EU MDR & MDD Redundant Certification

EU MDR & MDD Redundant Certification

July 6, 2021

EU MDR & MDD Redundant Certification

 

An MDD-certified device is generally eligible for participation in the EU MDR Article 120(2) and/or (3) 2024 transitional buffer.

 

 

An MDD-certified device is generally eligible for participation in the EU MDR Article 120(2) and/or (3) 2024 transitional buffer.  In that case, the MDD DoC can remain in effect (pursuant to certain EU MDR limitations) until replaced and/or supplemented by an EU MDR certificate and DoC.  But once EU MDR conformity is achieved, then I know of no legislative reason to thereafter redundantly maintain the MDD certificate, though I suppose there could be business reasons for such redundancy.  For the latter, it would mean a) that the manufacturer is willing to pay the NB(s) for the additional/duplicative conformity assessment services; and b) if the same NB will be used for both certifications, then such NB i) has the bandwidth and willingness to support such redundancy; and ii) such dual certification doesn’t violate the impartiality clauses (such as those in 4.2.4 regarding self-interest and familiarity) of the ISO 17021 standard(s) governing the NB.  Other than that, I can’t bring to mind other reasons that would prohibit such dual certification by a single NB.  But be sure to consult the NB involved so as to determine its particular stance on the matter.

 

Regarding significant changes to an existing MDD-compliant install base, refer to my related blog posts here and here.

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