About the Transition to ISO/IEC 22003:2022 Standard!

Standard of Requirements for Organizations Providing Certification of Food Safety Management Systems ISO 22003-1:2022, was published in June 2022. 

Certification bodies that provide ISO 22000 Food Safety Management System certification are required to complete their transition to ISO/IEC 22003:2022 by 31 December 2024.

In this context, all our customers certified by our organization on ISO 22000 Food Safety Management System must complete the audit activities until 30.06.2025, we bring to the attention of the relevant parties.

You can contact our System Certıfıcatıon department for detailed information about the changes.

What is the Gas Appliances Regulation (2016/426/EU)?

2016/426/EU Gas Appliances Regulation (GAR) was created by the European Union (EU) to determine the standards regarding the safety and placing on the market of gas appliances. This regulation imposes certain requirements to ensure that gas appliances and their associated equipment are produced and used in a safety, health and environmentally friendly manner. GAR aims to protect the safety of consumers and the environment by regulating the design, production, performance and conformity assessment processes of gas appliances.

Importance of Gas Appliance Tests

The safety of gas appliances is of paramount importance to both users and the environment. Testing these appliances is a critical step to ensure that they operate safely and efficiently. Testing processes evaluate the performance of appliances under various operating conditions and identify potential hazards in advance. Criteria such as gas leaks, combustion efficiency, emission levels and mechanical durability are the main focal points of these tests.

Testing gas appliances not only ensures the safety of users, but also minimises environmental impact by improving energy efficiency. These tests verify that the appliances comply with regulatory standards and regulations. Thus, it offers the highest quality in terms of safety and performance.

CE Certification and Advantages in the Market

CE certification indicates that a product complies with the health, safety and environmental protection requirements of the European Union. Obtaining CE certification for gas appliances means certifying that the product complies with GAR and other relevant directives. This certificate proves that the product complies with European standards in terms of quality and safety.

Products with CE certification have significant advantages in the market:

Compliance with Eco-Design Directives and Standards

Eco-Design directives and standards cover a set of requirements set by the European Union to improve the environmental performance of products. These directives and standards aim to minimise energy efficiency, resource use and environmental impact. Gas appliances are also covered by the Eco-Design directives and compliance with the standards improves the sustainability and energy efficiency of appliances.

Products compliant with Eco-Design directives and standards provide cost savings to consumers and minimise environmental impacts by reducing energy consumption. These standards make a significant contribution to a sustainable future by improving the environmental performance of appliances throughout their lifecycle.

Laboratory and Accreditation

Our laboratory is accredited by TÜRKAK within the scope of EN ISO/IEC 17025 to ensure high standards in the testing and evaluation processes of gas appliances. This accreditation guarantees the technical competence of our laboratory and the reliability of test results. EN ISO/IEC 17025 accreditation is an indicator that the laboratory operates in accordance with internationally recognised standards and provides high quality service.

Main Product Groups We Serve

Our laboratory provides testing and evaluation services for various gas appliances and equipment. The main product groups we serve are as follows:

• Household Cooking Appliances: Ovens, hobs and other household cooking appliances.
• Commercial Cooking Appliances: Industrial cooking equipment for large-scale kitchens and restaurants.
• Commercial Cooling Systems: Large-scale cooling systems designed for industrial use.
• Regulators : Fittings that regulate gas pressure and ensure safety.

The safety and performance of gas appliances are critical for both users and the environment. CE certification and compliance with Eco-Design standards ensure the safe and efficient use of these appliances, while the accredited services of our laboratory guarantee testing and evaluation processes of the highest standards. In this way, we contribute to the competitive positioning of gas appliances on the market.

 

Gas Appliances Department Manager

Burak Çalışkan

THE IMPORTANCE OF ACCREDITATION IN MACHINE CONFORMITY ASSESSMENT ACTIVITIES

Nowadays, conformity assessment activities in machines have changed. This is mainly due to developing technology and increasingly important standards. As Szutest Machinery Department, we call this process new generation machine conformity assessment activities.

Based on this context, an institution that carries out machine conformity assessment activities must first be accredited by the European Commission and then by our accreditation body, the Turkish Accreditation Agency, which is affiliated with our relevant ministry. Therefore, the notified body carries out and reports the necessary examinations and tests regarding the standards under the regulation for which it is accredited. Based on this logic, services such as PL verification and ESPE measurements performed within the scope of EN 13849-1 and EN 13855 standards, which have become increasingly important on machines recently, should also be performed by organizations accredited in the relevant regulation.

The importance of accreditation in machinery conformity assessment activities should be considered from several aspects.

Reliability and Trust: An accredited organization has a structure that independently verifies compliance with a certain standard or guideline and gives credibility to this verification. Therefore, assessment results by an accredited organization are generally considered more reliable.

Legal and Regulatory Compliance: In some countries, testing and certification by accredited organizations are required to evaluate certain products or processes. Accreditation is important to comply with such legal and regulatory requirements.

International Acceptance and Recognition: Accredited organizations generally operate in accordance with international standards and thus have the advantage of being recognized and accepted internationally. This may facilitate the entry of products or processes into international markets.

Quality and Process Management: The accreditation process can help organizations improve their processes and quality management systems. Accreditation criteria can provide organizations with a framework for continuous improvement and strengthening quality assurance systems.

