1. What is medical device technical documentation?
Medical device technical documentation, or formerly technical file, is the complete set of evidence a manufacturer compiles to demonstrate that a device meets the applicable regulatory requirements. Under EU MDR 2017/745, its required content is defined in Annexes II and III. It covers the device description and specification, design and manufacturing information, evidence of safety and performance, risk management, verification and validation results, and post-market surveillance.
2. What is the difference between a technical file and technical documentation?
They describe the same body of evidence, but the two terms come from different regulations. "Technical file" was the term used under the old Medical Device Directive. EU MDR 2017/745 replaced it with "technical documentation" to reflect the broader and more detailed evidence now expected by regulators. In everyday industry use, the two terms are still used interchangeably.
3. What must EU MDR technical documentation include?
Under Annex II of EU MDR 2017/745, technical documentation must include the device description and specification, the information supplied by the manufacturer such as labelling and instructions for use, design and manufacturing information, evidence of conformity with the general safety and performance requirements, the benefit-risk analysis and risk management, and product verification and validation results. Annex III adds the documentation for post-market surveillance.
4. How long must medical device technical documentation be kept?
Under Article 10(8) of EU MDR 2017/745, manufacturers must keep the technical documentation available to competent authorities for at least 10 years after the last device is placed on the market. For implantable devices, the minimum retention period is 15 years. The same periods apply to the EU declaration of conformity and any relevant certificates.
5. What documentation does an FDA 510(k) submission require?
A 510(k) is a premarket submission that demonstrates a device is substantially equivalent to a legally marketed predicate device. It sets out the device description, its intended use, and a direct comparison with the predicate, supported by performance data. Depending on the device, this can include bench testing, biocompatibility, software documentation, and electrical safety and electromagnetic compatibility evidence.
6. What is UKCA marking for medical devices?
UKCA (UK Conformity Assessed) marking is the route to place a medical device on the Great Britain market after conformity assessment against UK requirements, with registration through the MHRA. CE-marked devices are currently still accepted in Great Britain under transitional arrangements, with end dates that vary by device type. The MHRA is reforming the UK regime, so timelines continue to change.