Essentially, A European authorized representative plays an intrinsic part in post-market surveillance, including vigilance. The Authorized Representative (AR) is your link to European authorities, and they must maintain physical presence in Europe. They will register your medical device or IVD before it is marketed, and will always be available to serve as a contact between you and the Competent Authorities of the EU member states.
Your European authorized representative will also have access to your Technical File(s), which must be available for inspection by the Competent Authorities. In other words, a variety of the responsibilities of the manufacturer are delegated to the European authorized representative.
What is the role of a European authorized representative?
Your European Authorized Representative serves as a liaison between you and the national Competent Authorities (Ministries of Health). Additionally, your appointed representative will:
- Assist with certain device registrations, as required.
- Be identified on your product labeling throughout Europe.
- Make a current copy of your Technical File or CE Declaration of Conformity available for inspection by a Competent Authority, upon request.
- Assist with Incident and Field Safety Corrective Action (FSCA) reporting, in cooperation with you and your distributors.
When is an EU Authorized Representative (EC REP) required?
The European Union requires any foreign manufacturer who intends to sell their devices in any of the Member States to designate a sole authorized representative (EC REP) with a physical address within one of the Member States.
The obligations of manufacturers under the EU’s Single Market product safety legislation are well understood. For manufacturers based in the EU, it’s simply the case that they are responsible for all aspects of compliance and if the Market Surveillance Authorities (MSA) within the EU need to identify someone to take responsibility for faulty products or incorrect paperwork then the trail of responsibility leads straight to, and stops at, the manufacturer’s door.
he European authorized representative is required to have a relationship with the manufacturer, and the terms of that relationship must be documented in a mandate agreed between the manufacturer and the AR. Monitoring and complying with European regulations can be challenging. Choosing an Authorized Representative for your medical device or IVD Company is a serious decision, one which will affect you for years. Careful consideration of the points outlined above – your needs, their experience, the company’s history, and the question of appointing a distributor – will help you make the best decision for your company.
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11. Medical Device Design And Development 16. 21 cfr part 820 18. DMF submission 19. CAPA Management
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