Consumer and Corporate Trust: Certifications or reports issued by an accredited organization can create a reliable reference for consumers and other business partners. This can provide an advantage in market competition and increase customer satisfaction.

Potential harms of non-accredited organizations performing conformity assessment on machines may include:

Reliability Issues: There may be doubts about the reliability of evaluations made by non-accredited organizations. These organizations may not be able to fully implement quality control procedures required by certain standards or guidelines.

Legal Issues: In some countries, testing and certification by accredited organizations are legally required to evaluate certain products or machines. Certificates issued by a non-accredited organization may not be valid for legal compliance and this may lead to legal problems.

Deficiencies in Quality Standards: Non-accredited organizations may be inadequate to ensure compliance with national or international quality standards. This may result in products or machines not meeting expected standards in terms of safety, performance and quality.

Cost Increase and Inefficiency: Documents obtained as a result of the certification or evaluation processes of non-accredited organizations may not be accepted in international markets. This can make commercial acceptance of products or machines difficult and therefore lead to increased costs or operating inefficiencies.

Loss of Customer Trust: Certificates or evaluation reports issued by a non-accredited organization may cause loss of trust in customers. Customers may have concerns about the conformity of products or machines to certain standards, which may negatively affect sales.

When a notified body carries out conformity assessment activities on machines, it does not care which brand or model of components the manufacturer or designer uses. What he is interested in is whether that component has undergone a conformity assessment activity or not. An accredited notified body does not pursue any purpose other than conformity assessment activity.

As a result, accreditation in machine conformity assessment activities brings many important advantages such as reliability, legal compliance, international acceptance, quality management and consumer confidence. Therefore, it is important to consider these factors when researching and evaluating an organization’s accreditation. Conformity assessment of machines by non-accredited organizations may cause problems in important areas such as reliability, legal compliance, quality standards and customer confidence. For this reason, choosing accredited organizations in conformity assessment processes will generally be a healthier and more reliable approach.

 

İbrahim Aydeniz

SZUTEST Machinery Department Manager

Low Voltage Directive (LVD) and the Importance of Electrical Safety Tests

The safety of electrical appliances is of great importance for both manufacturers and consumers. The European Union’s Low Voltage Directive (2014/35/EU) is a regulation established to ensure this safety. This regulation sets safety standards for equipment operating at AC voltages between 50V and 1000V and DC voltages between 75V and 1500V. The aim is to minimise electric shock and other potential hazards.

Importance of Electrical Safety Tests

Electrical safety tests are carried out to check whether the appliances comply with certain safety standards. These tests are critical to ensure the safe use of devices and prevent possible accidents. In particular, tests such as electrical insulation, earthing, insulation, overcurrent protection, protection against high voltage are carried out to ensure the safety of the devices.

Advantages of CE Certificate

CE certification indicates that a product complies with European Union directives and can be used safely. Products with CE marking can circulate freely and be placed on the market in the European Economic Area. This gives manufacturers a wide market access. For consumers, the CE marking guarantees that the product is safe, high quality and environmentally friendly.

Accreditation of Our Laboratory and Our Services

Our company offers electrical safety tests as an accredited laboratory under the EN ISO/IEC 17025 standard. This accreditation provides international recognition of the technical competence of our laboratory and the reliability of test results. The accreditation process shows that our laboratory works to consistently high standards and attaches importance to customer satisfaction.

Product Groups We Serve

Our laboratory carries out electrical safety tests for a wide range of products. These product groups are as follows:

Household Cooking Appliances: Tests are carried out to ensure the safety of devices that we frequently use in our daily lives such as ovens, microwave ovens, hobs.

Industrial Cooking Appliances: Professional cooking appliances used in restaurants, hotels and other commercial kitchens must comply with high safety standards.

Household Refrigerators: Refrigerators used in homes for safe storage of food must be safe and energy efficient.

Industrial Cooling Devices: Commercial refrigeration systems are used in large-scale storage and food preservation processes. Safe and efficient operation of these devices is critical.

Household and Industrial Kitchen Equipment: A variety of kitchen equipment is tested for safe use in both domestic and industrial environments.

Electrical safety tests and CE certification ensure that products are both safe and competitive. Our company, with our accredited laboratory, provides high quality testing services to manufacturers, helping their products to take place safely in the European market. You can contact us to ensure that your products comply with safety standards and gain market advantage.

Gas Appliances  Department Manager

Burak Çalışkan

Dear sir / madam,

In support of the “London Declaration on Climate Change”, the International Organization for Standardization (ISO) has assessed the need to consider the impact of Climate Change on the ability of the management system to achieve its intended results and has decided to add two new textual statements to a number of existing management system standards and to include them in all new standards under development/revision.

In line with this decision, the specifications of various ISO standards

ISO 9001:2015/Amd 1:2024

ISO 14001/Amd 1:2024

ISO 45001 AMD 1:2024

ISO 22000 AMD 1:2024

ISO 50001 AMD 1:2024

ISO IEC 27001 Amd 1:2024

Published. ( https://www.iso.org/standard/88431.html )

Articles added with the new amendment;

4.1 The organization must determine whether there is an issue related to climate change or not.

4.2 NOTE: Interested parties may have requirements regarding climate change.

As above.

