Russian and Eurasian Regulatory Roundup of 2020

Russian and Eurasian Regulatory Roundup of 2020

Dear Colleagues,

2021 is approaching, and in my usual December post, let me look back and summarise the highlights and major updates on medical device regulations in Russia and the Eurasian Union in the year 2020.

  1. Eurasian Medical Device Regulation Highlights 2020:

A year ago, on 31 December 2019, the Russian healthcare regulator Roszdravnadzor announced that the first medical device was approved under the Eurasian medical device regulations. The first Eurasian registration certificate was issued for a 2A class neonatal phototherapy lamp that was manufactured in Russia.

By the end of December 2020, there have been four medical devices (in-vitro devices) mentioned in the Eurasian database – all of these manufactured by Russian manufacturers. In the same database, we can also notice over 30 files submitted for Eurasian registration between 2019 and 2020 (with a significantly high rejection rate and a review time of over 350 days).

One of the key challenges for manufacturers (especially during the time of travel restrictions imposed during the pandemic) has been the necessity for carrying out an inspection of a manufacturing site to ensure compliance with quality management system (QMS) requirements (in accordance with the Eurasian Regulation #106). This compliance, as per regulations, is a mandatory step for approval of any medical device belonging to classes IIA and III. However, in September 2020, Roszdravnadzor announced that the first QMS inspection was carried out on the first medical device and that its approval was provided by complying with the Eurasian medical device registration procedure. Roszdravnadzor also announced that it carried out manufacturing inspection of two manufacturing sites located in Russia.

Most of the 1st, 2nd and 3rd level Eurasian regulations, nowadays, are released and approved by the Eurasian Commission. Some of the regulations that were updated over the course of 2020 include the amendment to the rules of registration and examination of medical devices (link in Russian), draft of a regulation on technical testing requirements (link in Russian), draft regulations on amendments to the criteria for classifying products as medical devices (link to the draft document in Russian).


According to Decision #142 (published in September 2019), the end of the transition period for submissions, according to local regulations of the Eurasian member states, as of today, still remains 31 December 2021.

  1. Russian Medical Device Regulation Highlights 2020:
  1. Response to COVID-19 – Russian and Eurasian Medical Device Regulations:

In the year 2020, the COVID-19 pandemic has overwhelmed the Russian healthcare system (which has been the case with other countries too). In response to the pandemic, Russian Ministry of Health introduced certain new regulatory measures and approval pathways related to medical devices and in-vitro diagnostics:

  • On 18 March 2020, the Russian government released Resolution #299 (link in Russian) followed by methodical guidelines (link in Russian) and opened a simplified registration route for 36 types of class I protective medical devices, including surgical or protective face masks, respirators, medical protective clothing, surgical suits, medical gloves, overshoes, etc. The official timeline for taking a decision on registration of products that are included in the list is within five days upon receipt of the registration file, on the condition that the manufacturer provides documents confirming the safety and quality parameters of these devices (testing and trial reports) within five months of the approval date. By the end of the year, the regulator announced that the initial registration of 1342 medical devices that were approved through the accelerated and simplified registration route were withdrawn since the required documents were not provided within the established deadlines.
  • On 6 April 2020, the Russian government released Resolution #430 (link in Russian) followed by guidelines (link in Russian)  and introduces simplified accelerated registration process for temporary approval of particular batches of 108 types of medical devices and IVD products included in the list (this list was extended to 363 types of products )that were intended for emergency usage in the prevention and treatment of coronavirus infection.
  • The temporary registration certificate (validity of which was prolonged until the end of 2021) of the product included in the list may be granted by Roszdravnadzor (within three business days) after carrying out testing through the special accelerated program).
  • By the end of December 2020, there will be over 300 registration records (for particular bathes) holding a temporary registration certificate in the Russian registration database.
  • Additionally, since April 2020, the regulator has allowed to sell imported disposable medical products included in the list (and not registered in the Russian Federation) on the condition that these products are registered in the specified manner outlined by the manufacturing country.

