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MDR equivalence: document characteristics and data access

An equivalence strategy depends on demonstrable comparability and adequate evidence access, not a competitor catalogue.

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An equivalence strategy depends on demonstrable comparability and adequate evidence access, not a competitor catalogue.

MDR equivalence — Define the regulatory scope

MDR Annex XIV and MDCG 2020-5 address technical, biological and clinical equivalence. Applicable Article 61 conditions must also be checked for the specific device.

MDR equivalence — Build the working record

Create a characteristic-by-characteristic table with source documents, differences, clinical significance and access limitations. Distinguish equivalent devices from merely similar devices used to describe the state of the art.

MDR equivalence — Check before release

  • Compare materials and tissue contact.
  • Check intended purpose and user population.
  • Confirm access can support the actual equivalence claim.

MDR equivalence — Record the decision and handover

Approve equivalence only when the evidence chain is sufficient and differences are justified. Escalate unavailable data as a genuine gap and evaluate an alternative clinical evidence strategy rather than filling the table with assumptions.

Frequently asked questions

Does the same indication prove equivalence?
No. Technical, biological and clinical characteristics must be assessed together.
Is a contract always the only access test?
No. Check the device-specific legal conditions and the sufficiency of access; do not generalise one scenario.

Sources

  1. Primary requirement: MDR Annex XIV: equivalence
  2. Operational guidance: MDCG 2020-5: equivalence