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Importing Investigational Devices for Clinical Investigation in Europe

December 3, 2023

The EU Medical Device Regulation (MDR) has established a rigorous regulatory framework for the entry of investigational devices into the European Union (EU) for clinical investigation. These regulations detail specific obligations for entities looking to introduce investigational devices for such studies. Leveraging the expertise of a specialized Medical Device Contract Research Organization (CRO) is crucial for navigating these regulations and ensuring a seamless entry process.

Essential MDR Provisions for Investigational Device Importation

The MDR delineates vital requirements for the importation of investigational devices:

  • Designation of an EU Legal Representative: Non-EU entities must appoint a representative within the EU to ensure adherence to MDR regulations. (See MDR Article 62)
  • Conformity with Labeling Standards: Labels on investigational devices must comply with MDR stipulations, encompassing usage instructions, risk information, and device safety and performance details. Compliance with specific language and symbol requirements is essential. (See MDR Annex I Chapter III)
  • Demonstration of compliance with the applicable GSPR: This encompasses, when applicable, conducting technical and biological safety assessments, along with pre-clinical evaluations. It also involves implementing measures in occupational safety and accident prevention, all while considering the current state of the art. (See MDR Article 62.4.l)
  • Adverse Event Surveillance: Manufacturers and sponsors are obligated to implement a system for tracking and reporting adverse events associated with the investigational device over its entire usage period, adhering to defined adverse event criteria and reporting timelines. (See MDR Article 80)
  • Compliance with MDR Article 21: Importation must adhere to MDR Article 21, ensuring the free movement of investigational devices within the EU for clinical investigation.

Role of a Medical Device CRO in Investigational Device Importation

A Medical Device CRO offers comprehensive support:

  • Regulatory Guidance: CROs provide deep insights into MDR complexities and keep abreast of regulatory updates.
  • Labeling Assistance: They ensure investigational device labeling is in full compliance with MDR.
  • Adverse Event Reporting System Establishment: CROs facilitate setting up compliant adverse event reporting systems.
  • EU Regulatory Communication: CROs act as liaisons with EU regulatory bodies, managing necessary communications on behalf of manufacturers.
  • Documentation and Submission Management: From preparing technical documents to managing submissions and responses to EU authorities, CROs play a pivotal role.

Benefits of Collaborating with a Medical Device CRO

Partnering with a CRO offers numerous advantages:

  • Simplified Regulatory Compliance: CROs handle regulatory complexities, freeing manufacturers to concentrate on development.
  • Reduced Compliance Risks: Expert advice from CROs minimizes the risks of non-compliance.
  • Efficient Market Entry: CROs expedite the process of bringing investigational devices to the EU market.
  • Cost Efficiency: By streamlining the importation process, CROs help in curtailing unnecessary costs.
  • Expertise Access: CROs offer specialized knowledge in medical device regulation and market entry strategies.


Navigating the MDR for the importation of investigational devices for clinical investigation demands diligent regulatory adherence and strategic planning. Engaging an experienced Medical Device CRO is key to ensuring a compliant and efficient pathway for bringing innovative investigational devices to the EU market.

MDx CRO: Your Strategic Partner for Investigational Device Importation

MDx CRO, a leader in Medical Device CRO services, excels in assisting sponsors and manufacturers through the MDR’s complexities. Our team, proficient in the nuances of the MDR, provides end-to-end support, ensuring your investigational devices are compliantly and effectively introduced into the European market.

With MDx CRO, you gain a partner committed to a compliant, streamlined, and successful introduction of your investigational devices in the EU. Contact us to discover how our expertise can enhance your clinical investigation endeavors.

*MDx offers assistance with the importation of investigational devices. MDx’s range of services does not include acting as an economic operator importer as defined under Article 13 of the EU MDR.

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