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    I would like to thank all of my subscribers and readers for showing your continuous interest and feedback  in my posts and updates. I wish you a wonderful holiday season! All the very best for the year 2021!

Three Things You Should Know about Medical Device Regulations in Russia and Eurasian Union, November 2020

Dear Colleagues,

Here is my usual selection of highlights to keep you in the loop regarding updates in Russian and Eurasian medical device regulations for the last month.

  1. Prolongation of the Simplified Medical Device Approval Process in Russia


On 13 November 2020, the Russian government released Resolution #1826  (Link in Russian) extending the validity of the simplified batch-by-batch approval process for medical devices and IVD products intended for emergency use in the prevention and treatment of coronavirus infection introduced in April 2020, for one year (i.e. until the end of 2021).

The published resolution can also extend the validity of licenses that were issued according to this simplified procedure, for particular batches of the products. However, this extension will require the procedure of the administrative replacement.

As of today, the simplified batch-by-batch approval process is valid for 363 types of medical devices, including some IVD assays and laboratory consumables, artificial ventilation machines and breathing circuits, connectors and valves for mechanical ventilation, pulse oximeters, patient monitors, medical furniture, protective masks and other medical devices and protective equipment. There are 278 registration certificates that were issued through this process.

2. Updated Procedure for Safety Monitoring of Medical Devices in Russia

On 2 November 2020, the Russian Ministry of Health published the Order #980n on the approval of the procedure of the safety monitoring for medical devices (link in Russian).
The regulation, that replaced the previous obsolete order cancelled in July 2020, comes into force on 1 January 2021 and will be applicable for medical devices approved according to Russian local procedure until 1 January 2027.

The Russian medical device regulation, requires licence holders to perform safety monitoring  by collecting information ‘on adverse effects not specified in the operating manual of the medical device, adverse reactions during its use, the peculiarities of the interaction of medical devices with each other, facts and circumstances that pose a threat to the life and health of citizens and medical workers during their use and operation.’

According to the document, the Russian medical device regulator may receive the information on adverse events from the reporting of manufacturers of medical devices, as well as by monitoring the post-market surveillance databases of regulatory agencies of other jurisdictions or control measures performed by the regulator.

Based on the information received during safety monitoring, the regulator may initiate additional control measures or request a plan of corrective action from the manufacturer.

3. Eurasian Criteria for Classifying Products as Medical Devices

On 24 November 2020, the Eurasian Commission published draft regulations on amendments to the criteria for classifying products as medical devices within the Eurasian Economic Union.  (link to the draft document in Russian)

The document proposes changes to existing criteria, issued in 2018 in Regulation #25, in order to eliminate differences in the requirements for classifying products as medical devices between the  Eurasian regulations and local regulations of the member states.
Most of proposed changes relate to standardising criteria for medical software with recently updated Russian requirements and some protective equipment.

The draft document is open for public discussion until 25 January 2021.

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Three Things You Should Know About Medical Device Regulations in Russia, September 2020

Dear Colleagues,

Here is my regular update on the Russian and Eurasian medical device regulations for the last month:


1. Updated Criteria for Medical Devices Exempted from the Registration Requirement


On 1 September 2020 the Russian government released Resolution #1335 (link in Russian) and updated the criteria of medical devices that do not require registration in Russia. The regulator also harmonised these requirements with the Eurasian legislation.

Henceforward, the following medical devices are within the scope of this regulation:
–Medical devices that match the Eurasian criteria listed in Clause 4.11 of the Eurasian Agreement (including medical devices for personal use, medical devices for medical aid on transport or international cultural or sport events, as well as those imported for humanitarian use);
–Custom-made medical devices that are made and intended for a particular patient;
–Medical devices that are intended for use within the territory of the international medical cluster or innovative science and technology centres.

2. First Medical Device Passed Eurasian Quality Management Inspection

Russian healthcare regulator, Roszdravnadzor, announced on 16 September 2020 the approval of the first medical device according to the Eurasian medical device registration procedure including the completed manufacturing inspection of two manufacturing sites (located in Russia) for compliance with the quality management system requirements according to Eurasian Regulation #106.

