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MDRC – Medical Devices Regulatory Compliance

MDR Article 15 · IVDR Article 15 · MDCG 2019-7 Rev.1

Person responsible for regulatory compliance in the EU

A PRRC is not a ceremonial name on an organisation chart. The role provides defined regulatory oversight across device release, technical documentation, post-market surveillance, vigilance and investigational devices or performance studies.

Article 15 applies to manufacturers placing devices on the Union market and to authorised representatives of non-EU manufacturers. The appointment model depends on the legal entity, enterprise size and the role being performed.

Legal basisArticle 15 Applies underMDR and IVDR AvailabilityPermanent and continuous

Regulatory control without transferring the manufacturer’s responsibility

The PRRC has a key role in verifying that relevant regulatory processes work. The manufacturer must involve the PRRC in the processes needed for the role and provide access to necessary information, including identified nonconformities.

The manufacturer nevertheless remains responsible for demonstrating device conformity. Appointing a PRRC does not transfer legal manufacturer obligations, replace management accountability or turn one individual into the entire regulatory and quality function.

01

Verify

Check that defined processes and evidence are applied before release.

02

Connect

Link technical documentation, PMS, vigilance and change control.

03

Escalate

Raise regulatory gaps and inability to fulfil Article 15 duties.

04

Document

Leave a traceable record of oversight, decisions and follow-up.

First identify the legal entity and its role

“Manufacturer”, “authorised representative” and “group company” are not interchangeable. Article 15 applies at legal-entity level, and every legal manufacturer must be covered by its own compliant appointment.

Model 01

Manufacturer that is not micro or small

At least one qualified PRRC must be available within the organisation. MDCG 2019-7 Rev.1 interprets this as an employee of the legal manufacturer.

Relationship
Within the organisation
Typical evidence
Employment, role description and authority

Model 02

Micro or small manufacturer

The PRRC does not have to be within the organisation. An external person may be used when the manufacturer documents permanent and continuous availability and the practical means to perform the duties.

Relationship
Internal or contracted external PRRC
Typical evidence
Contract, availability and operating procedure

Model 03

Authorised representative

The authorised representative must have a qualified PRRC permanently and continuously at its disposal. The role may be subcontracted if the arrangement and availability are adequately documented.

Relationship
Internal or contracted external PRRC
Focus
Fulfilment of the authorised representative’s mandate

Keep the PRRC close enough to exercise real oversight

The location expectations below come from MDCG guidance and support the required permanent and continuous link. They are not a substitute for assessing the actual organisation, manufacturing activities and mandate.

EU manufacturer

PRRC in the Union market

MDCG guidance assumes that the PRRC of an EU manufacturer should also be located in the Union market.

Non-EU manufacturer

PRRC near manufacturing activities

The guidance assumes a location outside the Union and recommends physical and geographical proximity to manufacturing.

EU authorised representative

PRRC in the Union market

The authorised representative’s PRRC is expected to be located in the Union market so the mandate can be overseen effectively.

Independent second level of scrutiny

The PRRC of a non-EU manufacturer and the PRRC of its authorised representative cannot be the same individual. For a micro or small manufacturer, the two PRRCs must not belong to the same external organisation.

Two qualification routes, supported by evidence

The manufacturer or authorised representative must retain evidence showing that the named person is qualified and capable of performing the assigned role.

Route A

Recognised formal qualification

A university degree or equivalent course of study in law, medicine, pharmacy, engineering or another relevant scientific discipline

At least one year of professional experience in regulatory affairs or quality management systems relating to devices

Route B

Professional experience

At least four years of professional experience in regulatory affairs or quality management systems relating to medical devices or IVDs

01

Relevant, substantive and recent

Experience should relate to EU requirements and enable the person to perform the duties effectively. Administrative document handling or shadowing alone is insufficient.

02

Non-EU qualifications

A qualification obtained outside the EU should be recognised as equivalent by one EU Member State. Keep the recognition evidence with the appointment record.

03

MDR custom-made-device route

Subject to national provisions, a manufacturer of custom-made devices may demonstrate expertise through at least two years of relevant manufacturing experience.

Article 15 duties must be built into working procedures

The Regulation states minimum areas of responsibility. The operating model must translate them into access rights, review points, records, escalation routes and named process owners.

01

Before release

Conformity checks under the QMS

Ensure that device conformity is appropriately checked under the quality management system before release. This may use audits or risk-based sampling, but the check must address substance, not merely document presence.

02

Controlled evidence

Technical documentation and declaration

Ensure that the technical documentation and EU declaration of conformity are drawn up and kept current, including when product or process changes affect the evidence.

03

Lifecycle feedback

Post-market surveillance

Ensure compliance with PMS obligations and verify that the system collects and evaluates information needed to maintain device safety and performance.

