The MDR introduces Annex XVI products, which are products without an intended medical purpose, often used for beauty or cosmetic purposes. While these products do not serve a medical function, they are now strictly regulated under the MDR. Due to the stringent requirements, developers and manufacturers are encountering challenges in achieving compliance, necessitating the involvement of highly skilled and experienced professionals.
Additionally, the regulation of non-medical products is a new concept in the EU, making the development and certification of such products complex and requiring a comprehensive, well-informed approach.
If your product is now regulated under the MDR, the first step is to assess where your product and company stand in relation to the new requirements. We offer support through a detailed gap analysis, identifying where your current setup falls short and working with you to create a roadmap for compliance.
A well-defined strategy is crucial when bringing Annex XVI products to market. This strategy should outline the end goal and the steps needed to reach compliance. Our team of medical device experts can assist you in crafting a clear and actionable plan that meets all regulatory requirements.
Bringing your company and products into compliance is a complex process that requires dedicated effort. Depending on your needs, our experienced medical device team can become an integral part of your team, offering support across various roles, such as regulatory affairs (RA), quality assurance (QA), clinical evaluation, risk management, and more.
Under the MDR, clinical evaluation is the process of confirming a device's conformity with the relevant general safety and performance requirements outlined in Annex I. For Annex XVI products, demonstrating clinical benefit is interpreted as proving the performance of the device, which further complicates the clinical evaluation process. Our clinical experts are ready to provide essential insights or even conduct a complete clinical evaluation for your Annex XVI product, ensuring compliance with these stringent requirements.
Annex XVI products, although without a medical purpose, are now subject to the same rigorous clinical investigation requirements as medical devices. This means they must meet high industry standard ISO 14155. By following this standard and adopting a tailored approach for Annex XVI products, manufacturers can generate clinical data that is both sufficient in quantity and high in quality. A well-structured clinical development program is crucial for successful compliance. Our clinical experts are here to assist you in developing and implementing such a program.
The general risk management approach outlined in ISO 14971, which is commonly used for medical devices, also applies to Annex XVI products. This can be particularly challenging if you are not familiar with the standard. ISO 14971 requires building and maintaining a risk management system, applying it to all products, identifying potential hazards, mitigating risks to an acceptable level, and ensuring user safety. The Common Specifications provide a detailed list of hazards and risks that must be addressed for each category of Annex XVI products. Our medical device team is ready to assist you in navigating the complexities of risk management for your Annex XVI product, ensuring compliance and safety.
We handle Annex XVI products in multiple ways
What can we do for you?
Our regulatory experts support you at any stage of MDR Annex XVI compliance. Whether you’re new to Annex XVI or seeking to meet updated requirements, we offer tailored solutions, including gap analysis, strategic planning, clinical evaluation, and risk management. We help ensure your product is safe, compliant, and ready for market, guiding you through the stringent demands of MDR Annex XVI.
Approach & Expertise
Learn how we can support you in meeting your business goals
- Our lean and powerful team with degrees in pharmacy, chemistry, biology, or related studies strive to be of added value to you. Our short reporting lines enable the most efficient road to your success.
- Having one point of contact from our experts backed by the team’s collective knowledge and resources we give reliable advice and execute projects seamlessly.
- At Starodub, consistency and assurance of quality are vital. A quality management system has been implemented and we adhere to GxP and ISO 9001/13485.
Questions from our clients
FAQ Section
Annex XVI products were introduced into the EU regulatory framework with the adoption of the MDR. While these products do not serve a medical purpose, they are now regulated similarly to medical devices due to the potential risks they pose to users.
According to Article 1(2) of the MDR, Annex XVI products must comply with specific Common Specifications. Although the MDR came into force in 2017, there was a long transitional period for its full application. The Common Specifications, which were expected by May 2021, remained unclear for some time. It wasn’t until December 2022 that the European Commission adopted Implementing Regulation 2022/2346, which outlined the Common Specifications for Annex XVI products. These specifications introduce additional safety, risk management, and labeling requirements, as well as provide a new transitional period for compliance.
The implementation of these Common Specifications is still relatively new, and there remains a lack of expertise and certification experience in this area, making the process of bringing Annex XVI products to market particularly challenging.
Although the entire MDR applies to Annex XVI products with few exceptions, the Common Specifications, outlined in Implementing Regulation 2022/2346, introduce additional rules. These include seven annexes:
- Annex I defines general requirements for all Annex XVI products.
- Annexes II-VII provide specific guidelines for different product groups.
These annexes highlight particular risks that need to be addressed and set additional safety labeling requirements.
Compliance with these specifications will be crucial during the conformity assessment process conducted by Notified Bodies.
At present, there are no specific guidelines for bringing Annex XVI products to market. Since the Common Specifications were only recently adopted, there is still limited industry knowledge on how to fully implement these requirements. However, with a skilled team experienced in medical device development and certification, achieving compliance is a realistic goal.