What Our Certified Organizations Should Do in This Scope;

*Climate Change should be determined whether it is related to other issues, and if so, it should be evaluated within the scope of risk assessment within the scope of management systems standards.

*Where more than one management system is operated (for example, Quality Management and Health and Safety Management), Climate Change is assessed within the scope of each management system standard if it is determined to be relevant.

*It is noted that some climate change considerations and risks may be generic in nature (e.g., when related to regulatory compliance or operational adaptability and organizational resilience), regardless of the applicable management system scope or sector, while others will be indexed specifically to the requirements of management system standards for specific industries and characteristics of the organization (e.g., power generation, agriculture and fisheries), and others will be indexed specifically to the requirements of management system standards (e.g., geographic location, nature of the supply chain or labor dynamics).

Impact of the Amendment on 3rd party audits and Certification Process;

In accordance with the final text published in the Management systems audits carried out by Szutest, issues affecting Climate Change related to the organization and its context will be questioned. Where it cannot demonstrate that all internal and external issues identified as relevant, including Climate Change, have been taken into account, an appropriate finding will be provided.

Management system standards will go through the ISO amendment process, but there is no need to issue a revised certificate if the following are taken into account:

–              The publication year of each Management System standard will not change.

–              There is no change in the scope of application for the certified Management System.

–              There is no significant impact on the effectiveness of the certified Management System.

–           The method and actions that certified organizations will eventually enter into, due to the new requirement, will resemble methods and actions they would apply in the case of future changes in any other contextual issue they already address within the scope of the Management System.

For your kind information,

System Certification Department Manager 

Belma TURKEL

ISO 9001 is supposed to be revised in 2025. The new version of ISO 9001 is expected to adapt to developments in digital technologies and the evolving risk environment. The new version of ISO 9001 is supposed to be emphasizing the importance of data-driven decision-making, risk management and continuous improvement.

Most probably, it will include requirements for cybersecurity, data privacy, and the use of emerging technologies such as artificial intelligence and machine learning.

By adopting and implementing the new version of ISO 9001, digitalization will be better equipped to navigate the challenges and opportunities of the digital age.

It is very important for auditors to be aware of the latest developments in artificial intelligence and machine learning and to get the necessary skills to use these technologies effectively.

By adopting these technologies, auditors can improve their skills and contribute to the organization’s digital transformation journey. Apparently, it seems that the new version will ensure that the processes and systems of businesses will take place at the forefront of technological innovation.

 

System Certification Department Manager

Belma Türkel

As SZUTEST (NoBo 2195), we have successfully completed our Notified Body authorization process within the scope of the (EU) 2016/425 Personal Protective Equipment Regulation(3), first by the Turkish Accreditation Agency and then by the Ministry of Labor and Social Security. As of April 27, 2021, our notified body authorization was published on NANDO, the official publication of the European Union Commission.

We would like to inform you that we can perform CE certification procedures with the widest product group authorization among the Notified Bodies in Türkiye within the scopes you can find the details below.

For our scope on NANDO: https://webgate.ec.europa.eu/single-market-compliance-space/#/notified-bodies/notifications/1003821?organizationVersion=11

For our scope on TÜRKAK: https://portal.turkak.org.tr/en/accreditation/accreditation-certificate/search/59efe31c-e568-456a-95d8-54d82b6a5a70

Product Group	Module/Annex of the Regulation
Equipment providing foot and leg protection Equipment providing foot, leg and anti-slip protection	Module B – EU Type-examination (Annex V)
Equipment providing foot and leg protection Equipment providing foot, leg and anti-slip protection Protective equipment against electric shock	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing foot and leg protection Equipment providing foot, leg and anti-slip protection Specialized areas of competence: Fireman suits	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing foot and leg protection Equipment providing foot, leg and anti-slip protection Protective equipment against chemical agents	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing head protection	Module B – EU Type-examination (Annex V)
Equipment providing head protection Equipment providing protection against heat [heat<100°C], [heat>100°C and fire)	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing head protection Protective equipment against electric shock	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing head protection Specialized areas of competence: Fireman suits	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing hand and arm protection	Module B – EU Type-examination (Annex V)
Equipment providing hand and arm protection Equipment providing protection against heat [heat<100°C], [heat>100°C and fire	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing hand and arm protection Protective equipment against mechanical risks	Module B – EU Type-examination (Annex V)
Equipment providing hand and arm protection Protective Equipment against harmful biological agents Protective Equipment against substances and mixtures which are hazardous to health Equipment providing hand and arm protection against chemical agents	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing hand and arm protection Equipment providing protection against cold [cold >-50°C ]	Module B – EU Type-examination (Annex V)
Equipment providing hand and arm protection Specialized areas of competence: Fireman suits	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing hand and arm protection Specialized areas of competence: Protective clothing for use in welding and allied processes	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing hand and arm protection Protective Equipment against hand-held chain-saws	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing hand and arm protection Protective Clothing Against Static Electricity	Module B – EU Type-examination (Annex V)
Equipment providing hand and arm protection Protective equipment against electric shock	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII) )
Equipment providing general body protection (clothing)	Module B – EU Type-examination (Annex V)
Equipment providing general body protection (clothing) Specialized areas of competence: Protective Clothing Against Static Electricity	Module B – EU Type-examination (Annex V)
Equipment providing general body protection (clothing) Specialized areas of competence: High Visibility Clothing	Module B – EU Type-examination (Annex V)
Equipment providing general body protection (clothing) Specialized areas of competence: Protective clothing for use in welding and allied processes	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Equipment providing protection against heat [heat<100°C], [heat>100°C and fire and flame]	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Protective equipment against electric shock	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Equipment providing protection against extreme cold [<-50°C] Equipment providing protection against cold [cold >-50°C ] [extreme cold <-50°C ]	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Protective Equipment against hand-held chain-saws	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Specialized areas of competence: Fireman suits	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Protective Equipment against substances and mixtures which are hazardous to health	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Protective Equipment Against Risks Arising From Sports Activities	Module B – EU Type-examination (Annex V)
Equipment providing general body protection (clothing) Protective equipment against chemical agents	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing general body protection (clothing) Protective Equipment against harmful biological agents	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing respiratory system protection	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Equipment providing eye and face protection	Module B – EU Type-examination (Annex V)
Equipment providing eye and face protection Specialized areas of competence: Protective clothing for use in welding and allied processes	Module B – EU Type-examination (Annex V)
Equipment providing eye and face protection Specialized areas of competence: Protective clothing for motorcycle riders	Module B – EU Type-examination (Annex V)
Equipment providing eye and face protection Protective Equipment Against Risks Arising From Sports Activitie	Module B – EU Type-examination (Annex V)
Protective Equipment against harmful noise	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Protective equipment against drowning	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)
Protective Equipment against falls from heights	Module B – EU Type-examination (Annex V) Module C2 – Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals (Annex VII) Module D – Conformity to Type Based on Quality Assurance of The Production Process (Annex VIII)