It should be recalled that since March 2019, after a one-year transitional period, the quality management inspection system became a mandatory step for the Eurasian approval of medical devices of IIB–III risk classes; however, until today, many of the organizational and administrative requirements for such inspections, as well as the list of the organisations that conducted these inspections, were not clear.

In September 2019, the Russian Ministry of Health published a draft policy on determining the QMS inspection fees (link to the document in Russian); the policy elaborates on the inspection’s cost and calculation algorithms.

At the end of September 2020, there are four medical/in-vitro devices in the Eurasian database, all of them manufactured by Russian manufacturers.

3. Upcoming Deadline for the Administrative Replacement of the Obsolete Licences

In September, Roszdravnador reminded the industry that Russian registration certificates for medical devices issued before 2013 and having unlimited validity must be updated according to the special administrative replacement procedure by 1 January 2021; otherwise, after this deadline these licences will be annulled by the regulator.

The requirement to update old licenses was introduced in 2013, when Russia enforced a new medical device regulation system, and, after that, in 2017 the deadline for replacement was prolonged until 2021;

A detailed description of the replacement procedure is provided on the official site of Roszdravnadzor (in Russian) or here.

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Thank you for following my blog, which is the aim of providing timely and clear updates on the development of Russian and Eurasian medical device regulations. For Russian and Eurasian updates you might also be interested in my upcoming seminar or presentation on the MedTech summit.

Three Things You Should Know About Medical Device Regulations in Russia and the Eurasian Union – August 2020

Welcome to my monthly review of the most important updates to medical device regulations in Russia and the Eurasian countries.

 

  1. Development of the Regulations for Software as a Medical Device (SaMD) and Artificial Intelligence

On the 10th August 2020, the Russian Ministry of Health published order #686N (link in Russian) and updated the algorithm for the classification and registration of SaMD.

In addition, in early August 2020, the Russian Ministry of Health published two draft regulations:

  • An amendment to the rules governing the state registration of medical devices (link in Russian) suggesting an accelerated approval process (a one-step registration instead of the current two-step process) for SaMD, including software that uses ‘artificial intelligence technologies’.
  • An amendment to the requirements for technical files and the instructions for their use (link in Russian), providing specific requirements in relation to the technical files for SaMD.

It is interesting to mention that at the end of July 2020, the Russian Ministry of Health announced that work to improve the standards of artificial intelligence in healthcare was underway, and in the last month it has been revealed that a first draftof the national standard on clinical trials for systems with artificial intelligence has been published.

Regular readers might also recall that in June 2020, the Russian healthcare regulator Roszdravnadzor published the updated guidelines (national methodical recommendations) for the registration of SaMD in Russia (link in Russian).

The accelerated approval process for the registration of low-risk medical devices (class I) and in vitro diagnostics was implemented in Russia in 2018.

  1. List of Medical Devices Containing Ethyl Alcohol

On the 26th August 2020, Roszdravnadzor published (link in Russian) a list of 41 medical devices containing ethyl alcohol that are excluded from general alcohol regulations in Russia, such as Federal Law 171. The production, importation and circulation of these products will not be covered by the federal law on the regulation of ethyl alcohol and thus will not require additional licenses or permits.

According to the current procedure, this list is created using applications from manufacturers, or their authorized representatives, submitted to Roszdravnadzor between the 1st of January and the 30th of June each year, and subject to rules that came into effect in 2019.

It should also be noted that Russian legislation specifies that any medical device in liquid form containing ethyl alcohol (ethanol) should be subject to additional specific regulation.

  1. Eurasian Update

On the 3rd August 2020, the Eurasian Commission published a draft regulation with an amendment to the rules for toxicology (biocompatibility) testing of medical devices for Eurasian registration (link to the draft in Russian).

This document included updates to the testing requirements and the description of the testing procedure. The regulation also updated the criteria for the inclusion of testing laboratories into the unified Eurasian database.

