MDR Transition for Class III Implant Manufacturer
Leading European orthopedic implant manufacturer
The Challenge
The manufacturer had over 200 legacy MDD-certified products requiring transition to EU MDR (2017/745) compliance before the 2028 deadline. Their existing technical documentation had been developed under MDD standards and fell significantly short of the MDR Annex II and Annex III requirements. With no internal regulatory team experienced in MDR-level submissions, the company faced the prospect of losing CE marking for its entire portfolio.
Our Approach
Swiss MPC assembled a dedicated cross-functional team of senior regulatory consultants, clinical affairs specialists, and technical documentation experts. The engagement began with a comprehensive portfolio-wide gap analysis, evaluating each product family against the full scope of EU MDR Annex II (Technical Documentation) and Annex III (Post-Market Surveillance) requirements. This analysis identified over 1,400 individual documentation gaps across the 200+ product portfolio.
Based on the gap analysis findings, we developed a risk-prioritized transition roadmap that grouped products into families sharing common intended purposes, materials, and manufacturing processes. This family-based approach allowed us to create template structures and shared evidence packages, dramatically reducing redundant work while maintaining the specificity required for each individual product file.
Our clinical affairs team conducted updated Clinical Evaluation Reports (CERs) for each product family, incorporating systematic literature reviews per MEDDEV 2.7/1 Rev. 4, equivalence assessments under the stricter MDR Article 61 criteria, and identification of residual clinical data gaps requiring Post-Market Clinical Follow-up (PMCF) studies. For Class III implants, we prepared the clinical evidence packages to the heightened scrutiny standard expected by Notified Bodies under MDR.
The regulatory strategy team managed all Notified Body interactions, including pre-submission meetings, query responses, and audit preparation. We implemented a structured document management system with version control and review workflows to ensure consistency across the entire portfolio and enable efficient Notified Body review.
Throughout the project, we embedded knowledge transfer sessions with the client's internal quality and regulatory teams. This ensured the manufacturer would have the in-house capability to maintain MDR compliance for ongoing post-market obligations, product modifications, and future product launches without continued external dependency.
Results
55%
Timeline reduction
100%
First-submission acceptance
200+
Products transitioned
1,400+
Documentation gaps closed
“Swiss MPC's structured approach transformed what seemed like an insurmountable regulatory challenge into a manageable, systematic process. Their senior consultants understood the nuances of Class III implant submissions and delivered documentation that our Notified Body accepted without major findings on first review.”
VP Regulatory Affairs
European Orthopedic Implant Manufacturer
Topics & Standards
Services Used in This Project
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