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    MDR Article 117

    EU MDR provision adding device-component requirements to the EU pharma marketing authorization process.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed September 19, 2026

    Definition

    Article 117 amends Directive 2001/83/EC so that a medicinal product containing an integral device component (e.g., prefilled pen, drug-eluting stent) requires a Notified Body opinion on the device portion's conformity with relevant MDR General Safety and Performance Requirements before marketing authorization. The certificate or notified body opinion (NBOp) goes into the marketing authorization application for products such as prefilled syringes and inhalers. The medicinal product authority still decides on the product as a whole.
    What the regulation says
    MDR Article 117 modifies Directive 2001/83/EC, necessitating that notified bodies issue an opinion on the conformity of the device component of drug-device combination products with the EU MDR General Safety and Performance Requirements (Annex I), prior to the granting of a marketing authorization for the medicinal product. This ensures that the device aspect of these integral products meets EU MDR standards.

    What this means in practice

    Forces drug-device combination products into earlier and tighter coordination between pharma and device regulatory teams in Europe.

    Examples

    • A pharmaceutical company developing a new insulin pre-filled pen must obtain a Notified Body opinion on the pen's compliance with EU MDR GSPRs as part of its medicinal product marketing authorization application.
    • A drug-eluting stent, classified as a drug-device combination product, requires evaluation by a Notified Body regarding the stent's adherence to EU MDR Annex I before the drug can receive marketing authorization.
    • When a novel auto-injector is developed for a life-saving drug, the device component's conformity with EU MDR must be verified by a Notified Body under Article 117.
    Common pitfalls
    • •A common pitfall is underestimating the time and resources required for Notified Body involvement in the marketing authorization process for drug-device combinations.
    • •Another mistake is failing to integrate device regulatory experts early in the development lifecycle of a combination product.
    • •Companies often err by not adequately preparing technical documentation for the device component to meet EU MDR Annex II and III prior to seeking a Notified Body opinion.

    Frequently asked questions

    The primary impact is the mandatory assessment by a Notified Body of the device part of an integral drug-device combination product, ensuring its compliance with EU MDR General Safety and Performance Requirements before marketing authorization for the medicinal product.
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    Sources

    3 sources

    Sources support the definition or relevant regulatory context, not necessarily every claim on this page. 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: 3 verified· last checked 2026-06-20
    EUR-Lex·1IMDRF·1RAPS·1
    1. 1
      EU MDR Article 117
      Tier 1 Verified
      EUR-Lexeur-lex.europa.eu
    2. 2
      IMDRF Documents
      Tier 2 Verified
      IMDRFimdrf.org
    3. 3
      RAPS Regulatory Focus
      Tier 4 Verified
      RAPSraps.org

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