business. However, these are not only regulatory decisions any longer. This is now an overall business aspect. This means other departments of the company must be informed and should participate in the discussion - NOW.

Please contact MDSS for further details and the possible solution on this scenario. Our office in the UK could support your solution.  

Brexit scenarios:

  1. Brexit without a deal on October 31, 2019.

  2. Further extension for a few weeks or until January 2020 and then Brexit without a deal.

  3. Further extension with a deal. Transition until December 31, 2020 and then:

a. No agreement with the EU

b. Agreement with the EU and then:

i. Existing law as referenced above (only trade agreement but no Mutual recognition agreement (MRA) of approvals)

ii.New law and MRA.

And certainly, anything else may as well be possible.  

Categories: News

Brexit - Again!

If you come from the latest Brexit news here is the link back to the article you were reading.

UK Responsible Person = Importer with severe additional responsibilities

The MDSS solution:
Have MDSS set up an appointment with you to receive the solution for your individual business. A solution, which may also be extremely appealing to your distributor.

The UK authority (MHRA) published a new guidance on the UK responsible person (UK RP). MDSS, together with its clients, evaluated early on (during the drafting of the contract) that the UK RP is actually a new concept and can only be compared with the European Union (EU) Medical Device Regulation (MDR) Authorized Representative (AR) in some specific tasks. The standard AR contract is not sufficient. The new proposed UK law has something different in mind for an entity supporting out of the UK based manufacturers in terms of their compliance. As it seems, legal and liability ramifications play a key role. The new MHRA guidance tries to clarify this now.

Key aspects:

  • Clarification of UK RP responsibilities

  • The importer is the UK RP!

  • Announcement of grace period for the implementation of the UK RP

  • MDSS specialized service towards its clients to cope with the new requirements

The MHRA guideline states: „If you are a UK-based importer and you wish to place a device on the market, you must have the authority from the manufacturer before doing so. This means that you will become a UK Responsible Person.”

This then means that the UK Importer being the UK RP:

  • Must have a “letter of designation” from the Manufacturer

  • May be a person or a legal entity

  • Performs product registration

  • Pays the product registration fees

  • “Acts on behalf of the manufacturer established outside the UK”

  • Must take over specified tasks with regards to the manufacturer’s obligation under these regulations such as:

    • Performs verification of the technical documentation and other documents similar to the MDR Authorized Representative

    • Keeps available a copy of certain documents including the technical file for inspections by the MHRA

    • Fulfills other tasks similar to the MDR Authorized Representative

There are great concerns with the new proposed laws. As one UK entity already stated, they may not be able to buy any longer the product. His fear is that the purchase is of such a low volume and, therefore, not worthwhile for his supplier (manufacturer abroad) to entertain that business any longer with the increased scrutiny. Also, selecting a new supplier for him is now so burdensome that he may accept prices he normally would not! He preferably would now receive his product from a UK manufacturer.

As the manufacturer abroad:

  • Be aware that each individual distributor of yours will automatically be the UK RP. By nature, they are the importer of your products and place the product on the UK market. 
  • You will have to designate them to be the UK RP if you want to continue business with them.
  • You will have to give them a similar mandate as the MDR AR.
  • You will have to trust them with your technical file and other information.

It is not clear why the law actually specifies a UK responsible person. It would have been sufficient to simply impose the requirements on the Importer directly without defining a new term. However, due to the structure provided in the law, by reading the specific UK RP requirements only, someone could come to the conclusion that an independent UK RP is envisioned.

Therefore, the initial MHRA guidance indeed gave the pronounced impression that a manufacturer abroad should designate a UK RP:

- Independent of the importer and
- being a single UK RP

The new MHRA guidance clarifies that the importer is the UK RP (see above) but still suggests installing an independent UK RP. There may be solutions for this requirement with the statement: “Whilst there is no existing list of UK Responsible Persons, you may wish to speak to existing EU Authorized Representatives to determine whether they will be offering services as a UK Responsible Person.”

