The medical device renewal system was introduced to periodically re-examine the safety and effectiveness of medical devices that have been approved, certified, or notified, and to delist products with no manufacturing or import records. The key issue ...
The medical device renewal system was introduced to periodically re-examine the safety and effectiveness of medical devices that have been approved, certified, or notified, and to delist products with no manufacturing or import records. The key issue in the current renewal system is that, when the standards and specifications applied at the time of authorization differ from the latest standards and specifications at the time of renewal, manufacturers are required to submit test reports or evaluation data, while specific criteria for determining the level of renewal submission data have not been provided. Therefore, this study compared the CE re-certification system under the European Union Medical Device Regulation (EUMDR) and the system of the United States, which does not have a separate renewal system but operates a post-market management framework. Although the European Union and the United States differ from Korea in terms of regulatory operation, they share a common approach in that changes in standards or specifications are not treated as independent determining factors by themselves, but are considered together with product changes and post-market safety information. These comparative findings indicate that, in Korea’s medical device renewal system, the need for test reports or evaluation data should not be determined solely based on differences between the standards and specifications applied at the time of
authorization and the latest standards and specifications at the time of renewal; instead, product changes after authorization and safety information should also be considered.
This study selected non-absorbable sutures as a case product because changes in relevant standards and specifications can be clearly identified, including common standards and specifications for biological safety, medical device standards and specifications for non-absorbable sutures, KS P 3005 for medical suture needles, and stability testing standards. The purpose of this study was to propose criteria for reasonably determining the submission level of data demonstrating conformity with the latest standards and specifications under Korea’s medical device renewal system. To this end, the types of changes in detailed standards and specifications were classified into maintenance, relaxation, tightening, and addition, and these were established as a primary analytical framework for determining the submission level. Subsequently, by considering product changes after authorization and safety information together, the submission levels at the time of renewal were classified into: Level 1 (use of existing test data), Level 2 (submission of evaluation data), and Level 3 (conduct of additional testing). Level 1 applies when existing test data can explain the safety and performance of the current product. Level 2 applies when existing test data alone are partially insufficient, but the safety and performance of the current product can be explained through evaluation data that comprehensively consider differences in standards and specifications, existing test results, product changes after authorization, and safety information. Level 3 applies when the safety and performance of the current product cannot be explained even with existing test data and evaluation data, when the impact of product changes cannot be sufficiently justified through evaluation data, or when safety and performance need to be confirmed due to repeated or significant safety signals.
This study is meaningful in that it proposes criteria for determining the submission level of data demonstrating conformity with the latest standards and specifications, not merely based on whether standards and specifications have been newly established or revised, but by considering the impact of changes in standards and specifications on the explanatory applicability of existing test data, together with product changes after authorization and safety information. These criteria may serve as a basis for clarifying the direction of renewal data preparation for manufacturers and importers, and for specifying the criteria used by review authorities to determine the appropriate submission level.