For the application form click here

 

For detailed information, you can contact us at info@szutest.com.tr or +90 216 469 4666.

Article 120(3) of the Medical Device Regulation (EU) 2017/745 (MDR), last amended by Regulation (EU) 2023/607, states that devices which continue to comply with the MDD may be placed on the market or put into service until 31 December 2027 or 31 December 2028, as applicable, provided the conditions set out in Article 120(3c) MDR are fulfilled.
As you know, these devices are called ‘legacy devices’ and in line with MDCG Guidance Document 2021-25, ‘legacy devices’ should be understood as devices, which, in accordance with the MDR’s transitional provisions, are placed on the market after the MDR’s date of application (i.e. 26 May 2021) if certain conditions are fulfilled.
Those devices can be:
– devices which are class I devices under Directive 93/42/EEC (MDD), for which an EC declaration of conformity was drawn up prior to 26 May 2021 and for which the conformity assessment procedure under the MDR requires the involvement of a notified body;
– devices covered by a valid EC certificate issued in accordance with the MDD prior to 26 May 2021.
The conditions are set out in Article 120(3c) MDR and include, among others, that legacy devices must continue to comply with the MDD, as applicable, and that there are no significant changes in the design or intended purpose of the device. Therefore, it is important for manufacturers and notified bodies to have a clear understanding as to what changes to design or intended purpose would be considered ‘significant’.
It is essential for legacy devices that their certificates remain valid following changes that are not significant with regard to design or intended purpose and that the required appropriate surveillance is carried out.

Scope
MDCG 2020-3 Rev1 is intended to provide clarification on the concept of ‘significant changes in the design and intended purpose’ under Article 120(3c), point (b) MDR. It concerns manufacturers of legacy devices.
This guidance document does not elaborate on the process for manufacturers’ submission and notified bodies’ assessment of changes to the approved design or substantial changes to the approved quality system or the product-range covered.

Changes to Directive Certificates
It is important to highlight that no issuing of new certificates is allowed under Article 120(3c), point (b) MDR. This does not mean that notified bodies are not allowed to e.g. suspend, re-insate, restrict or withdraw such certificates. Such activities should be communicated as written decisions/statements. Moreover, notified bodies should document corrections or additions to existing certificates resulting from changes that are not significant changes to design or intended purpose (e.g. administrative changes).
The implementation of such a change would prevent the manufacturer from placing the device on the market under the MDD in accordance with that provision. If the manufacturer wish to place such a changed device on the market, they may do so under the MDR.

Assessment whether changes are ‘significant changes in the design or intended purpose’ in accordance with Article 120(3c), point (b) MDR
In order to benefit from the transition periods provided by Article 120(3) MDR, legacy devices may not undergo any significant change in the design or intended purpose after the date of application of the MDR, i.e. 26 May 2021.
A significant change in the design or intended purpose consist of two cumulative elements:
• there is a change in the design or intended purpose, and
• the change is significant.
That means that changes that do not concern the design or intended purpose are out of scope of Article 120(3) MDR. Equally, changes that concern the design or intended purpose only fall under Article 120(3) MDR if they are considered ‘significant’. Changes in order to comply with other Union legislation are also out of scope even if they relate to changes in the design, only if the risk/benefit ratio of the device is not negatively affected.
The manufacturer is responsible for providing evidence and justification that a change does not affect the design or intended purpose, or, in case the change affects design or intended purpose of the device, that it is non-significant, which should be assessed case-by-case. The outcome of the assessment should be documented and made available to a competent authority when requested.

