In-Vitro Diagnostic Regulation (IVDR)

Readiness Review
Company Name       Contact Name      
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How ready are you for the IVD Regulation?

EU Directives lay down certain end results that
The IVD industry is undergoing significant change. The IVDR, which must be achieved in every Member State.
replaces the IVD Directive (98/79/EC), entered into force on May National authorities have to adapt their laws to
25th 2017. This starts the transition period of five years for meet these goals, but are free to decide how to
manufacturers selling IVD devices into Europe. do so.

Manufacturers have the duration of the transition period to update Regulations are the most direct form of EU
their technical documentation and processes to meet the new law - as soon as they are passed, they have
requirements. BSI is committed to ensuring a smooth transition for binding legal force throughout every Member
all clients wishing to certify to the IVDR. State, on a par with national laws. National
governments do not have to take action
This document allows you to detail how you intend to meet the
themselves to implement EU regulations.
additional requirements of the new Regulation, please use in
conjunction with Regulation (EU) 2017/746. It is NOT an exhaustive
checklist but contains summary statements of the significant changes.

Completion of this form is not mandatory and does not need to form part of the transition process, but can help
with your internal preparation and be a useful tool for planning your transition strategy. Use the boxes below to
list procedures, records and examples that address the additional requirements. This can be used as a gap
analysis tool or as an aide memoire during your transition assessments.

Your BSI Team is here to support you on your journey, so please talk to us about your plans early on in your
preparation. Further information can be found BSI IVDR revision page www.bsigroup.com/IVDRRevision.
IVDR Readiness Review – Revision 1, March 2019 Page 2 of 13

Scope

The scope of the Regulation is more specifically defined compared to the Directive, and you
will need to check if you are affected by any of the following scope changes or clarifications.
Products newly or specifically defined under Article 2:
 ‘Prediction’ and ‘Prognosis’ of disease have been added to the definition of a medical device (MDR Article 2),
which will apply to some In vitro diagnostic devices (IVDs)

 IVD devices concerning the predisposition to a medical condition or a disease

 An IVD may be a device that is software or system, either integrated or standalone, which is used in vitro for
the examination of specimens

 IVD devices with a purpose is to predict treatment response or reactions

 IVD assays that are being used to provide diagnostic results either via the internet or as a ‘distant service’
(Article 6), where the result is being provided to an EU citizen.

You will need to provide information on any products that fall within the new Regulation, which were previously
not covered by the Directive:

Click here to type your response

Products required to meet Common

Specifications: Common Specification
Set of technical/clinical specifications other than a
 The Common Specifications (CS) under the IVDR is
not yet released, however, there are CS in standard, that allows compliance with legal obligations.
preparation for devices that are envisaged to be These may address general safety and performance
Class D under the IVDR that are currently not Annex requirements, clinical investigations, clinical evaluation or
II List A under the Directive. It is believed that the post-market clinical follow up.
Common Technical Specifications (CTS) for the IVD
Directive will convert to CS for the IVDR. Implementing acts
 Devices that are currently Annex II List A devices Include implementation measures that can be issued after
under the IVD Directive will most likely be Class D the Regulation has been published. These are changes
under the IVDR. These devices are already expected that are considered to be more procedural (eg templates,
to meet the CTS under the current IVDD. procedures, deadlines), and are used to ensure uniform
 There will be IVD devices that are not listed under application of “how” legislation is to be implemented.
Annex II of the IVD Directive, which will become
Class D devices under the IVDR. Delegated acts
 BSI believe there will be other devices for which Allow amending, supplementing, or deleting non-essential
Common Specifications will be issued. You should elements of the legislative act. These acts have the power
monitor the development of CSs for your devices to change the basic requirement, or “what” of these non-
that you think will be Class D under the IVDR. essential legislative elements. The power to adopted
delegated acts extends only until 25 May 2022.

EU Reference Labs and Expert Panels

 The IVDR brings on line a new network of EU Reference Laboratories’ (EURLs). A EURL will be involved in
 IVDR Readiness Review – Revision 1, March 2019 Page 3 of 13

verifying the performance claims of Class D devices during the conformity assessment under the IVDR.

