Staying Aligned: Why Timely Notification of Change Matters in Medical Device Certification

At Kiwa Assurance, we recognize that innovation is a constant in the medical device industry. But change comes with responsibility—especially when it comes to maintaining compliance under the MDR and ISO 13485. That’s where our Notification of Change (NoC) process plays a vital role.

Whether you're updating your quality management system, modifying a device’s intended purpose, or adding a new production site, it’s essential to notify us before implementing the change. Even seemingly minor updates can have a significant impact on your certification status, especially when they are noticed too late.

What types of changes require notification?

For example:

  • Changes to your QMS that may affect compliance
  • Modifications to device intended use
  • Adjustments in manufacturing processes or critical suppliers
  • Additions to your product range or Basic UDI

How does the process work?

Manufacturers submit a change notification form, which is reviewed by our experts. Depending on the nature of the change, this might lead to actions such as:

  • A supplement or amendment to your certificate
  • A new application review (for example, in case of scope expansion)
  • Updates to your technical documentation sampling plan

Transparency and timely communication are key to support your innovation while safeguarding patient safety and regulatory compliance. Late submissions often lead to surprises that could have been avoided.

Important:

  • The earlier you send us the notification, the earlier you’ll know what to expect. 
  • Substantial changes shall be approved by Kiwa Assurance before implementation.
  • Acting prematurely can invalidate your certificate and lead to regulatory consequences.

Note1 : The concept of a “significant change” is specific to MDD legacy devices and is defined under MDCG 2020-3. For MDR-certified devices, we assess substantial changes.

Note2 : Want to learn more about how we assess changes? Reach out to our team or consult the information package on our website.

Note3: The NoC process is subject to future updates in alignment with evolving regulatory guidance, including potential MDCG publications.

Certification

CE Marking of Medical Devices in accordance with MDR

Medical Devices are an heterogeneous category of products, such as active equipment, orthopaedic implants, reusable instruments, substances and materials, software, and more. These devices, designed for medical purposes and intended for use in or on humans, achieve their primary effects through mechanisms other than pharmacological, immunological, or metabolic actions. Before entering the European Economic Area (EEA) market, the medical devices need to be compliant to applicable legislation and obtain the CE marking.

Certification

ISO 13485 Medical Devices

ISO 13485 is the medical device industry's quality management system (QMS) standard. The scheme specifies the requirements for a quality management system for medical devices.

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