For nearly 30 years, the U.S. Food and Drug Administration has played a pivotal role in shaping the global medical device industry through strict regulatory requirements, international cooperation, and adaptation to technological advancements. However, with significant changes on the horizon in the U.S., how will these developments affect medical device manufacturers in Europe?

The United States remains a crucial market for European medical device manufacturers. As the world’s largest medical device market, it offers significant opportunities for European companies seeking global expansion. Additionally, the complexity of the EU Medical Device Regulation has prompted some non-European manufacturers to prioritize the U.S. as their preferred market for growth.

In recent years, the FDA has made substantial investments to enhance regulatory efficiency and accelerate market access. Programs such as E-Star, the Breakthrough Devices Program, and the Total Product Life Cycle (TPLC) Advisory Program facilitate early engagement and prioritized review for innovative technologies. Furthermore, increased staffing and funding through the Medical Device User Fee Amendments (MDUFA) have strengthened the FDA’s review processes, ensuring a more efficient and timely approval pathway.

As of February 2025, President Donald Trump’s administration has proposed significant reforms to the FDA. The nomination of Robert F. Kennedy Jr. as Secretary of Health and Human Services (HHS) signals a potential shift in the agency’s regulatory approach and priorities. Additionally, the administration is considering an executive order that could significantly reduce the FDA’s workforce. The administration has also indicated plans to streamline FDA ´s regulatory processes to accelerate the approval of innovative medical devices. Proposed measures include reducing bureaucratic obstacles. Specific details on the implementation of these changes have, however, not yet been fully outlined.

The current uncertainties surrounding potential FDA regulatory changes under the Trump administration create challenges for EU medical device manufacturers seeking U.S. market entry. A faster, less stringent approval process could lower barriers to entry, but shifting FDA policies may create unpredictability in compliance expectations, making it harder for EU manufacturers to align their regulatory processes. This regulatory uncertainty can affect investment decisions and long-term planning for companies looking to expand into the U.S. market.

The future development of the regulatory landscape in the U.S. remains uncertain and needs to be closely monitored by manufacturers intending to enter U.S.  At QAdvis, our Quality and Regulatory consultancy team tracks these developments to support our customers and provide a proactive approach to upcoming changes. Or, to paraphrase Charles Darwin; The one most responsive to change is the one most likely to survive.

The Health Technology Assessment Regulation (HTAR), officially known as Regulation (EU) 2021/2282, marks an advancement in the evaluation of health technologies within the European Union. Effective from January 12th, 2025, the HTAR aims to harmonize the assessment processes for health technologies, including medical devices (MDs) and in vitro diagnostic medical devices (IVDs), across EU member states.

Key objectives of the HTAR
The primary objective of the HTAR is to establish a structured and legally binding process for evaluating the relative clinical effectiveness and safety of health technologies at the EU level.

At the core of this process are the joint clinical assessments (JCAs), entailing a scientific evidence-based “analysis of the available clinical evidence on a specific health technology in comparison with one or more other health technologies or existing procedures, addressing a specific health problem”.

Once published, EU Member States will have to give due consideration to the JCA outcomes in their own national HTA reports. The information thus generated will allow national competent authorities to determine the relative effectiveness of new or existing health technologies and inform policymaking for the purpose of reimbursement and price negotiations at national level.

What’s in scope?
Under the HTAR, the implementation of JCAs is planned to be phased over time. Starting from 2025, JCAs will be mandatory for cancer medicines containing new active substances, advanced therapy medicinal products and a selection of high-risk MDs and IVDs. From January 2028, orphan medicinal products will be added to the list, and from 2030 all new medicinal products will be in scope of the HTAR.

High-risk MDs and IVDs
The following high-risk devices shall be subjected to JCAs:

  • Class IIb active devices intended to administer and/or remove a medicinal product and class III implantable MDs for which the relevant expert panels have provided a scientific opinion in the framework of the clinical evaluation consultation procedure.
  • Class D IVDs for which the relevant expert panels have provided their views in the framework of the performance evaluation consultation procedure.

Implementing acts will be released by the European Commission at least every two years to define which, among the high-risk devices listed above, will be selected to fall under the scope of the JCAs.

Importantly, according to the HTAR, the mandatory JCA process for high-risk devices should not delay or interfere with CE-marking of MDs and IVDs, nor should it delay their market access. Once the certification is obtained, manufacturers of devices falling under the scope of JCA are expected to contact with the HTA Secretariat and submit a summary of all the relevant clinical data supporting the device’s safety and clinical performance. Further guidance on how the application process will formally look like for MDs and IVDs is expected shortly.

What can I do as a manufacturer?
As a manufacturer of a high-risk device, it is advisable to ensure that robust processes are implemented for the collection and analysis of clinical data. Clinical evaluation (MD) and performance evaluation (IVD) reports are key documents in the dossier which the manufacturer is expected to submit for JCA.

To stay informed about the selection process for high-risk devices under the HTAR, and seek guidance on the actual application process, manufacturers are advised to:

Talk to us at QAdvis for professional advice –  we are always nearby and can help you navigate the new HTA Regulation!

QAdvis is delighted to announce that Anna-Karin Alm has joined QAdvis as the new CEO, effective from February 1st 2025.

We are delighted to announce the appointment of Anna-Karin Alm as the new CEO of QAdvis AB, succeeding Robert Ginsberg, who has decided to step down from this position. Anna-Karin also assumes the QA/RA Business Area Head position in Aurevia, and is a member of the Aurevia Management team.

Anna-Karin is an experienced leader with over 20 years in leading roles within the Medical Technology sector. She is dedicated to defining and improving organizations and has worked in medical device companies throughout her career.

Anna-Karin brings a diverse set of leadership skills, having held positions such as CEO, Director of Medical Device Compliance, Director of Operational Excellence, Senior Consultant and Business Development Manager. Anna-Karin has also led multiple cross-functional and cross-cultural development teams and improvement projects. She emphasizes that product quality and corporate quality are essential for medtech companies, and she is committed to securing the success of our company by streamlining these services. Most recently, she has worked at Prevas AB (SDS MedteQ AB) and SHL Group AB.

 “I am delighted to introduce Anna-Karin as our new CEO. She brings a wealth of experience, fresh perspectives, and a strong commitment to the values that have shaped our company. I have full confidence that she will lead QAdvis into an exciting future together with Aurevia” says former QAdvis CEO Robert Ginsberg.

“I feel proud to be part of this experienced and skilled team of quality and regulatory experts within QAdvis and Aurevia. Our team has a broad set of skills, not only within our own business area, but also with colleagues within the CRO part of the organization. Together we will enable access for clients to the best experts within the broad medtech field.”, concludes Anna-Karin Alm.

Anna-Karins special interest in making the whole organization grow through strategic deployment work will be a great asset to QAdvis continued growth together with Aurevia.