 EU reference laboratories will verify by laboratory testing the performance claimed by the manufacturer and the
compliance of devices presenting the highest risk with the applicable CS, when such CS are available, or with
other solutions chosen by the manufacturer to ensure a level of safety and performance that is at least
equivalent.

 If your device will be class D but does not currently have a CS (or CTS under the IVDD), the first device placed
on the market under the IVDR of its type will be required to go for an additional expert panel review.

You will need to provide information on:

 ‘If your device will be Class D but does not currently have a Common Specification (or Common Technical
Specification under the IVDD), the first device placed on the market (undergoing conformity assessment) of its
type will go to an expert panel’

 ‘New’ Class D devices will need to allow for potentially more transition time to the IVDR to allow for expert
panel review.

 Details of CTS currently used and how you will transition to the new CS under the Regulation.

 Processes to check for publication of and/or changes in Common Specifications, Implementing Acts and
Delegated Acts

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Classification (Article 47 & Annex VIII)

The classification of IVDs has been radically transformed from a list-based approach in the Directive, to a rule-
based approach in the Regulation. The rule-based approach comprises of four risk categories, from Class A
(lowest risk) to Class D (highest risk).

IVDR Classification rules:

 Rule 1 Devices intended to be used for the following purposes are classified as class D:
o detection of the presence of, or exposure to, a transmissible agent in blood, blood components,
cells, tissues or organs, or in any of their derivatives, in order to assess their suitability for
transfusion, transplantation or cell administration;
o detection of the presence of, or exposure to, a transmissible agent that causes a life-threatening
disease with a high or suspected high risk of propagation;
o determining the infectious load of a life-threatening disease where monitoring is critical in the
process of patient management.
 Rule 2 Devices intended to be used for blood grouping, or tissue typing to ensure the immunological
compatibility of blood, blood components, cells, tissue or organs that are intended for transfusion or
transplantation or cell administration, are classified as class C,
o except when intended to determine any of the following markers: — ABO system [A (ABO1), B
(ABO2), AB (ABO3)]; — Rhesus system [RH1 (D), RHW1, RH2 (C), RH3 (E), RH4 (c), RH5 (e)];
— Kell system [Kel1 (K)]; — Kidd system [JK1 (Jka), JK2 (Jkb)]; — Duffy system [FY1 (Fya),
FY2 (Fyb)]; in which case they are classified as class D.
 Rule 3 Devices are classified as class C if they are intended:
IVDR Readiness Review – Revision 1, March 2019 Page 4 of 13

o (a) for detecting the presence of, or exposure to, a sexually transmitted agent;
o (b) for detecting the presence in cerebrospinal fluid or blood of an infectious agent without a
high or suspected high risk of propagation;
o (c) for detecting the presence of an infectious agent, if there is a significant risk that an
erroneous result would cause death or severe disability to the individual, foetus or embryo being
tested, or to the individual's offspring;
o (d) for pre-natal screening of women in order to determine their immune status towards
transmissible agents;
o (e) for determining infective disease status or immune status, where there is a risk that an
erroneous result would lead to a patient management decision resulting in a life-threatening
situation for the patient or for the patient's offspring;
o (f) to be used as companion diagnostics;
o (g) to be used for disease staging, where there is a risk that an erroneous result would lead to a
patient management decision resulting in a life-threatening situation for the patient or for the
patient's offspring;
o (h) to be used in screening, diagnosis, or staging of cancer;
o (i) for human genetic testing;
o (j) for monitoring of levels of medicinal products, substances or biological components, when
there is a risk that an erroneous result will lead to a patient management decision resulting in a
life-threatening situation for the patient or for the patient's offspring;
o (k) for management of patients suffering from a life-threatening disease or condition;
o (l) for screening for congenital disorders in the embryo or foetus;
o (m) for screening for congenital disorders in new-born babies where failure to detect and treat
such disorders could lead to life-threatening situations or severe disabilities.
 Rule 4 Self-testing and near-patient testing
o (a) Devices intended for self-testing are classified as class C, except for devices for the detection
of pregnancy, for fertility testing and for determining cholesterol level, and devices for the
detection of glucose, erythrocytes, leucocytes and bacteria in urine, which are classified as class
B.
o (b) Devices intended for near-patient testing are classified in their own right.
 Rule 5 The following devices are classified as class A:
o (a) products for general laboratory use, accessories which possess no critical characteristics,
buffer solutions, washing solutions, and general culture media and histological stains, intended
by the manufacturer to make them suitable for in vitro diagnostic procedures relating to a
specific examination;
o (b) instruments intended by the manufacturer specifically to be used for in vitro diagnostic
procedures;
o (c) specimen receptacles.
 Rule 6 Devices not covered by the above-mentioned classification rules are classified as class B.
 Rule 7 Devices which are controls without a quantitative or qualitative assigned value are classified as
class B.
 IVDR Readiness Review – Revision 1, March 2019 Page 5 of 13