04

Regulatory reporting

Vigilance obligations

Ensure that applicable reporting obligations are fulfilled, including serious incidents, field safety corrective actions and trend reporting.

05

Clinical or performance studies

Required study statement

For investigational devices and relevant IVD performance studies, ensure issuance of the statement required by MDR Annex XV or IVDR Annex XIV.

Permanent availability is a system, not a phrase in a contract

MDCG guidance does not interpret “permanently and continuously” as automatic 24-hour daily availability. It does require an arrangement that lets the PRRC perform operational duties and react in a timely manner.

  1. 01

    Define scope

    Identify the legal entity, product portfolio, MDR or IVDR scope and the exact Article 15 responsibilities assigned.

  2. 02

    Provide access

    Give the PRRC controlled access to the QMS, technical documentation, change records, PMS data and vigilance information.

  3. 03

    Set review points

    Place PRRC review at meaningful control points such as release, significant change, PMS review and reportability assessment.

  4. 04

    Define escalation

    Document response times, deputies, urgent communication routes and what happens when recommendations are not accepted.

  5. 05

    Retain evidence

    Keep review records, findings, management responses, follow-up and current qualification evidence available for inspection.

Manufacturer PRRC and authorised representative PRRC are not the same role

A non-EU manufacturer and its EU authorised representative each need their own regulatory control. Combining them would remove the intended second level of scrutiny.

Control pointManufacturer’s PRRCAuthorised representative’s PRRC
Primary basisArticle 15(1)–(5)Article 15(6) and the AR mandate
Core focusManufacturer processes, device release and lifecycle complianceFulfilment of the authorised representative’s tasks under Article 11(3)
Location expectationClose link with manufacturing activitiesLocated in the Union market
Can be the same personNo, for a non-EU manufacturer and its authorised representative
Can share one external organisationNo, where the manufacturer is micro or small and uses an external PRRC
No disadvantage for proper performance

The PRRC must not suffer disadvantage within the manufacturer’s organisation for properly fulfilling the role, whether or not the person is an employee. Independence requires authority to raise issues and a documented management response.

Record the PRRC details and keep them current

The PRRC is not registered as a separate economic operator. Instead, the manufacturer or authorised representative records the PRRC’s name, address and contact details within its own actor information.

Mandatory module use 28 May 2026

The Actor Registration module is among the first four EUDAMED modules whose use became mandatory.

Change control

Update changed PRRC information, including a replacement or terminated contract, within one week.

What a defensible PRRC arrangement should contain

A name and CV are only the starting point. The appointment should show how the person can actually exercise oversight across the relevant device lifecycle.

Legal-entity scope

Every manufacturer and authorised representative covered by the appointment is identified.

Qualification file

Diplomas, recognition evidence, CV and substantive recent experience support the selected route.

Written responsibilities

Article 15 duties and any division between multiple PRRCs are stipulated in writing.

Information access

The PRRC can obtain controlled documentation, PMS data, complaints, changes and nonconformities.

Availability and continuity

Response expectations, leave coverage, deputy arrangements and urgent escalation are workable.

Review records

Checks, findings, decisions, management responses and closure evidence are retained.

Protection from disadvantage

The governance model permits independent escalation without retaliation for proper performance.

EUDAMED maintenance

PRRC contact details are current and a process exists to update changes within one week.

Questions about the PRRC role

Does every manufacturer need a PRRC?

Manufacturers placing devices on the Union market must have at least one qualified PRRC. Micro and small manufacturers may use an external person, but must have that person permanently and continuously at their disposal.

Can a larger manufacturer appoint an external consultant as its only PRRC?

Not under the MDCG interpretation of “within their organisation”. A manufacturer that is not micro or small is expected to appoint an employee of the legal manufacturer. External support may supplement, but not replace, that internal appointment.

Must an external PRRC be available 24 hours every day?

No. The arrangement must allow the PRRC to perform operational duties and react in a timely manner. The contract should define realistic availability, urgent escalation and continuity.

Can several people share PRRC responsibilities?

Yes. Their respective areas of responsibility must be stipulated in writing and, together, cover the required Article 15 responsibilities.

Can one group PRRC cover several legal manufacturers?

Each legal manufacturer must have its own PRRC arrangement. The same qualified person may potentially support more than one entity only where each appointment independently meets the legal, availability, location and capacity requirements.

What changes must be made in EUDAMED when the PRRC changes?

The actor information should be updated with the new PRRC name, address and contact details within one week. Internal appointment and access records should be updated at the same time.

Make the PRRC role operational, not nominal

MDRC can review your appointment model, verify qualifications, define the oversight procedure and provide external PRRC support for eligible organisations.