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Review
. 2021 Jul;35(7):1444-1448.
doi: 10.1111/jdv.17238. Epub 2021 May 6.

Position statement: The need for EU legislation to require disclosure and labelling of the composition of medical devices

Affiliations
Review

Position statement: The need for EU legislation to require disclosure and labelling of the composition of medical devices

A Herman et al. J Eur Acad Dermatol Venereol. 2021 Jul.

Abstract

Background: In recent years, skin reactions secondary to the use of medical devices (MD), such as allergic contact dermatitis have increasingly been observed (e.g. to continuous blood sugar monitoring systems, insulin pumps, wound dressings, medical gloves, etc.): this is regarded as a developing epidemic. Lack of labelling of the composition of MD, as well as frequent lack of cooperation of manufacturers to disclose this relevant information, even when contacted by the clinician for the individual case of an established adverse reaction, significantly impede patient care.

Objectives: To advocate for full ingredient labelling in the implementation of EU regulation for MD.

Methods: This position paper reviews the scientific literature, the current regulatory framework adopted for MD to date, and the likely impact, including some costs data in case of the absence of such labelling.

Results: Efforts made by several scientific teams, who are trying to identify the culprit of such adverse effects, either via asking for cooperation from companies, or using costly chemical analyses of MD, can only partly, and with considerable delay, compensate for the absence of meaningful information on the composition of MD; hence, patient management is compromised. Indeed, without knowing the chemical substances present, physicians are unable to inform patients about which substances they should avoid, and which alternative MD may be suitable/tolerated.

Conclusion: There is an urgent need for full and accurate labelling of the chemical composition of MD in contact with the human body.

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References

    1. Regulation (EU) 2017/745 of the European Parliament and of the Council of 5 April 2017 on medical devices aDE, Regulation (EC) No 178/2002 and Regulation (EC) No 1223/2009 and repealing Council Directives 90/385/EEC and 93/42/EEC. URL https://eur‐lex.europa.eu/legal‐content/EN/TXT/HTML/?uri=CELEX:32017R074... (last accessed: 15 October 2020).
    1. Regulation (EU) 2017/746 of the European Parliament and of the Council of 5 April 2017 on in vitro diagnostic medical devices and repealing Directive 98/79/EC and Commission Decision. URL https://eur‐lex.europa.eu/legal‐content/EN/TXT/HTML/?uri=CELEX:32017R074... (last accessed: 10 October 2020).
    1. European Commission . Regulatory framework. The new Regulations on medical devices. URL https://ec.europa.eu/growth/sectors/medical‐devices/regulatory‐framework_en (last accessed: 26 June 2019).
    1. Regulation (EU) 2020/561 of the European Parliament and of the council of 23 April 2020 amending Regulation (EU) 2017/745 on medical devices, as regards the dates of application of certain of its provisions. URL https://eur‐lex.europa.eu/legal‐content/EN/TXT/PDF/?uri=CELEX:32020R0561... (last accessed: 5 May 2020).
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