Three Things You Should Know about Medical Device Regulations in Russia and the Eurasian Union, September 2016

 

Dear colleagues and group members, please find below my selection of highlights in terms of medical device regulations in Russia, for September:

 

  1. State Control over Medical Devices in Russia
    In September, Roszdravnadzor (the Russian medical device approval agency) published a release about the state control over the circulation of medical devices. According to the regulator, 85% of the medical devices [on the Russian market, checked and tested in the context of state control measures] do not meet the required quality and safety requirements. Recall that today’s Russian medical device regulations require a full correspondence of all characteristics (technical specifications, model and size ranges, labelling, software versions), with the data provided in the registration dossier, and in the case of discrepancies with which this data medical product can be considered as unregistered by the regulator.
    State control over the circulation of medical devices has been implemented in Russia since 2013 and includes the possibility of revisions / audits of medical device manufacturers, distributors and clinics by Roszdravnadzor (see full regulation in Russian). Since 2015, Russia has strengthened the responsibility for violations of medical device regulations and today we can see some of the first legal practices on this.

 

  1. Revised Version of Requirements for Technical Files and Instructions of Use for Medical Devices
    The Russian Ministry of Health published a revised version of the draft of requirements for the technical documentation and instruction for the use (IFU) of medical devices. The document clarifies the full list of the information required in the technical file and IFU for medical devices and in-vitro devices. As you probably know by experience and based on the feedback from Roszdravnadzor, discrepancies and lack of consistency or particular information regarding these documents are the most common reasons in registration delays today.
    An interesting innovation for Russia is that the draft regulation allows a shorter version of instructions for the use for medical devices of the I and IIA class (on the condition that such medical devices can be safely used). According to the document, it is also allowed to distribute electronic forms of instructions for use (on the website or on the screen of the medical devices)—in this case, the manufacturer must ensure that the consumer is informed about how to have access to the up to date version and about how to receive their paper version.
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  2. Tax Exemption for Foreign Medical Device Components
    A number of amendments to the Russian Tax Code, exempting Russian medical device manufacturers from paying value added tax (VAT) for importing components and raw material for the medical device manufacturer process in Russia, will come into force on the 1st of October 2016. Until that day, Russian medical device manufacturers are required to pay 18% VAT on any imported components for their products, which, in some cases, poses significant restrictions and impacts on the cost of the manufacturing process. New amendments grant VAT exemptions in situations whereas the imported medical device components or the raw materials have no Russian equivalents and in those cases when their intention for manufacturing a medical device is proven. According to experts, the amendments will help to develop the Russian assembly of complex medical equipment, but their implementation in practice may take some time.

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