Does it make sense for your AR to offer such a service? The customers (UK Importer = UK RP) of the manufacturer are automatically the UK RPs! Furthermore, does your AR normally sell your products? The manufacturer specifically selected an AR not being engaged with the sales/import of the products. However, the guidance seems to indicate that the MHRA would like to see a professional UK RP implemented to take over these nontrivial UK RP tasks and that they may have a solution in mind for these new requirements. However, that solution is not outlined in the guidance.

In case of a hard Brexit (Brexit without a deal), the manufacturer will have the time to install such an agreement within the timeframe as outlined for the registration. The guidance states in regards to the timeline:

„The requirement for a manufacturer to have in place a UK Responsible Person is in line with the grace period for registering your devices with the MHRA. Details of the grace period for registrations is set out in our guidance on registrations. Therefore, you must ensure that you are designated as a UK Responsible Person by the time you register with the MHRA.”

With the importer automatically being the UK RP, it actually should read that the UK Importer must implement the requirements of the UK RP and, therefore, must ask his supplier (the manufacturer abroad) to allow him the sales (placing on the market) of the products and that he is allowed to act on his behalf etc... It is up to the manufacturer whether he will conduct now business in the UK with such requirements.  

The grace period is 4, 8 and 12 month and it depends on the classification of the products with the highest classification being the shortest and so on.

There seems to be a different understanding in the guideline in terms of the registration. It is stated that “the UK RP will then assume the responsibilities of the manufacturer in terms of registering the device”. However, the law outlines the “Registration of persons placing general devices on the market” and that is by nature the UK manufacturer or the UK Importer. The requirements for that person among other aspects:

“supplies the Secretary of State with a description of the relevant device; and
pays to the Secretary of State the relevant fee in accordance with regulation 53.”

Our overall impression of the new UK law is that the UK is very UK centered and that there is actually no responsibility for the manufacturer if not located in the UK. The Importer must ensure that he purchases products that comply with the UK law (for the time being CE marked products), must register the products and defend your products because he is the entity facing severe consequences. Legal as well as product liability are aspects the importer faces! The product liability is by nature bestowed upon the legal entity who places the products on the market and the legal concerns are directly outlined in the UK Law.

“(3) A UK responsible person—
may be proceeded against as a person placing the device on the market for the purposes of these regulations;

For a manufacturer abroad, considering the above, there is nothing to be gained to install an independent UK RP.  
Therefore, the motivation to install an independent UK RP may fade significantly by the manufacturer.  

We are of the opinion that both entities, the manufacturer abroad and the Importer may not be content with the requirement.  We suggest a specific solution, which may be agreeable with your customer (the UK Importer).

The MDSS solution:
Have MDSS set up an appointment with you to receive the solution for your individual business. A solution, which may also be extremely appealing to your distributor.

We strongly recommend to evaluate the actual law which can found here.

The guidance on the UK responsible person can be found here.

If you come from the latest Brexit news here is the link back to the article you were reading.

Categories: News

Another update on UK guidance!

Published September 3.

We will review this new update and check whether it effects our Responsible Person (RP) contract and update accordingly if needed.  

Please review for yourself.

Clarification is definitely needed because the proposed law is not clear on a very specific concern and hopefully the new guidance will provide the clarification.

2019 No. 791
Consumer Protection

The Medical Devices (Amendment etc.) (EU Exit) regulations 2019

Categories: News

Regulating medical devices in the event of a no-deal Brexit

Latest update on UK in regards to medical devices in case of no-deal Brexit published on August 8, 2019.  

UK Responsible Person:

A new role has been created, which applies from the day the UK leaves the EU.

  • must be established in the UK

  • acts on behalf of a manuf. established outside the UK

  • carries out specified tasks

  • this includes registering with the MHRA

Establish your responsible person with MDSS!

Link to the article.

Categories: News
  • UK Responsible Person

    6 Wilmslow Road, Rusholme, Manchester M14 5TP, UK

    +44 7898 375115

  • U.S. Agent

    IL 60630

    +1 (312) 975-1694

  • Cosmetics Responsible Person

    Schiffgraben 41
    30175 Hannover

    +49 511 6262 8630

  • CH-REP

    Laurenzenvorstadt 61
    5000 Aarau

  • Importer

    Limmerstraße 15
    30451 Hannover

    +49 511 62 62 86 30


Schiffgraben 41
30175 Hannover


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