Manufacturers are recommended to evaluate Annex VIII fully prior to completing the section
below.
You will need to provide information on the new classification of your devices:

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Device IVDD classification IVDR Classification

X X x

Routes of Conformity (Article 48)

Scrutiny
The Notified Body must consult with the
Products that may have changed route of conformity:
Commission on the adequacy of the clinical
 All IVD devices will have a new classification under the IVDR.
evaluation and PMCF plans prior to granting
Depending on whether you have a CE certificate under the IVD
certificates for new Class D products.
Directive, under Annex II will affect whether the re-
classification changes your conformity assessment route
Competent Authority
 If your device is listed under Annex II List A or B of the IVDD, The Competent Authority is a body with authority
your device is most likely to be Class D or Class C under the to ensure legal enforcement of the Regulation
IVDR. For these devices, there may not be a significant change within their Member State, to investigate vigilance
to your conformity route. However, you will need to assess the issues and to remove unsafe or fraudulent devices
new expectations under the IVDR on evidence of conformity
from the Market.” The Competent Authority is
and role of EU Reference Laboratories.
also responsible for designating one or more
Notified Bodies, to act as independent third party
assessors of the manufacturer’s compliance.

European Medicines Agency (EMA)

The EMA is responsible for the scientific
evaluation, supervision and safety monitoring of
medicines developed by pharmaceutical companies
 IVDR Readiness Review – Revision 1, March 2019 Page 6 of 13

 IVDs that were ‘self-certified’ under Annex III of the IVD Directive will most likely need to change conformity
route, unless your device is Class A (non-sterile) under the IVDR.

 Class D or C devices will need to apply for either Quality Management System (QMS) Insurance Annex IX
(Article 48, clause 7 for Class D, clause 7 and 8 for Class C) or Type examination Annex X and production
quality assurance Annex XI (Article 48, clause 4 for Class D, clause 8 for Class C) under the IVDR.

 Class B devices will need to apply for a Quality Management System assurance Annex IX certificate (Article
48, Clause 9).

 For specific devices there will also need to be an application for assessment of technical documentation, in
particular Class D devices, self-tests (class B, C or D), near patient tests (class B, C or D) and companion
diagnostics.
For other devices, there will be an assessment of technical documentation on a sampling basis as part of the
QMS or Type/QA conformity routes, per generic device group (Class C) or subcategory of devices (Class B).

 All Class D devices will require verification of performance by an EU Reference Laboratory, in addition to
batch testing following certificate issue.

 Class D devices may undergo additional scrutiny (article 50) or expert panel review (article 48.6).

 Companion diagnostic devices under rule 3(f) require consultation with a national Competent Authority or
EMA (article 48.8).
 Class A devices may undergo conformity assessment via self-certification, however, if the Class A device is
provided sterile it will need to submit an application for Notified Body assessment with respect to the sterility
aspects (Annex IX or Annex XI).

 Please note that the Regulation does not have an equivalent to the Directive’s EC verification
conformity route (98/79/EC Annex VI)