For the end of August 2020, according to the official website of the Eurasian Commission, there were three medical devices approved using the Eurasian procedure with more than 20 applications for Eurasian registration submitted by manufacturers over the last year, and 23 laboratories now accredited to perform the testing.

 

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Thank you for following my blog, which is a non-commercial project with the aim of providing timely and clear updates on the development of Russian and Eurasian medical device regulations. Let me remind you that you can receive my regular updates directly to your email via the ‘follow’ button on the toolbar of this blog.

Three Things You Should Know About Medical Device Regulations in Russia and the Eurasian Union, July 2020

 

Dear colleagues,

Let me summarise the most important news and updates from the Russian medical device regulatory landscape in July 2020.

  1. Russia Abolished Certain Excessive Medical Device Regulations 

On 4 July 2020, the Russian government published the Resolution 982 (link in Russian) and, in the framework of the so-called ‘regulatory guillotine’, abolished some of the national medical device regulations. 

The most serious changes affected Russian post-market requirements for medical devices (i.e. the cancellation of Regulation 12N on adverse event reporting and Regulation 175N on safety monitoring) and their exclusion from the list of products requiring a GOST certification. 

The published resolution also abolished the regulation on the licensing of manufacturing and technical maintenance of medical equipment and the rules regarding the destruction of counterfeit medical products.

In addition, it will cancel 11 other minor regulations affecting medical devices, starting in January 2021. 

Later, on 29 July 2020, the Ministry of Health published a new draft of a regulation on medical device safety reporting (link in Russian) intended to replace the cancelled regulation. 

The ‘regulatory guillotine’ initiative was announced by the Russian government in 2018 as a measure to cancel the regulatory acts that are no longer effective for the excessive and inefficient regulation of business.

  1. Updated Medical Device Examination Requirements in Russia and Kazakhstan

On 24 July 2020, the Russian Ministry of Health released an updated version of the regulation on the examination of medical devices for their state registration (link in Russian), which replaced its obsolete version.

The document reflects recent changes in higher-level regulations and describes the examination procedures of medical devices (as a part of the registration process) depending on the class of the device or/and the type of submission (e.g. registration of low-class devices, in-vitro diagnostics; accelerated track for medical devices included in the emergency list; examination processes for registration renewals).
Similar changes have recently been implemented in Kazakhstan. The new version of the examination rules, released on 10 July 2020 (link in Russian), allows registration approvals without quality inspections of the manufacturers or/and type testing at the manufacturing sites as a response to the pandemic.

  1. Eurasian Technical Testing Requirements Updated and theSecond Product Approved

On 10 July 2020, the Eurasian Economic Commission published a draft of a regulation on technical testing requirements for Eurasian registration procedures (link in Russian).

The draft clarifies the testing procedures of medical devices for Eurasian registration and the requirements for the accreditation of testing laboratories.

As it was stated in the previous version of the regulation, the objective of technical trials is to demonstrate conformity to Eurasian essential safety and efficiency requirements and standards. The regulations allow testing one ‘typical model’. In cases of groups of similar products and of capital equipment, technical testing may be performed in the countries where the devices are installed. Technical testing is not required for in-vitro diagnostics.

At the end of July 2020, two medical/in-vitro devices have received Eurasian approval.

Response to COVID-19 in Russian and Eurasian Medical Device Regulations

Dear Colleagues,

This is my monthly update regarding changes to medical device regulations in Russia and the Eurasian Union; this month will be entirely devoted to a review of recent legislation changes related to the coronavirus COVID-19 outbreak:

