Accurate labelling of medical devices is vital for the safe and proper use of medical devices by patients and care givers and is a key thing to get right when bringing a product to market. ISO 13485 considers medical device labelling includes the label, instructions for use, and any other information that is related to identification, technical description, intended purpose and proper use of the medical device.
Accordingly, when designing and evaluating the medical device labelling, manufacturers need to make sure they consider and include the following 10 key pieces of information:
The information that you need to include on your medical device labels is determined by which market or markets you are going to sell your product in. Label requirements can vary according to country and region, and the ISO15223-1 Medical devices — Symbols to be used with information to be supplied by the manufacturer is a harmonised reference standard. Within the UK and EU, medical device labelling must comply with the ISO 15223-1 standard, and label information must be presented in the language of the market. Labelling requirements for the US are set out in the FDA’s quality system regulations subpart K 21 CFR Part 820.120.
In the UK, devices can have both the CE and UKCA markings present on the labelling. The name and address of the UK Responsible Person, where applicable, must be included on the product labelling or the outer packaging, or the instructions for use in cases where the UKCA marking has been affixed. UK Responsible Person details do not need to be included on labelling for CE marked devices, unless the device bears both the CE and UKCA markings. The importer or distributor’s name and address do not need to be present on the label unless the importer or distributor are acting as the UK Responsible Person for the purposes of the UKCA marking (reference).
Registration of your devices with the MHRA does not represent any form of accreditation, certification, approval or endorsement by the MHRA. Therefore, you are not permitted to make any claims to this effect, including the use of any MHRA logos in any marketing materials, on device packaging, in the instructions for use, on laboratory tickets/dockets, or in any other documentation (reference).
A simple procedure and checklist can be helpful to reduce the risk of errors in labelling design and packaging.
An example is set out overleaf.
Purpose
This procedure is designed to confirm the labelling requirements of the UK MDR have been addressed in accordance with the UK (MDR) 2002 as amended. The is achieved through compliance with the international standard ISO15223-1: 2021 Medical devices – symbols to be used with information to be supplied by the manufacturer .
Procedure
The procedure should be implemented once to confirm existing labelling is acceptable and subsequently triggered by proposed changes to the device.
Input
New medical device requiring labelling or existing labelling for medical device undergoing change.
Output
Compliant medical device label meeting the requirements of UKCA 2002 MDR as amended.
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