EUDAMED – Pro­vi­si­on of the Actor Regis­tra­ti­on Modu­le alre­a­dy plan­ned for ear­ly Decem­ber 2020

EUDAMED is a product- and manufacturer-related data­ba­se in which manu­fac­tu­r­ers are requi­red to store data in accordance with the new Euro­pean regu­la­ti­ons for the deve­lo­p­ment, manu­fac­tu­re, mar­ke­ting and pro­duct moni­to­ring of medi­cal devices within the EU in the form of the MDR (PDF) and IVDR (PDF).

Ori­gi­nal­ly, this data was to have been coll­ec­ted by the plan­ned effec­ti­ve date of the MDR (26 May 2020), with a 18-month tran­si­ti­on peri­od pro­vi­ded for by the Euro­pean legis­la­tor. Howe­ver, the Com­mis­si­on delay­ed the intro­duc­tion of EUDAMED by two years last Octo­ber becau­se it feared that the sys­tem would not be rea­dy in time for the ori­gi­nal tar­get date of May 2020. Howe­ver, this post­po­ne­ment has no impact on the effec­ti­ve date of the MDR its­elf, which is (curr­ent­ly) 26 May 2021.

The data­ba­se is inten­ded to moni­tor the safe­ty and effec­ti­ve­ness of medi­cal devices as part of the now delay­ed Medi­cal Devices Regu­la­ti­on. In March, the MDCG (Medi­cal Device Coor­di­na­ti­on Group) (PDF) and the Com­mis­si­on agreed to make the six modu­les (that com­pri­se EUDAMED) available on an ongo­ing basis as soon as they beco­me available.

At that time, the Com­mis­si­on pre­dic­ted that the Actor Regis­tra­ti­on Modu­le (ACT) would be rea­dy by March 2021. Part of this plan has recent­ly been chan­ged: the Actor Regis­tra­ti­on Modu­le is now sche­du­led to be available as ear­ly as the begin­ning of Decem­ber 2020.

The MDCG is now pre­pa­ring the indus­try for the intro­duc­tion of the modu­le, which will enable pro­duct manu­fac­tu­r­ers, aut­ho­ri­sed repre­sen­ta­ti­ves and importers to obtain the SRN (sin­gle regis­tra­ti­on num­ber) they ulti­m­ate­ly need for certificates.

As the­re are still almost 18 months bet­ween the intro­duc­tion of the modu­le and the full launch of EUDAMED, orga­ni­sa­ti­ons now have more time to obtain the SRN they need to use other func­tions of the data­ba­se. This deve­lo­p­ment would repre­sent a signi­fi­cant impro­ve­ment in the situa­ti­on, espe­ci­al­ly as the­re were recent­ly fears that Mem­ber Sta­tes would have to vali­da­te all regis­tra­ti­on appli­ca­ti­ons within two months.

The intro­duc­tion of this modu­le is inten­ded to be the first in a series of steps towards the full imple­men­ta­ti­on of EUDAMED. Two fur­ther modu­les (pro­duct regis­tra­ti­on, UDI – Uni­que Device Iden­ti­fi­ca­ti­on, and cer­ti­fi­ca­te, CRF – Cer­ti­fi­ca­te) are to be put into ope­ra­ti­on by May 2021, as the Com­mis­si­on is working towards its goal of having a sys­tem rea­dy for test­ing in time to bring the data­ba­se online in 2022. In anti­ci­pa­ti­on of the launch, the Com­mis­si­on published a fact sheet last month with details on EUDAMED infor­ma­ti­on that will be publicly available.

A gui­dance docu­ment for users of the EUDAMED data­ba­se can be found here (PDF).

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