  • On 26 March 2020, the Russian Ministry of Health announced a green channel regime for approval in Russia for medical devices intended for the diagnosis of coronavirus COVID-19 infection. The published letter on this matter (link in Russian) informs that ‘in condition on rules of submission of documents for registration are respected, medical devices intended for diagnosis of coronavirus infection will be performed in shortest time’. The same document also announced that pre-registration consultations with manufacturers regarding the approval of medical devices that are intended for the diagnosis of coronavirus COVID-19 infection are provided by expert institutions at no cost.
    However, it should be noted that this announcement does not introduce any new approval track/route, but rather expedites the existing testing and registration procedure.The first coronavirus IVD assay was approved in Russia, according to the information from the national medical device register, on 11 February 2020.
    For 30th March 2020, according to the Russian Minister of health, there are seven assays approved in Russia, and review of such applications <by the regulator> is performed “within one-two days”.
  • On 18 March 2020, the Russian government released the Resolution #299 (link in Russian) and simplified the registration route for 36 types of low-class, protective medical devices, including surgical/protective face masks, respirators, medical protective clothes, surgical suits, medical gloves, overshoes, and others.
    According to the published resolution, Roszdravnadzor, the Russian medical device regulator, will make a decision on the approval of such protective devices within five days from the receipt of the registration file; this will be carried out on the condition that a manufacturer provides documents confirming the safety and quality parameters of these devices (testing and trials reports) within five months from the approval from the regulator. In the case where discrepancies (between data submitted for registration and in the test reports) appear, such approval may be withdrawn. The above mentioned resolution was followed by methodical guidelines (link in Russian), clarifying a new, simplified procedure.
  • On 2 March 2020, the Russian government released the resolution #233 (link in Russian) and implemented a temporary ban on the exportation of certain types of medical devices and protective equipment from Russia, including face/surgical masks, respirators, protective glasses, medical protective clothes, and others – 16 types of medical products are included in the restriction list. According to this resolution, the export ban on these devices will be effective until 1 June 2020.
  • On 25 March 2020, the Eurasian Commission published the decision #25 (link in Russian) and annulled the importation customs fees for several medical devices intended for the diagnosis and prevention of COVID-19 infection, which are included in the special list provided in the same document – the list includes IVD assays, protective clothes, and personal protective medical products. The document grants exemption from fees on the importation of products on the list from 16 March until 30 September 2020, in the territory of the Eurasian Union.
  • Since 26 March 2020, the Russian parliament has been discussing the draft federal law (link in Russian), which may grant the Russian government the right to introduce a special procedure for the approval of medical devices, as well as the suspension of the wholesale and retail sale of medical devices in Russia for up to 90 days in the case of an emergency or epidemic.
  • All registration inspections for medical device manufacturers have been cancelled/postponed by the Ministry of Health of Belarus (link of the published letter in Russian), as well as the Kazak competent authority (link to the announcement in Russian).

The first cases of COVID-19 infection were reported in Russia on 31 January 2020, and until today the rate of infection continues to climb. On 30 March 2020, Russia closed its borders and imposed a nine-day national shutdown.

Three Things You Should Know about Medical Device Regulations in Russia and the Eurasian Union in February 2020

 

Dear colleagues,

I am pleased to deliver my usual end-of-the-month update on the highlights of medical device regulations in Russia and the Eurasian Union.

  1. Updated Criteria for Software as Medical Devices in Russia

On the 14th of February 2020, the Russian medical device regulator Roszdravnadzor published a letter that clarifies the criteria by which software may be considered a medical device (and require registration) and annulled previous requirements that had been applied to software since December 2015.

According to the letter, the Russian medical device regulator considers software to be a medical device when it meets all of the following criteria:

  • It is a computer program or its module (regardless of the program’s hardware platform and/or mode of distribution);
  • It is intended by the manufacturer to be used for medical care;
  • It is not a component of another medical device; and
  • It is intended to interpret sets of data received from medical devices, or entered by medical professionals, with the intention that the interpretations will be used for medical purposes.

According to several examples provided in the published document, medical software is not considered a medical device if it is intended for:

  • Hospital administration
  • Health and lifestyle management
  • The archiving and administration of medical data and medical images without the intention of interpreting them
  • The control and technical maintenance of medical equipment
  • Communication between doctors and patients
  • Educational and informational use
  • Receiving data from medical devices but not for medical care.

It should also be noted that, earlier in January 2020, the Roszdravnadzor announced plans to simplify the approval process for some IT healthcare products in Russia and to create a dedicated working group to discuss the registration of medical software.

