Three Things You Should Know about Medical Device Regulations in Russia: July 2019

 

Dear Colleagues,

This is my usual selection of highlights and recent changes in medical device regulations in Russia:

  1. Some Updates in Medical Device Registration and Clinical Trial Requirements in Russia

On 4 July 2019 the Russian Ministry of Health enforced order no. 239N (link in Russian). This updated certain requirements for pre-registration clinical trials (update of order no. 2N), requirements for the content of the technical file and instruction for registration of a medical device (update of order no. 11N). The main updates implemented in the published document are:

  • The clarification of and uniform requirements for documents confirming the quality of the pharmaceutical component of drug-containing medical devices.
    The first amendments of registration rules (regulation no. 1416) to simplify the registration of drug-containing medical devices in Russia were made in June 2018; later in 2018 Roszdravnadzor clarified requirements for confirming the quality of the pharmaceutical component. However, until July 2019 these registration rules were not harmonised with other Russian medical device regulations (order no. 2N and order no. 11Nr). The order no. 239 seems to finally resolve these discrepancies.
  • Henceforth, it is permitted to conduct clinical trials for registration in Russia where a certain type of capital medical equipment is on-site in other countries in ‘organizations where a medical device is located/installed and is approved for use/application’. The possibility of on-site clinical trials is not new, however, previous revisions of order no. 2N permitted clinical trials to be performed ‘during inspection on the place of the manufacturing of a medical device’.
  1. Russia Launches the List of Medical Devices Containing Ethyl Alcohol

On 2 July 2019 the Russian government enforced resolution no. 774 (link in Russian), which approved the rules for the formation of the list of alcohol-containing medical devices. Medical products included in this list are excluded from general alcohol regulations in Russia i.e the Federal law 171 “On state regulation of the production and circulation of ethyl alcohol, alcoholic and alcohol-containing products and on limiting the consumption (drinking) of alcoholic beverages”. The released resolution provides the criteria for inclusion on the list (based on a product’s intended use, the form of the container or package and the product retail price) along with a list of documents  for application for inclusion. Russian healthcare regulator Roszdravnadzor is responsible for the list’s inclusion procedure and has clarified the rules for applications — which should be received <annually> by the regulator between 1 January – 30 June.

  1. Russia: New Administrative Provision on Medical Device Registration

On 26 July 2019 the Russian Ministry of Health published order no. 3371 (link in Russian) – with a new version of the administrative provision of Russian medical device regulator Roszdravnadzor – on the procedure for the registration of medical devices in Russia. Simultaneously, the previous version of the same document (the Ministry of Health order no. 737) was annulled.

Administrative provision on the procedure for the registration of medical devices is a regulation that establishes the following: the terms and sequence of administrative procedures of the regulator during the approval process, the procedure for interaction between its structural divisions and the interaction between applicants/manufacturers and other government bodies. The new version of administrative provision does not contain critical changes but it is aligned with the last changes of the registration rules and other medical device regulations.

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Three Things You Should Know About Medical Device Regulations in Russia and the Eurasian Union – June 2019

 

Dear colleagues,

Welcome to my usual monthly review containing the most important medical device regulation changes across Russia and the Eurasian Union over the past month:

  1. New Restrictions on State Procurements for Certain Medical Devices in Russia

On 26 June 2019, the Russian government published Resolution # №813 (link in Russian) and extended the list “of certain types of medical devices originating from foreign countries subject to restrictions for state and municipal procurements in Russian Federation”. 

The state procurement of medical devices included in the list, according to the Resolution #102 introduced in 2015, will be closed to foreign manufacturers if at least two bids on medical devices from local manufacturers (Russia, Kazakhstan or Belarus) were submitted for tender.

Above-mentioned Resolution # №813 has added 14 new types of device to the restriction list including ventilation devices, gamma-therapeutic radiation complex, ultrasound devices, certain types of endoprosthesis, external fixation devices, medical beds, intraocular lenses, intraocular tonometry, micro sources with iodine-125, certain adhesive dressings and surgical materials, medical devices for storage and transporting biological samples, air sterilisers and dry air thermostats.

According to the published document, analogs of each of these products are currently produced in Russia in sufficient volume by at least two local companies. The decision was taken with the aim of supporting the development and production of these products in Russia.

The new revision of the list is available in Russian.

  1. Russian Ministry of Health Clarified Trademark Requirements for Medical Device Registration 

The requirement to provide confirmation of the legitimate use of the Russian trademark for registration of a a medical device is a relatively new requirement, which was introduced by the Resolution 633 in June 2018 and raised a lot of questions and confusion across registration applicants over the last year.

Thus, according to the petition initiated by Russian medical device registration consulting company Medrelis and 28 medical device companies submitted to the Russian Ministry of Health in May 2019, over the past year the interpretation of trademark legitimacy by Russian health care regulator Roszdravnadzor was often controversial and led to additional difficulties in the registration procedure and an increased amount of registration rejections.

On June 2019, the Russian ministry of health, for the first time since the enforcement of the new trademark requirements, clarified (the letter kindly provided by Medrelis) that Roszdravnadzor, to prevent the circulation of counterfeit medical devices, may compare (verify) information provided <for registration of a medical device> by the manufacturer or the authorised representative of the manufacturer (s) with information received, inter alia, as “interdepartmental information interaction” (which means that missing documents confirming trademark legitimacy in the registration file may not be a reason for the registration rejection or additional requests to the applicant from the regulator).

  1. Multiple Updates of Regulations for Medical Devices and Pharmaceuticals in Kazakhstan

Kazakhstan continues to release multiple updates to local medical device and pharmaceutical regulations started earlier this year. Thus, for the past months the following regulations have been released in new revisions: 

  • On 02 May 2019 – the order KR-DCM 53 (Link In Russian) updating the rules of wholesale and retail sales of medicines and medical devices.
  • On 27 May 2019 – Order KR-DCM-88 (Link in Russian) updating pharmacovigilance requirements for pharmaceuticals and rules for safety monitoring of medical devices; 
  • On 7 June 2019 –the Order KR – DCM 82 (Link in Russian) updating requirement rules for assessing the safety and quality of medicines and medical devices registered in Kazakhstan;
  • On 9 June 2019 – the Order KR – DCM 87 (Link in Russian) updating rules of state registration, re-registration and amendments of the registration dossier for pharmaceutical products and medical devices.