Clinical Evaluation Report · EU MDR 2017/745

CER that Notified
Bodies accept
the first time.

Eclevar Medtech eliminates the root causes of Notified Body non-conformities before the first draft reaches the reviewer. We build clinical evidence that closes the cycle in one round.

Performance Metric 0 Major Non-Conformities Across Eclevar-managed CER submissions in 2024 and 2025.
MEDDEV 2.7/1 rev.4
Annex XIV Traceability
Article 61(4) Equivalence
PMCF Linkage
The Clinical Evidence Gap

Why most CERs fail
the first Notified Body review.

68%

Major NCR Rate at First Submission

More than two-thirds of Class IIb and Class III CER submissions under EU MDR receive a Major NCR. Issues range from insufficient safety evidence to missing PMCF feedback loops.

9mo

Average CE Mark Delay from CER Cycles

Each Q&A round adds 3-4 months. For many, cumulative delays exceed 9 months, resulting in massive lost market access for every month the device is not on the shelf.

Top 5 NCR Root Causes (EU MDR 2025)

01

Lack of traceable Annex XIV residual risk-to-clinical evidence mapping.

02

Equivalence claimed without similarity demonstrated.

03

PMCF Plan not linked to CER gaps.

04

Literature methodology fails MEDDEV 2.7/1 standards.

05

No state-of-the-art benchmark defined.

The Eclevar Medtech Difference

Building Backwards from the Notified Body Checklist. Every CER Eclevar authors is built against the same checklist that your Notified Body uses. Our team includes former reviewers who have assessed hundreds of packages. They know exactly which evidence gaps trigger a Major NCR.

Our CER Expert Team

Former Notified Body experts
who de-risk your CER.

Chief Medical Officer - CER Lead

Pierre-Marie Boutanquoi

Cardiology - Clinical Evidence Strategy - EU MDR Submissions

Pierre-Marie is a senior expert with deep expertise in methodology for high-risk cardiovascular devices. Former assessor for Class III packages, he builds documents the way a reviewer needs to read them.

MEDDEV 2.7/1 rev.4Equivalence ClaimsClass III CER
Chief Operating Officer - Regulatory Strategy

Mark DaCosta

EU MDR Regulatory Affairs - Notified Body Relationships

Mark specializes in shortening the Q&A cycle through structured pre-submission alignment meetings and proactive gap analysis before the first submission. Expert in NB relationship management.

NB RelationshipPre-SubmissionQ&A Management
CMO - Orthopedics - Former TUV SUD

Nikhil Khadabadi

Orthopedics & Spine - Class IIb / III Implants

Former assessor at TUV SUD. Nikhil has assessed clinical evidence for hundreds of implants from the reviewer side. He writes CERs against the exact internal assessment frameworks of major NBs.

Former TUV SUDOrthopedic ImplantsAssessor Standards
Our CER Architecture

How we eliminate every
Notified Body non-conformity.

01

Annex XIV Traceability Matrix

NCR: No residual risk-to-evidence mapping

We build a complete matrix mapping every CER residual risk to a specific clinical evidence source. Notified Bodies cannot find a gap because there are no gaps.

02

Article 61(4) Equivalence Architecture

NCR: Insufficient equivalence demonstration

We build the full three-dimensional similarity matrix (technical, biological, clinical) before equivalence is claimed. No assertion is made without documentation.

03

MEDDEV 2.7/1 Literature Methodology

NCR: SLR methodology fails scrutiny

Full MEDDEV 2.7/1 Section 9 compliance: predefined strategy, explicit inclusion/exclusion, PRISMA flow, and study appraisal with NICE or GRADE. No cherry-picking.

04

PMCF Plan Closing CER Gaps

NCR: PMCF Plan not linked to specific gaps

Each PMCF objective is derived directly from a specific evidence gap identified in the clinical evaluation. The PMCF Plan and CER are two sides of a single document.

Q&A Cycle Comparison

From months to weeks.

Typical Submission

  • Submit CER with narrative SLR.
  • Notified Body: Major NCR on SLR methodology.
  • CAPA: 2-3 months to revise SLR.
  • Notified Body: Major NCR on equivalence.
  • CAPA: 2 months to rebuild equivalence.
3-4 Rounds
Without Eclevar

Eclevar Submission

  • Pre-submission alignment.
  • Submit CER with full architecture.
  • Notified Body: Minor clarification queries only.
  • Clarification response: 2-3 weeks.
  • Final approval.
1 Round
With Eclevar

NCR Reference & Solutions

NCR ReferenceRoot CauseEclevar Solution
Equivalence inadequate (Art. 61(4)) Similarity not demonstrated per MDR Article 61(4). Full 3D similarity matrix built before claim.
SLR fails MEDDEV 2.7/1 rev.4 No PRISMA flow; narrative review only. Section 9 compliant SLR with GRADE appraisal.
No PMCF-to-CER gap linkage PMCF Plan authored independently. PMCF Plan co-authored with direct gap mapping.
SSCP inconsistent with CER Performance data values do not match conclusions. Documents co-authored from verified source documents.
CER Service Portfolio

Every CER deliverable,
one integrated framework.

State-of-the-Art Definition

Pre-evaluation definition of SoA for the device category, establish benchmarks before search begins.

SoA AnalysisBenchmarking

Systematic Literature Review

MEDDEV 2.7/1 Section 9 compliant review with PRISMA flow and GRADE/NICE appraisal.

PRISMASection 9

Equivalence Analysis

Full Article 61(4) coverage for technical, biological, and clinical similarity.

Art. 61(4)Technical Matrix

Data Appraisal & Integration

Critical appraisal of device-specific data (Investigations, PMCF, Registries).

RCT / RegistryIntegration

CER Authoring

Full MEDDEV 2.7/1 rev.4 authoring with embedded Annex XIV traceability matrix.

Annex XIVTraceability

SSCP & PMCF Integration

Co-authored deliverables to ensure 100% internal consistency across all documents.

SSCPPMCF Plan

Our Process

01

CER Gap Assessment

Free 30-min call to identify NB risks and map pathway.

02

Architecture and SoA

Build traceability and SoA benchmark before finalize strategy.

03

SLR and Appraisal

Section 9 SLR and comprehensive clinical data appraisal.

04

Authoring and Review

Draft CER reviewed by second expert against NB checklist.

05

Submission and Q&A

Manage NB cycle until final approval is achieved.

Free · 30 Minutes · No Obligation

Your CER should be the last one
with a Major NCR.

Book a free Clinical Evaluation Report Gap Assessment. We will review your current evidence and outline exactly what is required to achieve approval in a single round.

Book Free CER Strategy Call

Reforming Clinical Evaluation of Medical Devices in Europe