EU MDR & IVDR Clinical Evidence

Clinical
Evaluation
Reports

The document that carries your CE mark

Why the CER Decides Everything

Your Notified Body Reads the CER First. Make It Unarguable.

Under EU MDR 2017/745, the Clinical Evaluation Report is the document that carries your CE mark. It must prove, from systematically gathered clinical evidence, that your device's benefits outweigh its risks against the current state of the art. The bar rose sharply from the MDD era, and a report that reads like a narrative instead of a proof is a report the assessor sends back. We plan, author, and defend clinical evaluations that pass notified body review the first time, so a documentation finding never becomes the thing standing between your device and the European market.

A reviewer appraising clinical study data against a device dossier
Evidence that holds

Literature, clinical data, and a benefit-risk conclusion a notified body accepts the first time.

The Bar Moved

What Passed Under the MDD Will Not Pass Under the MDR.

The regulation did not just add paperwork. It changed what “sufficient clinical evidence” means, and every legacy device is now measured against the new standard, not the one it was certified under.

Then
Under the MDD
  • Equivalence was a practical shortcut to a predicate's data.
  • A narrative literature review, lightly documented.
  • The CER was a document you finished at certification.
  • Clinical data included “as appropriate” to the device.
Now
Under the MDR
  • Equivalence is a commitment to prove technical, biological, and clinical characteristics.
  • A reproducible, systematic search a notified body can rerun.
  • The CER is a living document tied to your post-market data.
  • Sufficient clinical evidence, benchmarked to the current state of the art.
Open scientific literature representing the systematic review behind a clinical evaluation
The bar moved

A reproducible, systematic literature search a notified body can rerun, benchmarked to the current state of the art.

A Loop, Not a Line

Under the MDR, Clinical Evaluation Never Closes.

The CER is not a deliverable you file and forget. It runs on a cycle: plan the evidence, gather it, appraise it, conclude on benefit-risk, then feed real-world data back in and begin again.

A clinical specialist reviewing device performance records
Kept current, on purpose

Post-market data flows back into the evaluation, so recertification is routine, not a scramble.

Plan

Clinical Evaluation Plan

Fix the scope, the evidence you will gather, and the standard you hold it to, so the report writes toward a conclusion.

Gather

Systematic Literature

A search a notified body can rerun and an appraisal it cannot fault, the step where most CERs quietly fail.

Appraise

Weigh the Evidence

Every source graded on the same criteria, applied consistently, with the weak data marked as weak.

Conclude

Benefit-Risk

A conclusion that follows from the data presented, against the state of the art, with nothing in the file contradicting it.

Monitor

PMCF & PMS

Post-market clinical follow-up fills the gaps the CER identified and feeds the next revision.

PMCF and post-market surveillance feed straight back into the plan. The evaluation that clears this audit is already building the evidence for the next one.
The Equivalence Test

Three Characteristics. All Three Must Hold.

The fastest way to sink a CER is to build it on an equivalence claim that does not survive scrutiny. Under the MDR, equivalence is not one judgment but three, and a gap in any single one collapses the whole claim.

Technical

Same design, conditions of use, specifications, and principles of operation, close enough that the differences do not affect safety or performance.

Biological

The same materials in contact with the same tissues or body fluids, so the biological response can be assumed to match.

Clinical

The same condition, purpose, site, population, and performance, used under the same clinical circumstances.

Demonstrate all three, with genuine access to the data behind them, or the claim fails and the CER needs clinical evidence of its own.
Clinician reviewing diagnostic imaging as clinical evidence for a device evaluation
Appraised clinical performance data on screen supporting an equivalence claim

CER update due before your next surveillance audit? The literature review alone takes longer than you think.

Talk to an Expert
Why CERs Come Back

The Findings a Notified Body Writes Most.

Rejections rarely turn on the device. They turn on the report: gaps in method and consistency an assessor is trained to find on the very first read.

Clinical research documentation under review
Found on the first read

An assessor knows exactly where a CER's seams are. We close them before the file is submitted.

Unreproducible Searches

A literature search the assessor cannot rerun to the same result, the single most common deficiency.

Inconsistent Appraisal

Grading criteria applied loosely, with favourable papers quietly weighted over inconvenient ones.

Equivalence That Does Not Hold

A claim missing one of the three characteristics, or without real access to the predicate's data — why that access bar is narrower than it looks.

State of the Art Ignored

Benefit-risk argued in isolation, not against what current alternatives already achieve.

Conclusion Ahead of the Data

A benefit-risk conclusion the evidence actually in the file does not support.

PMCF Disconnected

A post-market plan that does not address the specific evidence gaps the CER itself identified.

Same Discipline, Two Variations

Diagnostics, and Devices Caught Mid-Transition.

IVDR

Performance Evaluation

Under IVDR 2017/746, in vitro diagnostics need a Performance Evaluation Report built on three pillars: scientific validity, analytical performance, and clinical performance. The same rigour as a CER, a different structure, and a notified body scope that now reaches most assays for the first time.

Legacy Devices

MDD-to-MDR Transition

Devices certified under the old MDD face a harder question at recertification: is the existing clinical evidence still sufficient under MDCG 2020-6, or has the state of the art moved past it? We answer that before the notified body does, and rebuild the evidence where it falls short.

Who You Work With

Writers Who Think Like the Assessor Across the Table.

A CER is won by anticipating the questions before they are asked. Your leads are senior clinical evaluators, medical writers, and former notified body reviewers who have authored clinical evaluations across device classes and defended them through review.

The Assessor's Eye

We review our own drafts the way a notified body will, and close the seams before the file is ever submitted.

Method-Disciplined

Reproducible searches and consistent appraisal, documented so the method itself is never the finding.

Across Device Classes

Implantable, surgical, software as a medical device, and IVDs, each with its own evidence expectations.

Built to Stay Current

CERs wired to your PMCF and PMS, so the next revision is an update, not a rebuild from scratch.

Clinical evaluator documenting appraised evidence for a Clinical Evaluation Report
Where to Go Next

The Work a CER Sits Inside.

Clinical evaluation is one piece of the European device dossier. These are the services it connects to most.

Work With Us

Your Next CER Cycle Starts Now.

Tell us where the device stands: first CE mark, MDR transition, scheduled update, or an open deficiency letter. We'll match you with a senior clinical evaluation lead and respond within one business day. All inquiries are strictly confidential.

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