If a change is not a significant change in design or intended purpose,
– the implementation of such a change is allowed during the transitional period without the need for certification under the MDR. In such cases, the manufacturer is required to comply with the documentation requirements of the MDD. The updated technical documentation must allow assessment of the conformity of the product with the applicable requirements.

Additional considerations for devices covered by a certificate issued by SZUTEST
In line with the agreed arrangements for notification of changes between the manufacturer and the notified body according to the MDD (e.g. contractual relationships, approved procedures), changes and their implementation are to be verified by the notified body as part of the surveillance activities, or following a manufacturer’s submission for prior approval.
The outcome of this verification will determine whether a certificate in accordance with the MDD remains valid according to Article 120 MDR. In case of doubt as to whether a given change, which concerns the intended purpose or the design is significant, manufacturers should ask SZUTEST.
The certificate should not be amended. SZUTEST may confirm in FR.MED.57 Change Assessment Form and FR.MED.171 Certificate Info Ammendment Form after having reviewed the manufacturer’s description of the (proposed) change, that the implementation of the change does not represent a significant change in design or intended purpose under Article 120(3c), point (b) MDR and that the related MDD certificate remains valid until the end of the transition period.
Where the conformity assessment procedure under the MDD for a given legacy device requires the quality management system (QMS) of the manufacturer to be approved by SZUTEST, the manufacturer must observe that the conditions for which the certificate was granted are maintained. In any case, changes to the QMS continue to be subject to the agreed notification procedure between manufacturer and SZUTEST.

Changes not concerning the design or intended purpose
Changes concerning the manufacturer’s organisation (administrative changes) or changes concerning the manufacturing process should generally not be considered changes in the design or intended purpose within the meaning of Article 120(3c), point (b) MDR, even if they need to be reflected in the information to be supplied with the device (e.g. label or instructions for use). This includes for example:
• changes of the manufacturer’s name, address or legal form, including a merger or acquisition involving the manufacturer;
• changes in relation to the authorised representative relocation or addition of new manufacturing sites, including when it affects subcontractors or suppliers;
• changing the supplier of a material, substance or component, provided the specifications of the new material, substance or component do not change;
• adding or replacing a new material number for logistic reasons without changing the material;
• new process validation as part of manufacturing improvements or scale-up of manufacturing.
Changes of the QMS, such as changes in the monitoring and control of production and operations environment, generally do not impact the design or intended purpose either, provided that the conditions for which the conformity assessment certification was granted are maintained. In any case, changes continue to be subject to the agreed notification procedure between manufacturer and SZUTEST.

Changes in the design or intended purpose
Design and intended purpose
As legacy devices need to be in compliance with MDD, the benchmark for determining their design and intended purpose, as well as any possible change, should be the MDD respectively. While the MDD do not define the “design” of a device, the “intended purpose” means “the use for which the device is intended according to the data supplied by the manufacturer on the labelling, in the instructions for use and/or in promotional materials” (Article 1(2) letter (g) MDD).

Significance of changes
To facilitate a harmonised judgement of the significance of a change, MDCG 2020-3 Rev 1 provides several flowcharts. The assessment of a proposed change using the main flowchart and any of the applicable sub-charts is intended to assist manufacturers, notified bodies and market surveillance authorities in deciding whether or not a change of the design or intended purpose of the device is to be considered significant under Article 120(3c), point (b) MDR.
A change is considered a non-significant change of design or intended purpose per Article 120(3c) point (b) MDR if the answer to every question in a sub-chart leads to “non-significant change” also when returning to the main chart. On the contrary, if any sub-chart delivers the result “significant change”, the change being assessed is a “significant change in design or intended purpose” according to the Article 120(3c), point (b) MDR.
General considerations
As a rule, the following changes in design and/or intended purpose should be regarded as “nonsignificant”:
• changes related to corrective actions assessed and accepted by the competent authority of the Member State in which the manufacturer or its authorised representative has its registered place of business (see also Q&A 17 of the CAMD’s FAQ – MDR Transitional provisions20) regarding design changes – the same approach should apply also to changes related to the intended purpose;
• correction of spelling mistakes or merely editorial changes of the information to be supplied with the device (e.g. label or instructions for use);
• updates of the information to be supplied with the device (e.g. label, instructions for use or implant card) if they are required by EU legislation other than the MDR (e.g. CLP Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures read in conjunction with Annex I, section 7.5 MDD), are mere clarifications and do not adversely affect the devices’ safety and performance in relation to existing or new risks;
• clarifications of intended purpose, population, clinical application in the information to be supplied with the device in line with the original certification.