Devices shall be divided into classes A, B, C and D, taking into account the intended purpose of the
devices and their inherent risks. Conformity assessment shall be carried out in accordance with
Annex IX or Annex X + ANNEX XI.
Self-test: means any device intended by the
Although the Regulation indicates there are four manufacturer to be used by lay persons,
classes of device, the routes of conformity also including devices used for testing services
reference some specific types of devices that will have offered to lay persons by means of information
additional requirements as part of the conformity society services.
assessment.
You will need to review and group your devices based on: Near-patient test: means any device that is not
 Class D devices (including self-tests and near patient tests) intended for self-testing but is intended to
perform testing outside a laboratory
 Self-test devices
environment, generally near to, or at the side of,
o Class C the patient by a health professional;
o Class B
Companion Diagnostic: means a device which
 Near-patient test devices
is essential for the safe and effective use of a
o Class C
corresponding medicinal product to: (a) identify,
o Class B before and/or during treatment, patients who
 Companion diagnostic devices are most likely to benefit from the corresponding
medicinal product; or (b) identify, before and/or
 Other Class C devices
during treatment, patients likely to be at
 Other Class B devices increased risk of serious adverse reactions as a
 Class A devices that are provided sterile. result of treatment with the corresponding
 Other Class A devices medicinal product.
IVDR Readiness Review – Revision 1, March 2019 Page 7 of 13

Click here to type your response

Device IVDD route to conformity IVDR route to conformity

X X x
IVDR Readiness Review – Revision 1, March 2019 Page 8 of 13

Quality Management System

QMS Requirements to be assessed for ALL IVDR EC Certifications from 26 May 2022
This includes:
 New requirements for performance evaluation, clinical evidence and post market performance follow-up
(Article 56)
 Process/Procedure for communication with Commission/Member States to obtain SRN (Article 28)
 Registration of Economic Operators including Single Registration Number (Article 28)
 Systems for Market Surveillance (activities described in Article 88)
 Systems for Serious Incident, Field Safety Corrective Action (Article 84) and Trend Reports (Article 83)
 New requirements for vigilance reporting i.e. maximum duration to report 15 days (Article 82)
 Systems for PMS Plan and Report (Article 79, Article 80)
 Systems for Periodic Safety Update Report (Article 81)

Additional QMS Requirements for IVDR Applications

You will need to provide information on:
 All systems for reclassification of devices or devices new to the scope of the IVDR (see previous
sections)

 Strategy for regulatory compliance (Article 10)

 The new role of Person Responsible for Regulatory
Compliance, PRRC, (Article 15)
Single Registration Number (SRN)
 Unique Device Identification and Registration (Article 24, 25)
A unique reference number given to
 Handling communication with regulatory authorities, Notified manufacturers, authorized representatives
Bodies, economic operators (Article 10) and importers.

 Economic Operators Registration (Article 28) and Single

Unique Device Identifier (UDI)
Registration Number (Article 28(2))
Series of characters defined through
 EU Authorised Representative i.e. written mandate (Article internationally accepted coding to identify
11), SRN (Article 28), PRRC (Article 15) a specific device on the market.
 Importers i.e. SRN (Article 28), QMS (Article 13)
EUDAMED
 Distributors i.e. QMS (Article 14) An information system for exchanging
 A process to identify General Safety & Performance Requirements legal information
(GSPR) (Article related
10). Seeto the
moreapplication
below.
of European Union Regulations.
 New post-market obligations for devices

 New vigilance requirements.

Changes in Activity in BSI Audits

 All QMS audits to carry out or ask for physical/laboratory tests in order to check the QMS is working
properly
 Unannounced Audits frequency at least once every five years
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 IVDR Readiness Review – Revision 1, March 2019 Page 9 of 13

General Safety & Performance Requirements (GSPR).

The GSPRs replace the IVD Directive’s Essential Requirements.

New Requirements
You will need to provide information on:

GSPR Number Comments

2, 3, 4, 5, 8 Risk Management to EN ISO 14971:2012
9. Performance characteristics
10. Chemical, physical and biological properties
11. Infection and microbial contamination
12. Devices incorporating materials of biological origin
13. Construction of devices and interaction with their environment
14. Devices with a measuring function
15. Protection against radiation
16. Electronic programmable systems – devices that incorporate electronic programmable
systems and software that are devices in themselves
17. Devices connected to or equipped with an energy source
18. Protection against mechanical and thermal risks
19. Protection against the risks posed by devices intended for self-testing or near-patient
testing

Label and instructions for use:

20  General requirements regarding the information supplied by the manufacturer
 Information on the label
 Information on the packaging which maintains the sterile condition of a device
(‘sterile packaging’)
 Information in the instructions for use
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Technical Documentation
Your application to a Notified Body will require submission of Technical Documentation, either
under Annex IX or Annex X.
The submission of Technical Documentation should show the evidence of conformity to the GSPRs. it is advised
that a summary is provided which covers all relevant points of Annex II and Performance evaluation and clinical
evidence, refer to XIII.
For existing CE marked devices (either via a Notified Body or those devices which have been ‘self-declared) a
new full application will be needed to include all technical documentation as outlined by the new regulation.

