Medicinal products that are combined with a medical device in a secondary packaging must take into account the specifications according to MDR/IVDR. These so-called co-packaged products (e.g. reusable pens for insulin cartridges) must be labelled specifically. This should distinguish them from combination products offered in a fixed combination with a medicinal product (integral products, e.g. a single-use dose inhaler), which are considered medicinal products according to the MDR.
For all combination products, the safety and performance requirements of the MDR must be met. If the products were authorised before 26 May 2021, no variation needs to be submitted to demonstrate compliance. If adjustments still need to be made to meet the requirements, a transition period until 26 May 2024 applies.
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