  1. Draft on the Amendment to the Eurasian Medical Device Registration Procedure

On the 18th of February, the Eurasian commission published a draft document on an amendment to the rules of registration and examination of medical devices in the Eurasian Union (link in Russian). The current version of these rules (Regulation 46) is available in English.

The published draft suggests several clarifications and amendments to the definitions used in the regulations, as well as a clarification of the procedure by which member states accept registrations. It also suggests a protocol for making, and providing notification of, amendments to the registration dossiers of devices, and a clarification of the procedure for cancelling registration certificates.

The document is open for public discussion until the 20th of April 2020.

  1. Update on the Regulation of Medical Devices with Ethyl Alcohol

On the 9th of February 2020, the Russian healthcare regulator Roszdravnadzor enforced regulation 7975 ‘On approval of the regulation on the commission for the formation of a list of alcohol-containing medical devices, the production of which is not covered by the Federal law on the regulation of ethyl alcohol’ (Link in Russian).

Roszdravnadzor published a reminder to the industry that the process of forming this list is carried out on the basis of applications from manufacturers, or their authorized representatives, that are submitted to Roszdravnadzor between the 1st of January and the 30th of June.

It should be noted that the rules for the formation of the aforementioned list were enforced previously in July of 2019. Medical products included in this list are excluded from general alcohol regulations, such as Federal law 171, in Russia. According to this law, ‘alcohol-containing medical devices’ are medical devices in liquid form containing the pharmaceutical substance of ethyl alcohol (ethanol) or ethyl alcohol.

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Some other minor updates over the last month merit mention: Clarification letters have been published by the Russian Ministry of Finance regarding the application of a reduced tax rate for some medical devices (link in Russian). The tax rate for medical devices that will be applied after 2022 (link in Russian) and for custom-made medical devices (link in Russian). Several administrative regulations regarding the control of medical devices have also been cancelled (link in Russian) and replaced by new editions (link in Russian).

Russia and Kyrgyzstan approved the First Medical Device under the Eurasian Regulations

On 31 December 2019, the Russian healthcare regulator Roszdravnadzor announced first medical device approved under the Eurasian medical device regulations  First registration certificate was issued for 2A class neonatal phototherapy lamp manufactured in Russia.  The registration record has also appeared in the Eurasian database. 

Three Things You Should Know about Medical Device Regulations in Russia and the Eurasian Union in October 2019

 

Dear Colleagues,

Welcome to my monthly review of medical device regulatory changes in the Eurasian region:

  1. Eurasian Guidance on the Content and Structure of the Eurasian Medical Device Registration Dossier 

On 8 October 2019, the Eurasian Commission published Recommendation #29 ‘On methodical recommendations on the content and structure of documents of the registration dossier for a medical device’(link in Russian). This published document describes the requirements regarding the format, as well as language and legalisation, of documents covering 30 sections of the Eurasian registration dossier of a medical device depending on risk class. Annex II of the document provides guidance on the format of clinical data depending on the safety class of the device and date of clinical trials. Also included is the criteria for acceptance of clinical data from clinical centres outside of the Eurasian Union and requirements for clinical data for an analogue/equivalent device.

It should be noted that requirements for the registration file were previously published and can be found in Annex IV of Regulation #46 (link in Russian), and requirements for the content of technical files is in Annex II and Annex III of Regulation #29 (link in Russian).

  1. New Devices Added to the List of Regulated Implantable Devices in Russia

On 8 October 2019, the Russian government released Resolution #2333-R (link in Russian), which extended the list of medical devices which can be implanted into the human body for providing medical care under the programme of State Guarantees of Free Provision. According to the published document, there are four new types of devices including polymer ligation clips, ligation end loops, implantable dual chamber MRI compatible pacemakers and associated leads.

The prices for medical devices in the list for these programmes are regulated in the manner prescribed by Resolution #1517 released in 2015. 

