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    Notified Body Scrutiny (IVDR Class D)

    Additional expert-panel review of a notified body's assessment for certain novel or high-risk Class D devices before certification.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed July 25, 2026

    Definition

    Article 48(6) requires the notified body assessing a Class D device to notify a designated expert panel of its Performance Evaluation Assessment Report (PEAR) where no CS exist for the device, the device is the first of its kind, or the CS have been recently revised. The expert panel may deliver a scientific view within 60 days that the notified body must duly consider.
    What the regulation says
    Article 48(6) and Article 106 detail the composition and functioning of the expert panels and the procedure by which their scientific views feed back into the notified body's decision.

    What this means in practice

    Scrutiny is a checkpoint intended to raise consistency across notified bodies for the highest-risk IVDs (HIV, HCV, blood grouping, novel pathogen assays). It borrows the mechanism of MDR Article 54 CECP scrutiny for implantable Class III devices.

    Examples

    • A diagnostic assay for a newly identified zoonotic pathogen, for which no harmonized standards or common specifications yet exist, would undergo notified body scrutiny.
    • A device for screening blood donations for a highly variable virus, where the common specifications for detection methods have been updated to include advanced molecular techniques, would be subject to scrutiny.
    • The first-ever IVD to use a novel biomarker for early detection of a severe chronic disease, even if common specifications for similar diseases exist, would typically face expert panel scrutiny due to its novelty.
    Common pitfalls
    • •A common misconception is that scrutiny implies the notified body's assessment is incomplete or incorrect, when in fact it is a standard procedural step for certain high-risk devices.
    • •Manufacturers often assume that if their device is not 'novel' or 'first of its kind,' it will bypass scrutiny, but if no common specifications exist or they were recently revised, scrutiny may still apply.
    • •Some believe that expert panel scrutiny is a final decision-making body, but its role is to provide a scientific view for the notified body to consider, not to approve or reject certification directly.

    Frequently asked questions

    Article 48(6) requires notification to a designated expert panel when no Common Specifications exist for the device, when the device is the first of its kind for that intended purpose, or when the applicable Common Specifications have recently been revised. Not every Class D certification triggers this step; it targets novelty and regulatory-gap scenarios specifically.
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    Sources

    3 sources

    Every citation below opens the original document. Each is graded against our source-tier hierarchy so you can see what rests on binding law versus commentary.

    Tier 1Binding law and standards· 1Tier 2Regulator guidance and consensus· 1Tier 4Trade press and expert commentary· 1
    Link health: 2 verified 1 unchecked· last checked 2026-06-20
    EUR-Lex·1MDCG·1RAPS·1
    1. 1
      Regulation (EU) 2017/746, Article 48(6) and Article 106
      Tier 1 Verified
      EUR-Lexeur-lex.europa.eu
    2. 2
      MDCG 2019-3 Interpretation of Article 54(2)(b) MDR (analogous)
      Tier 2 Unchecked
      MDCGhealth.ec.europa.eu
    3. 3
      RAPS Regulatory Focus
      Tier 4 Verified
      RAPSraps.org

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