Page Last Reviewed: 2 January 2024
Yes, it is possible to transfer to a different UKRP. There is nothing that prohibits changing your UKRP from one company to another.
No, it is not possible to have more than one UKRP at the same time.
Per the MHRA’s Guidance on Regulation Medical Devices in the UK, manufacturers can only have one UKRP and that UKRP must represent all of the manufacturer’s devices in Great Britain.
“If you are a medical device manufacturer based outside the UK and wish to place a device on the Great Britain market, you need to appoint a single UK Responsible Person for all of your devices, who will act on your behalf to carry out specified tasks, such as registration.”
Therefore, this is an especially key role in the UK.
For example: You designate a distributor as your UKRP. That distributor only sells certain devices in your product line, but you intend to sell different products to other distributors / hospitals / end users. That UKRP must still act as the UKRP for all those other devices. They must register those devices for you and your other customers, since they are the UKRP. Further, they must notify the MHRA of your other UK importers, which could be their competition.
This is different from Europe, in which a manufacturer can have multiple EU Authorized Representatives, as long as they represent different devices.
No, a UKRP transfer agreement is not required at this time.
The reason this question is relevant is because the European MDR/IVDR (Art. 12) requires that:
“detailed arrangements for a change of authorised representative shall be clearly defined in an agreement between the manufacturer, where practicable the outgoing authorised representative, and the incoming authorised representative.”
The UK left the European Union in the so-called ‘Brexit’ before the MDR/IVDR dates of application. As a result, the UK’s current legislation is still based on the old Directives, which were in force at the time they left the EU. The old Directives do not require a transfer agreement. That said, the MHRA is in the process of updating its legislation, with many MDR/IVDR level changes proposed. Therefore, it could be required in the future.
The manufacturer must time the transition from its current UKRP to the new UKRP.
This is important because a UKRP is required to register the manufacturer they represent, and the manufacturer’s devices. However, the new UKRP cannot do this if there is already an active registration under a different UKRP. If so, the MHRA will reject the new UKRP’s application.
Once the new registration is granted, the MHRA will issue a confirmation letter and publish the manufacturer and device registration on its public database.
The above is based upon the devices being CE marked. European CE marking is currently accepted by the MHRA due to a transition allowance. If the device is UKCA marked, then the following additional steps apply before starting the re-registration process:
For more information on UKCA marking transition dates, please read: New Dates for UK Regulation & CE Marking
If you are placing devices onto Great Britain via the CE Marking transition period allowance, then no labeling updates are required.
Per the MHRA guidance Regulating Medical Devices in the UK:
“The name and address of the UK Responsible Person, where applicable, must be included on the product labelling or the outer packaging, or the instructions for use in cases where the UKCA marking has been affixed. UK Responsible Person details do not need to be included on labelling for CE marked devices, unless the device bears both the CE and UKCA markings.”
A few notes on the CE Marking transition period:
The timing to transfer your UKRP is ultimately based on:
If all parties move at a reasonable pace, it can be completed within 1-2 weeks.