The Medical Device Coordination Group (MDCG) has issued a draft Q&A document clarifying the obligations for Manufacturer Trend Reporting (MTR) under Article 88 of the medical devices regulation (MDR) and Article 83 of the in vitro diagnostic medical devices regulation (IVDR). Its aim is to harmonise vigilance practices across the EU and ensure that manufacturers, notified bodies, and competent authorities apply consistent criteria when identifying and reporting significant increases in device-related incidents.
Scope of reporting
The guidance explains when a report is required, highlighting that both increases in frequency and severity of incidents may trigger reporting. It also clarifies that the requirement can apply to individual devices, product groups, and, in some cases, global datasets. To ensure consistency, the document sets out expectations for defining “statistical significance,” providing examples of suitable methodologies, and stressing the need to justify baselines and observation periods.
Manufacturer responsibilities
Manufacturers are reminded that trend reporting is not a standalone exercise but part of the post-market surveillance system. An MTR submission should include the designated form together with a supporting Trend Report document. Actions may follow from identified trends, including deeper investigations, updates to the benefit–risk profile, post-market surveillance adjustments, and where necessary, corrective actions or field safety measures.
EUDAMED & practical guidance
The Q&A also offers practical guidance on how to handle submissions in EUDAMED, including the fields to complete and requirements for follow-up reports. By providing illustrative examples and addressing common scenarios—such as new event types or expanded device scope—the document makes the obligations more operational.
We would like to note that the document is still in its draft form and when published, it will be non-binding. Nonetheless, the Q&A provides an important outlook regarding expectations of authorities towards manufacturers.
Source: European Commission