Changes in the intended purpose
– Chart A
Regarding changes of the intended purpose the following principles should apply (see chart A):
Non-significant change:
• Limitation of the intended purpose (see Q&A 17.3 of the CAMD’s FAQ – MDR Transitional provisions), such as:
 restriction or deletion of certain indications;
 restriction or deletion of certain applications, e.g. anatomical site, delivery pathway or deployment method;
 restricting the target population.
Significant change:
• Extension of the intended purpose, such as:
 additional or new indications;
 additional or new clinical conditions.
• New user or patient population, such as:
 additional or new target population;
 additional or new user (e.g. change from professional use to layman use).
• New way of clinical application, such as:
 additional or new applications (different stage or severity of disease);
 additional or new anatomical site;
 new delivery pathway or deployment method.
When assessing whether the intended purpose is being changed, changes in the label or instructions for use, as well as promotional materials, that are linked to the use for which a device is intended (e.g. limitations, warnings) should be considered.
Changes in the design
– Charts B to E
Changes concerning software, substances or materials, or sterilisation also concern the design of the device. Specific flowcharts (C, D, E) are intended to assist in assessing whether changes in those areas should be considered significant changes in the design.
Regarding changes of the design the following principles should apply (see chart B): Note: Change of a software shall be primarily evaluated per chart C. However, there may be cases where a major change of a software may be considered a change in built-in control mechanism or device’s operating principles and therefore are evaluated according to chart B.
Non-significant change:
• change of the design that does not alter:
 the built-in control mechanism,
 the device’s operating principle,
 the change of the source of energy, or
 the alarms systems and which does not adversely affect the safety, performance or usability and negatively affect the risk/benefit ratio of the device.
Examples:
Change in Specification/Labelling:
• change within the currently certified range (more narrow or detailed information), new article inside certified worst case or accepted bracket validations such as: new screw variant within current range of lengths and diameter; new catheter variant, with length and diameter within current range and worst case in sterilisation performance; new stent lengths which are intermediate between the previously certified stent lengths.
• change of colour of an assembly or device;
• change to the grip of a steerable ablation catheter to provide improved ergonomic comfort for the healthcare professional or aesthetic presentation of the device without changing the functionality;
• change to device housing that are minor reinforcement or attachments (handles/extra handles) or changes to supporting parts (for reduction of vibration);
• change to design for an easier operation, such as change to the thumb rest of injection syringe, change to lids or change to the mechanism of loading substances;
• change/modification of a connector to reduce misconnection and thereby improve safety of use;
• modification of a part (e.g. a connector) to adhere to a new or revised standard;
• removal of accessories (e.g. torque device) from a system (which is certified as a device) that are otherwise clinically readily available;
• formatting an existing IFU content into a newly created IFU, including reorganization of information; • editorial labelling improvements to warnings and precautions to better communicate and clarify critical information to the end user;
• adding to an existing IFU a new list of accessories including new versions of an accessory assigned to the device;
• change of label or packaging material of a non-sterile device e.g. a change in packaging from one variant of polyethylene to another due to supplier rationalization or cost saving measures;
• change to primary package size within previously validated range and previously validated sterilisation parameters;
• changes to outer packaging (e.g. size, material, layout) that do not adversely affect the stability, sterility or microbiological state of the device;
• extension of temperature or humidity range limitations for operation or storage;
• changes in reprocessing instructions, including increase of the number of allowed reprocessing cycles of a re-usable device in the related labelling, if achieved without changing the device design but provision of appropriate testing.
Note: These examples are valid only provided that the risk/benefit ratio of the device is not negatively affected.
Change of a component of a device (in particular electronics):
• change of a semiconductor/electronic component/electronic assembly, e.g. due to obsolescence;
• replacement of a semiconductor/electronic component/electronic assembly with the same specifications.
• replacement of a semiconductor/electronic component/electronic assembly with the same function, and requiring changes such as: re-layout of the printed circuit board (e.g. if not drop-in compatible); installation of a new firmware of software driver to operate the new semiconductor; adjustments of the software operating the device to accommodate the new semiconductor to operate as intended; re-arrangement of interfaces.
• addition of a coating on a non-contacting patient printed circuit board assembly (PCBA) to improve electrical current insulation;
• replacement of alarm signal generation components, e.g. LEDs, speakers;
• change of size or geometrical shape of operation/alarm buttons;
• change of the audible alarm mode by an additional red light.
Note: These examples are valid only provided that the risk/benefit ratio of the device is not negatively affected.

Change to the source of energy:
• change of a battery type, e.g. from AA to 6LR61;
• change of battery chemistry, e.g. from Alkaline to Lithium Manganese Dioxide or from lead acid batteries to lithium iron phosphate (LiFePo) batteries;
• change from a battery to a rechargeable accumulator, if recharging takes place outside of the device;
• change of battery charger or supply cords (under same specification).
Note: These examples are valid only provided that the risk/benefit ratio of the device is not negatively affected.
Significant change:
• change of the design that alter:
 the built-in control mechanism,
 the device’s operating principle,
 the change of the source of energy, or
 the alarms systems.
Examples:
• change from analogue to digital control;
• change from manual to software driven device;
• change to measuring function, wavelength or light emission;
• replacement of PCB with new feature or change of control circuits;
• change from energy source battery or accumulator to net-power operation of the device or vice versa; or from LED (Light-Emitting Diode ) to U.V rays;
• reduction of battery operating time;
• change of an advisor for the Insulin-bolus-volume in an Insulin pump;
• silencing/removing/adding of an alarm system or handling of alarm situation.

