May 17, 2020

4 ways to transform the European medical device supply chain

MedTech
Admin
3 min
Outsourcing the logistics activities and operations to a 3PL with expertise in managing medical device supply chains frees up the manufacturer to focus on its core business.
As recently reported by our sister publication Supply Chain Digital, the European medical device industry is weathering a perfect storm, which is shifti...

As recently reported by our sister publication Supply Chain Digital, the European medical device industry is weathering a perfect storm, which is shifting the business paradigm.

The world’s leading logistics company, DHL, is therefore examining how changes in the European health care market are impacting supply chain models.

In a new white paper commissioned by the company, DHL explains what modifications medical device supply chains must undergo in order to survive in today’s environment and ensure first-class service for patient care.

RELATED TOPIC: Where is the future of the health care supply chain headed?

“Illness patterns in the emerging Eastern European markets are starting to match those in the mature Western European countries, but product preferences, payer mechanisms, regulations and distribution channels continue to differ widely by country. These practices vary country-by-country, making Europe a very complex market to serve,” said Susanne Amholt, DHL Supply Chain’s Vice President for Business Development, Life Sciences and Healthcare, Europe.

Outlined in the white paper are four important strategies that medical device and life science companies can implement to address these changes:

1. Segmenting supply chains by product value.

Segmentation includes tailoring the mode of transportation and warehousing and the distribution channels in each country, according to the type and category of medical device. Low-value, high-volume consumer medical devices may be transported by ocean, long-haul road freight and faster, higher cost modes for 'emergency' situations. From a network perspective, these same products may be distributed via regional distribution centers or cross-dock facilities located in closer proximity to the end market.

RELATED TOPIC: Top trends in enterprise labeling: Part 1

2. Creating a direct to customer channel.

To reduce costs and increase profits, manufacturers are beginning to look at serving certain customers direct. This approach provides an alternative to the traditional distributor-intermediary model and connects businesses more directly with patients. However, the decision of going direct versus through a distributer is highly reliant on several factors, including attributes such as cost of product, security needs and number of final distribution points.

3. Leveraging shared-use distribution centers.

Under a shared services solution, multiple manufacturers house their product with a single third party logistics service provider (3PL) in a shared network of facilities and transportation capacity, which streamlines the supply chain for manufacturers and their customers.

RELATED TOPIC: Top trends in enterprise labeling: Part 2

4. Outsourcing logistics to a third party.

Outsourcing the logistics activities and operations to a 3PL with expertise in managing medical device supply chains frees up the manufacturer to focus on its core business—developing and producing medical devices. It enhances flexibility by tapping into the capabilities portfolio, infrastructure and expertise of a global 3PL—rather than trying to build and maintain those assets and processes in-house.

“The time has come to re-think the European medical device operating model in general and the supply chain in particular. Leading manufacturers are doing just that. They are working with their logistics service providers to reengineer their supply chains to embrace outsourcing solutions, shared services and other supply chain solutions,” said Lisa Harrington, President of the lharrington group LLC, who prepared the white paper.

RELATED TOPIC: How NHS SBS is transforming health care procurement

With more than 325,000 employees in over 220 countries and territories worldwide, DHL’s portfolio of logistics services ranges from national and international parcel delivery, international express, road, air and ocean transport to industrial supply chain management. 

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Jun 20, 2021

Medical device companies: how to prepare for Brexit

medicaldevices
supplychain
Brexit
Compliance
Ed Ball
6 min
Ed Ball, Senior Associate at RQM+ , explains how medical device companies can prepare for post-Brexit compliance

Over the last decade, medical device businesses have been no strangers to regulatory changes and new compliance requirements. Companies with devices in the EU market have been working hard to achieve conformity with the requirements of the EU Medical Device Regulation 2017/745 (MDR) and In Vitro Diagnostic Regulation 2017/746 (IVDR), but the UK’s exit from the EU, effective as of 1st January 2021, demands yet another change: to comply with the new UK regulatory regime.

The Medicines and Medical Devices Act passed into law on 11 February 2021 does just that; it enables the UK to build its own regulatory system, although when this new framework will be fully in place is not yet known.

The transition to the UK’s new regulatory regime officially began on the 1st of January 2021, and with it a series of deadlines and phases that medical device manufacturers exporting to GB and Northern Ireland would do well to take close notice of. During the transition period, the UK Medical Devices Regulations (UK MDR) 2002, not to be confused with the EU MDR, will continue to apply in England, Scotland and Wales, whilst CE marked medical devices will still be accepted up to 30th June 2023.

