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Secondary Manufacturing of MD/IVMD

Comprehensive manufacturing, packaging, labelling, and distribution support for medical devices and IVDs.

Manufacturing Excellence

Secondary manufacturing of medical devices and in vitro diagnostic medical devices (IVMD) encompasses all processes that take place after primary manufacturing, including packaging, labelling, sterilization, and preparation for distribution.

CEHP provides expert consulting and operational support to ensure your secondary manufacturing processes meet all regulatory requirements under MDR (EU 2017/745) and IVDR (EU 2017/746), while optimizing efficiency and quality.

Whether you are establishing new manufacturing operations or optimizing existing ones, our team brings the expertise needed to navigate the complex regulatory landscape of medical device manufacturing in Europe.

Core Capabilities

  • Packaging design, validation, and compliance
  • Labelling compliance under MDR/IVDR (including UDI)
  • Sterilization process management and validation
  • Supply chain optimization and logistics
  • GDP and GMP compliance consulting
  • Distribution channel setup across EU
  • Quality management system support
  • Regulatory documentation for manufacturing

Our Manufacturing Services

Packaging & Labelling

  • Primary and secondary packaging design
  • Packaging validation (IEC 11607)
  • UDI implementation and compliance
  • Multilingual labelling for EU markets
  • Symbols and regulatory marking compliance

Sterilization & Quality

  • Sterilization method selection and validation
  • Bioburden testing coordination
  • Clean room operations consulting
  • Environmental monitoring programs
  • Process validation and qualification

Distribution & Logistics

  • EU-wide distribution strategy
  • Authorized representative services
  • Import and customs compliance
  • Cold chain management
  • Traceability systems implementation

Regulatory Manufacturing Support

  • Manufacturing site registration
  • Technical documentation for manufacturing
  • Supplier qualification and auditing
  • Change management processes
  • Complaint handling systems
Regulatory & Market Context

The European Commission has recently adopted measures under the International Procurement Instrument (IPI) following its first investigation into barriers affecting EU access to third-country public procurement markets. Under these measures, EU contracting authorities may exclude Chinese companies from public procurement procedures for medical devices exceeding EUR 5 million, and successful tenders may include no more than 50% of input materials originating from China, unless specific exemptions apply.

These measures are proportionate, compliant with EU international obligations (including WTO rules), and designed to ensure the availability of essential medical devices for EU healthcare systems, while protecting EU enterprises from unfair and discriminatory treatment.

Strategic Opportunity: Manufacturing in Bulgaria (EU)

Establishing manufacturing or assembly operations in Bulgaria offers a sustainable and fully compliant pathway to continued access to the EU market.

Products manufactured in Bulgaria are legally treated as EU-origin products

They are fully eligible for EU public procurement, including large-scale government tenders

They benefit from unrestricted access to the EU Single Market

Clinical investigations and performance studies may be conducted on a Bulgarian (European) patient population, strengthening regulatory acceptance and market credibility

Full compliance with MDR (EU 2017/745) and IVDR (EU 2017/746) can be ensured from the earliest development stage

Proposed Scope of Cooperation

A comprehensive end-to-end cooperation model, covering the entire lifecycle of medical devices and IVD products.

1

Establishment of Manufacturing / Production Lines in Bulgaria

  • Technology transfer and localization
  • ISO 13485 and GMP-compliant production
  • Structuring of EU-compliant supply chains in line with origin requirements
2

Clinical Investigations & Performance Evaluation

  • Clinical trials and performance studies conducted in Bulgarian healthcare institutions
  • Access to accredited clinical sites and CEHP-BMA (CRO) infrastructure
  • Generation of EU-relevant clinical and performance evidence
3

CE Marking & Regulatory Compliance

  • Preparation of full technical documentation
  • Clinical Evaluation Reports (CER) and Performance Evaluation Reports (PER)
  • Interaction with Notified Bodies and conformity assessment procedures
  • UDI implementation, labeling and IFU localization
4

Post-Market Surveillance & Vigilance

  • PMS, PMCF and PMPF systems
  • Vigilance reporting and regulatory lifecycle management
  • Continuous compliance with MDR and IVDR requirements
5

Market Access & Public Procurement Support in Bulgaria

  • Public procurement eligibility and tender strategy
  • Market entry planning
  • Engagement with healthcare institutions and distribution networks
Strategic Rationale

This initiative responds to the EU's objective to protect EU enterprises from long-standing discriminatory practices, while maintaining an open and rules-based trade framework. At the same time, it enables manufacturers to:

  • Retain full and sustainable access to the EU market
  • Mitigate regulatory and geopolitical risks
  • Establish long-term partnerships within the EU healthcare ecosystem

Next Steps

  • Product portfolios suitable for EU localization
  • Manufacturing in Bulgaria and regulatory timelines
  • Partnership and investment models
Discuss Your Project

Optimize Your Manufacturing Operations

Contact us to learn how CEHP can support your secondary manufacturing needs for medical devices and IVDs.

Contact Us