Changes that may adversely affect the safety or performance and negatively affect the risk/benefit ratio of the device, even if they do not alter the built-in control mechanism, the device’s operating principle, the change of the source of energy or the alarm systems.
Examples:
• change to device dimensions or design characteristics outside of current specifications, such as: new stent lengths which are outside of the range of the previously certified stent lengths; addition of two or more electrodes, or a new anchoring mechanism on an implantable pacing lead; reduction in size of the wire diameter to reduce the overall pacing lead diameter;
• widening of specification limits on critical component/parameter;
• new sensors with different working principle (e.g. air bubble detector with ultrasound vs light sensor; alarm noise to light);
• change to mechanisms for preventing reflux of substances;
• removal of a design and development input.
Software changes
– Chart C
Regarding software changes the following principles should apply (see chart C):
Non-significant change:
Examples:
• correction of an error which brings the device back to its original specification (bug fix);
• performance improvements intended to reduce latency;
• security update (e.g. cyber-security enhancements, longevity calculations);
• updates or upgrades of standard third-party operating systems, e.g. Microsoft Windows, iOS, Android;
• appearance of the user interface (e.g. new languages, layouts or graphics) provided that the changes do neither negatively affect the usability nor add new functions;
• changes to enhance the user interface without changes in performance (e.g. software change to allow the healthcare professional to select and/or change the preexisting units of measure on a blood oxygen monitor);
• improvement to operating efficiencies (e.g. allow the queuing of multiple criteria without alteration to performance, safety or interpretation of data);
• new non-medical features, such as: software changes only introducing non-therapeutic and/or non-diagnostic features (e.g. printing, improved image clarity, reporting format, additional languages, barcode reader); change of the software manufacturer’s graphical charter (logo, colours, fonts); change including algorithm change impacting the control of the device without alteration of diagnosis or treatment; software change that disables a feature that does not interact with other features; displaying data on the screen which were already present in the device and part of the original conformity assessment.
Note: These examples are valid only provided that the risk/benefit ratio of the device is not negatively affected.
Significant change:
Examples:
• new or major change of operating system or any component (beyond minor changes) (e.g. Linux to Windows or iOS or Android) or new version of an operating system Windows 10 to Windows 11) if modification to the device software is required;
• new or major modification of architecture;
• change of an algorithm which impact the operating principles or impact the control of the device and may alter the diagnosis or therapy delivered;
• required user input replaced by closed loop algorithm;
• new user interface, such as: presentation of medical data in a new format or by a new dimension or measuring unit; keyboard input to touchscreen; keyboard to wireless remote control; software changes that impacts the way data is read or interpreted by the user, such that the treatment of the patient may be altered when compared to previous version of software;
• new medical feature or functionality that may change the diagnosis or the therapy delivered to the patient;
• new channel of interoperability (e.g. software changes that allow for wireless communication with compatible -continuous- blood glucose monitors).
Changes related to a substance or material
– Chart D
Regarding changes of substances or materials the following principles should apply (see MDCG 2020-3 Chart D):
Non-significant change:
• new or additional supplier/producer of a material within the defined specifications;
• substitution of a chemical substance in order to comply with other applicable laws and regulations e.g. REACH Regulation (EC) No 1907/2006;
• replacing a substance or material, unless considered a significant change as listed below. Examples: • update to material grade (e.g. additives in Loctite adhesive) with no change to specification;
• change in supplier that extrudes the polymer tubing with no change in device specifications;
• replacing a material of a sterile device’s packaging that has no function in maintaining the sterile barrier or packaging integrity;
• change in a material which serves solely as a processing aid which is not available on the finally cleaned device and therefore considered a manufacturing but not a design change;
• addition of an antioxidant to the drug coating of a combination product that reduces the degradation of the drug during production but does not alter its pharmaceutical properties or release kinetics.
Note: These examples are valid only provided that the risk/benefit ratio of the device is not negatively affected.
Significant change:
• change to a material or substance which is part of an implant and intended for direct or indirect contact with patient tissue or fluid for more than 30 days, or is part of a surgically invasive device which is absorbed;
• addition or change of a material of human/animal origin (e.g. collagen produced from skins by collagen produced from bones);
• change to a material containing a medicinal substance (i.e. excipient or carrier material with influence on the delivery of the medicinal substance), or to the medicinal substance itself;
• change from a material with a low toxicological or biological risk to a material with a higher one;
• new or changed substance or material that adversely affects the safety or performance of the device and therefore negatively affects the risk/benefit ratio of the device.
Changes related to sterilisation
– Chart E
Regarding changes related to the sterilisation method or related to the design or the packaging with impact on the sterile condition of the device, the following principles should apply (see chart E):
Non-significant change:
• change of the sterilisation cycle parameters;
• extension of the shelf life validated by protocols approved by the notified body;
• new sterilisation vendor or chamber;
• change from single sterile to double sterile packaging.
Note: These examples are valid only provided that there is not impact to sterility assurance level or sterilisation residuals.
Significant change:
• change of the terminal sterilisation method (e.g. ETO to Gamma);
• change from biological indicator to parametric release;
• changing a device from labelled “non-sterile” to labelled “sterile”;
• change (e.g. of the device) which adversely affects the sterility assurance level;
• change in packaging design which affects sterility, stability or microbiological state of the device, including seal integrity;
• extension of the (labelled) shelf life which is not validated against protocols approved by the notified body.
• changes to storage or transportation conditions which could adversely affect the sterility or stability.

For application of Flow Charts, please see MDCG 2020-3 Flow ChartsA, B, C, D and E.

We hope that the information provided above will be useful in your change evaluation efforts.