For today, information about registered prices for these implantables is available on the official website of Russian healthcare regulator Roszdravnadzor 

  1. Kazakhstan Updated Medical Device Classification Guideline. 

On 2 October 2019, the Ministry of Health of Kazakhstan released Order #KR-DCM-129 (Link in Russian) and updated the rules for the classification of medical devices and in-vitro diagnostics in Kazakhstan. This document also contains rules for medical software classification. There are still four classes of medical devices categorised by invasiveness, duration of use, contact with patient, implementation with vital organs, and use of energy sources. Compared to previous revision, the structure of this new version of the Kazak classification is closer to the Eurasian medical classification; however, the two are not totally identical and still contain different classification algorithms. 

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It should also be mentioned that, in October 2019, some minor changes in tax regulations for medical devices have been enforced in Russia and several national GOST standards for plasters, surgical/operating room drapes, dental filling materials and hit implants have been updated and published.

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Your feedback, questions and comments regarding my updates are always welcome🙂

Three Things You Should Know About Medical Device Regulations in the Eurasian Union, September 2019

 

 Dear colleagues:

This is my monthly selection of updates on medical device regulations in the Eurasian region:

  1. Changes to the Eurasian Transition Period for Medical Devices

Here is the long-awaited update on the Eurasian transition period for medical devices. On 5 September 2019, the Eurasian Economic Commission published Decision no. 142 (link in Russian) which contained an approved draft of the proposed changes to a transition period for registration for medical devices. According to this document, if a medical device is approved in a Eurasian member state before 31 December 2021, it may be re-registered <only in this member state> using the local re-registration procedure until 31 December 2026. Such a device can be on sale in this member state <but not the whole Eurasian Union> until the expiry of the registration certificate.

Previously, the Eurasian Agreement on medical devices required re-registration of all medical devices using the Eurasian registration procedure before 31 December 2021. In the last two years, several proposals from Eurasian member states to change these transition deadlines have been discussed.

Registrations of new medical devices before 31 December 2021, can be submitted using either the local registration procedure or the Eurasian registration procedure. After 31 December 2021, all new medical devices should be submitted for registration using the harmonised Eurasian procedure only.

The Eurasian member states must first ratify (within 90 days) the draft of Decision no. 142 (link in Russian) before this comes into effect.

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While the Ministry of Health of Kazakhstan recently reported the first Eurasian approval of a pharmaceutical product,  activity on Eurasian medical device registration is still not too fast: for today there is still minimal information about products submitted for registration. Twenty-five laboratories are accredited to perform registration type testing. However, there is still no clarity as to when the quality management system (QMS) inspection, which is required for registration may begin.

  1. Draft Guidance to Determine the Costs of QMS Inspection in the Eurasian Union

On 2 September 2019, the Russian Ministry of Health published a draft policy for determining the fees for a QMS inspection before registration of the medical device can take place within the Eurasian Union (link to the document in Russian).

According to Regulation no. 106, which came into force in March 2018, the QMS inspection of manufacturing sites is mandatory for the registration of most IIA-III class medical devices in the Eurasian Union. The scope of the QMS inspection includes the assessment of quality sub-systems, i.e. design and development, document and record management, production and output control, corrective and preventive actions, and consumer-related processes.

The document proposes rules for calculating the cost of an inspection which depends on the number of employees of the enterprise and its location. The document also suggests the duration of the inspection is from four to eleven working days, and that the maximum cost is limited to 2,600,000 RUB (approx. 40,000 USD), excluding the cost of translation services.

  1. New Rules for Technical Testing of Medical Devices in Kazakhstan

On 6 September 2019, the Ministry of Health of Kazakhstan released Regulation KR DSM-124 (link in Russian) regarding technical trials for medical devices as part of the national registration procedure. According to the document, technical tests of medical devices (not required for in-vitro diagnostics) are carried out as type testing of samples or as data analysis (e.g. for some large-sized medical devices). These tests include assessment of the parameters provided in the technical or operational documentation, evaluation of the ‘design and operability of a medical device in terms of safety, ease of use, operational and ergonomic characteristics’, and an assessment of the labelling and packaging of a medical device. The duration of technical testing, according to the rules, should not exceed 30 calendar days.

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I would like to thank LIMI Consulting who helped me prepare the update regarding the Kazakhstan regulation in this post.