EU MDR • Regulatory Affairs

EU MDR Transition - IFU & Label Update

Published • • 1 min read

Building Table 2 (Technical Documentation Correlation to International Standards) and Table 3 (General Safety and Performance Requirements) showed that IFU and label content has to be re-validated against the MDR General Safety and Performance Requirements directly, not just copied forward from the MDD-era documents.

Table 2 and Table 3 exist to correlate technical documentation against international standards and General Safety and Performance Requirements, and building them surfaced exactly where IFU and label content still traced back to MDD-era assumptions.

Correlation tables expose copied-forward content

Populating a correlation table forces every referenced requirement to be checked directly. Content that was copied forward from MDD-era documents without re-validation shows up immediately as an unsupported or missing correlation.

Building Table 2 and Table 3 required:
  • Mapping each MDD-era requirement/document against its MDR equivalent using the technical documentation correlation tables
  • Verifying against applicable harmonized standards
  • Tracking action items to closure in the quality plan

What an unmapped requirement risks

An MDD-era requirement with no confirmed MDR equivalent, left unmapped in the technical file, is exactly what these correlation tables are designed to catch before a notified body does.

What the tables delivered

Updating the IFU/label content to reflect current MDR requirements closed the labeling gap identified during the transition review, once Table 2 and Table 3 made the gap visible.

The Real Takeaway

IFU and label content has to be re-validated against the MDR General Safety and Performance Requirements directly.

Not just copied forward from the MDD-era documents.

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