SZUTEST UYGUNLUK DEĞERLENDİRME A.Ş.
Adres: Tatlısu Mahallesi, Akif İnan Sk. No:1, 34774 Ümraniye/İstanbul
Tel: +90 216 469 46 66 (pbx)
Fax: +90 216 469 46 67
Email: info@szutest.com.tr

 In line with Article 27 of the (EU) 2017/745 Medical Device Regulation (MDR), manufacturers for all medical devices, except for custom-made devices to be certified under MDR;

1. a) the creation of a UDI, including:

1) a UDI device identifier (‘UDI-DI’) specific to a manufacturer and a device

2) a UDI production identifier (‘UDI-PI’) that identifies the unit of device production and if applicable the packaged devices

28. b) placing of the UDI on the label of the device or on its packaging and before a device is placed on the market the manufacturer shall ensure that the information referred to in Part B of Annex VI of the device in question are correctly submitted and transferred to the UDI database referred to in Article 28.

• UDI carriers are placed on the label of the device and on all upper levels of the packaging. Upper levels of packaging do not include shipping containers.
• The UDI shall be used for reporting serious incidents and field  safety corrective actions in  accordance with Article 87
• The Basic UDI-DI, as defined in Part C of Annex VI, of the device shall appear on the EU declaration of conformity referred to in Article 19.
• Manufacturers shall keep the list of all assigned UDIs up to date as part of the technical documentation referred to in Annex II.

The guidance document “MDCG 2021-25” has been published for legacy devices manufactured within the scope of the Medical Device Regulation (93/42/EEC) and to be placed on the market after 26.05.2021.

According to this guide, it is seen that MDR “Article 27 Single Device Identification System” is not applicable for legacy devices, while “MDR Article 29 Devices Registration” provision is applicable.

In this context, the guidance document published on “Registration of Legacy Devices in MDCG 2019-5 EUDAMED” provides information on how to EUDAMED registration of legacy devices that do not have Basic UDI-DI according to MDR article 27.

In line with the MDR and guidance documents, there is no obligation to have UDI on the legacy devices themselves, on their labels and on their packaging.

Many chemicals are used in the production of electrical and electronic equipment (EEE). These substances, including heavy metals, can cause serious damage to human health and the ecosystem when they mix with nature. When we consider that the use of EEE and consequently the amount of electronic waste has increased exponentially with the rapidly developing technology, we see that the dimensions of the danger increase even more.

Based on this danger, the European Union (EU) introduced two important regulations for the production of EEEs in 2003. These regulations, including the Restriction of the Use of Certain Harmful Substances in Electrical and Electronic Equipment (RoHS) and the Control of Waste Electrical and Electronic Equipment (WEEE); In addition to limiting the use of harmful substances such as Mercury (Hg), Lead (Pb), Cadmium (Cd) in the production of EEEs, it introduced the technical framework for environmentally friendly recycling of waste EEEs. Within the framework of the RoHS regulation, which has been revised twice, taking into account the technological developments in the process until today, manufacturers are required to declare their compliance with the specified conditions in order to put their products on the market. This declaration, also called the RoHS document, is a prerequisite for EEEs to be placed on the market in Europe and in our country.

ITS SCOPE AND EQUIVALENT IN OUR COUNTRY’S LEGISLATION

The RoHS directive was first transferred to our country’s legislation within the scope of the Regulation on the Limitation of the Use of Certain Harmful Substances in Electrical and Electronic Equipment dated 30 May 2008. The Waste Electrical and Electronic Equipment (WEEE) Control Regulation, which was issued in May 2012, combined the two regulations and canceled the previous regulation. The regulation in its current form;

-Large household items

-Small appliances

-IT and telecommunications equipment

-Consumer equipment

-Lighting equipment

-Electrical and Electronic tools

-Toys, entertainment and sports equipment

-Vending machines

-Medical devices

-Monitoring and control tools

It covers a large number of products from refrigerators to dialysis devices in a total of 10 different categories. It is possible to see the detailed list of these products in Annex 1/B of the Regulation. The Regulation, which sets out the technical conditions and product group-based targets for the recycling of waste EEEs in an environmentally compatible manner, also includes the limit values listed below for substances harmful to health used in production.:

-Mercury (Hg) – 0.1%

-Cadmium (Cd) – 0.01%

-Lead (Pb) – 0.1%

-Chromium (Cr) – 0.1%

-Polybromide Biphenyl (PBB) – 0.1%

-Polybromide Diphenyl Ether (PBDE) – 0.1%

Detailed information on the said limit values can be found in Annex 2 of the regulation.

HOW IS THE ROHS CERTIFICATE PREPARED? WHAT DOES IT CONTAIN?

Manufacturers need to prove that the content of their products complies with the limit values we have stated above in order to obtain the RoHS Certificate. For this purpose, the products sent to the laboratory are analyzed in accordance with the relevant TS EN 62321 standard and a technical file is prepared. In case the analysis results comply with the values stipulated in the Regulation, the RoHS certificate to be prepared should contain the following information:

-Statement that it has been manufactured in accordance with the Regulation on the Restriction of the Use of Certain Harmful Substances in Electrical and Electronic Equipment

-Manufacturer Name and Address

-Name and types of products

-Company contact information

-A reference to the test report

-Test standard

-Place and date declared

In this preparation process, we see the importance of getting help from competent institutions for necessary analyzes and technical files.