The conformity assessment processes defined in the UK MDR 2002 (as amended) will require that medical devices carry the UKCA mark for entry in the GB market or the UKNI mark for entry in Northern Ireland (where the devices are not CE marked for the EU). In Northern Ireland, where the rules for placing a device on the market differ, the EU MDR and IVDR will apply in 2021 and 2022 respectively, in line with the EU’s implementation timeline. 

This easing-in period of transition is valuable time that should be used productively by manufacturers to ensure that they get up to speed, keep up with relevant updates and prepare strategies and product portfolio for the next phase. To do this, businesses should make sure they consider the following areas as they assess their strategy for UK market access:

Potential Overlap with EU MDR and IVDR
Medical device manufacturers have been working to implement measures to ensure they comply with EU MDR and IVDR for quite some time. The experience, processes and objective evidence that they have gathered in these efforts are certain to be of use when applying for UKCA marking. 

Rigorous Planning
Product portfolios and new product pipelines should be evaluated against both overall compliance risk and commercial and strategic value. By identifying the regulatory compliance status for each product for the UK market and the efforts required to maintain that compliance, manufacturers can plan to use the grace period up to June 2023 to complete their activities. These plans should also be evaluated in consideration of the commercial importance of the individual products to help prioritise the workload. This may well result in the decision to discontinue certain products in the UK or to introduce new products on the UK market ahead of other markets.

Engage with Approved Bodies
This activity cannot take place too soon; as of the 1st of January 2021, UK organisations that were acting as EU Notified Bodies have become Approved Bodies in the UK, while EU Notified Bodies are no longer able to provide conformity assessments under the UK regulations. As there are currently only three UK Approved Bodies offering this service, there is a very real risk that latecomers will struggle to find a UK Approved Body to carry out the conformity assessment required to attain their UKCA mark in time.

Authorised Representatives
Just as EU Notified Bodies are no longer relevant to pursuing UK certifications, UK-based Authorised Representatives are no longer valid when CE marking against the MDR or IVDR. Manufacturers using UK-based EU Authorised Representatives must switch to an EU-based Authorised Representative.

For the UK market, the role of the EU Authorised Representative is also no longer applicable. Non-UK manufacturers must have a UK-based Responsible Person (UKRP), which is equivalent to the EU Authorised Representative in terms of roles and responsibilities. Only one UKRP may be appointed, unlike EU Authorised Representatives, and they must have a registered place of business in the UK in order to register with the MHRA. Approved Bodies may be able to provide details of organisations acting as UKRPs and once this role has been assigned it will be critical for manufacturers to determine exact procedures for managing documentation and that clear communication channels are established. 

Labelling and Import/Export
New UK regulations require that medical devices bear a UKCA mark in addition to the name and address of the UKRP for non-UK based manufacturers. Manufacturers who use the same products/packs for the EU and UK markets will need to consider the impact of adding more content to their labels in terms of usability for the supply chain and end-users. 

While CE marking and certificates will continue to be recognised by the UK until June 2023, import/export administration is likely to change and become more burdensome. Manufacturers using separate products for GB (UKCA) and the EU and Northern Ireland (CE marked) will need to plan for how to ensure that the CE marked product is not shipped to GB post June 2023. Ensuring that processes and resources are in place to deal with developing situations will help manufacturers hit the ground running.

Clinical Investigations
Many businesses will find that clinical investigations are carried out across multiple sites, some of which are outside the UK. In these instances, manufacturers will do well to have a plan for implementation and management of investigations, in compliance with local requirements. It is likely that the MHRA will also continue to update their requirements for clinical trials in the UK.

Data Protection and Standards
New tensions are emerging between the EU and the UK concerning UK data protection rules and the EU’s General Data Protection Regulation (GDPR), suggesting that maintaining ‘equivalency’ may involve a number of different phases.

Compliance with applicable standards also requires close attention; the list of designated standards for medical devices issued by the UK’s Department for Health and Social Care is based on the list of harmonised standards published in the Official Journal of the EU, which in turn are harmonised to the MDD, AIMDD and IVDD. More recently published standards, however, have not been harmonised to the latter European directives and are thus not in the UK’s designated list, despite being considered state of the art. It would be prudent for manufacturers to monitor the state-of-the-art standards and apply where applicable, rather than rely on superseded and outdated standards.

As the UK moves into a new regulatory regime, medical device manufacturers who have already invested time and resources to comply with EU MDR and IVDR can use this to attain their UKCA mark. However, a dynamic compliance environment combined with the new onus relating to export policies means that close attention needs to be paid on numerous fronts. Keeping pace with this changing environment will ensure that manufacturers face the future with confidence and do not lose important space on their markets.

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