Clinical Evidence
IVDR Readiness Review – Revision 1, March 2019 Page 10 of 13

The term ‘performance evaluation’ has been redefined by the IVDR. There is a new requirement to
demonstrate how a manufacturer plans to evaluate the performance of the device (‘performance
evaluation’), and the output of the performance evaluation as a collation of clinical evidence in the
form of a ‘Performance Evaluation Report’ (Article
56, Annex II, Annex XIII).
You will need to provide to the notified body:
Performance Evaluation
 A Performance Evaluation Plan (Annex XIII Part A ‘performance evaluation’ means an assessment
(1.1)) and analysis of data to establish or verify the

You will need to provide to the notified body a

Performance Evaluation Report (Annex XIII 1.3.2):

 A scientific validity report (Annex XIII Part A (1.2.1))

 An analytical performance report (Annex XIII Part A

(1.2.2))

 A clinical performance report (Annex XIII Part A (1.2.3))

 Conclusions drawn from assessment of the clinical

evidence (Article 56, 3.; Annex XIII 1.3.1)

 Clinical performance studies shall be performed unless

due justification is provided for relying on other sources
of clinical performance data (Annex XIII 1.2.3)
 Unless duly justified, self-test and near-patient test
devices should have data from clinical performance
studies performed in the environment in which the
device is intended to be used
 Additional requirements for certain types of
performance studies (Article 58):
 Interventional clinical performance studies (Annex
XIV)
 Performance studies on incapacitated subjects
(Article 60)
 Performance studies on minors (Article 61)
 Performance studies on pregnant or breastfeeding
women (Article 62)
 Performance studies in emergency situations
(Article 64)
 Requirements for obtaining informed consent (Article 59).
 For Class C and D devices a Summary of Safety and Performance will be needed (Article 29).

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Post-Market Surveillance (PMS) Requirements

Post-market surveillance (Article 88), market surveillance, vigilance, registration of economic

IVDR Readiness Review – Revision 1, March 2019 Page 11 of 13

operators shall be applicable to ALL devices placed on the market or put into service from the date
of application, 26th May 2022.
This includes:
 PMS Plan (Article 79). A PMS Plan shall be provided at the time of initial application.
 PMS Report (Article 80)
 Periodic Safety Update Report (Article 81)
 Serious Incident, Field Safety Corrective Action (Article 82)
 Trend Report (Article 83)
 Market Surveillance (activities described in Article 88)

 Registration of Economic Operators including Single Registration Number (Article 27, 28)

You will need to provide information on:

 How to meet the new IVDR requirement i.e. maximum duration to reporting 15 days
 Meet the new IVDR requirement on post market performance follow-up
 Process/Procedure for communication with Commission/Member States to obtain SRN
 Process/Procedure to provide PSUR at frequency described by Article 81
 EU Authorized Representative i.e. written mandate (Article 11), SRN (Article 28), PRRC (Article 15),
 Importers i.e. SRN (Article 28), QMS (Article 13)

 Distributors i.e. QMS (Article 14)

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IVDR Readiness Review – Revision 1, March 2019 Page 12 of 13

Other Changes

New requirements
You will need to provide information on:
 Declaration of Conformity (Article 17 & Annex IV)
 Unique Device Identification –Based on the classification of the device (transition provision 113) UDI
obligations will come into act from:
 Class D: 26 May 2023
 Class C and B: 26 May 2025
 Class A: 26 May 2027.
 EUDAMED – obligations start from the date of application (Article 30). There are transition arrangements
for the implementation of EUDAMED under Article 110.

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 IVDR Readiness Review – Revision 1, March 2019 Page 13 of 13

When responses are complete please share with your Scheme Manager as “readiness review”; this will help plan
the transition described by Article 110.

Find out more about how BSI can

support your transition by visiting
our website
or call: +44 345 080 9000

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T:+44 345 080 9000F:+44 1908 Place, 979 King’s Road,Island
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