First Clinical Use / Europe

First-in-Human Medical Device Studies in Europe

Take the device from preclinical readiness to controlled first clinical use, with the investigator, procedure, safety controls and next decision defined beforehand.

Eclevar is a specialist medical device CRO. We assess whether a first-in-human study is justified, judge whether Europe is the right location, select the country, investigator and site, design and submit the investigation, oversee the first cases, and turn what they show into a next-stage decision.

  • FocusSpecialist medical device CRO
  • DesignClinician-led FIH strategy
  • ReviewFormer Notified Body clinical review experience
  • DeliveryEuropean country and site delivery
  • IntegratedClinical operations, data management and biostatistics

The decision

First-in-Human Is a Readiness Decision, Not a Calendar Milestone

First clinical use should not begin because the prototype exists, an investor milestone was announced, or a country looks like a fast submission route. The question is whether the residual uncertainty can be addressed in a human being, at a justified risk level, with controls that make the result interpretable. Five domains decide it.

  1. 01

    Device readiness

    Question
    Is the device used in the first case the device that was tested?
    Evidence
    Design status of the clinical configuration, verification and validation, sterilization, shelf life, controlled manufacture, traceability.
    If unresolved
    Observations cannot be attributed to a known configuration, and a later change strands the data.
  2. 02

    Clinical rationale

    Question
    What can only be answered in a human being?
    Evidence
    Intended purpose, target population, the residual uncertainty, and why preclinical work cannot resolve it.
    If unresolved
    The study collects experience rather than evidence, and the next decision stays unsupported.
  3. 03

    Risk controls

    Question
    What can go wrong in the first cases, and what is in place beforehand?
    Evidence
    Risk management file, procedure-specific hazards, mitigations, rescue options, a documented residual-risk position.
    If unresolved
    Events are managed improvisationally, and participant protection rests on one operator's judgment.
  4. 04

    Investigator and site readiness

    Question
    Can this team perform the procedure, recognize what is happening, and document it?
    Evidence
    Procedural experience, training and proctoring plan, site team, imaging and rescue capability, escalation route.
    If unresolved
    Operator variability dominates, and the result describes a site, not a device.
  5. 05

    Evidence and decision readiness

    Question
    What decision will these cases inform, and what observation would change it?
    Evidence
    A written clinical objective, the observations that serve it, a review cadence, and criteria for continuing, pausing or stopping.
    If unresolved
    The program ends with a locked database and an open argument about what comes next.

Figure 1 · Five conditions before the first case

  • Device and preclinical evidence
  • Risk analysis and mitigation
  • Clinical protocol and endpoints
  • Investigator, training and site
  • Safety, data and escalation controls
Convergence

Authorized and controlled first clinical use

Conceptual framework. Readiness requirements depend on the device, purpose, risk profile and jurisdiction.

The engagement

What the First-in-Human Study Review Determines

A structured working review of your device, your evidence and your intended first case, ending in a written position.

  • whether first clinical use is justified at the current development stage;
  • the principal readiness gaps, named;
  • whether a European, US or hybrid model should be assessed;
  • the initial country and investigator profile;
  • the first-case safety and escalation model;
  • the study objective and its staging options;
  • the evidence required for the next development decision;
  • the critical path and the preliminary budget drivers.

Terminology

First-in-Human, FDA EFS and EU Clinical Investigation Are Not the Same Thing

A first-in-human medical-device study involves the first clinical use or exposure of the investigational device, or of the relevant new device configuration, in human participants. Because the term is used differently across programs, state precisely what is first: the device, configuration, indication, procedure or intended use. A new indication or minor design modification is not automatically first-in-human.

FIH describes a development stage rather than a standalone regulatory category. The label alone does not determine the applicable regulatory route, risk classification, sample size, oversight model or submission procedure.

First-in-human
A development stage: the first clinical use or exposure of the investigational device, or of the relevant new device configuration, in human participants.
FDA Early Feasibility Study
A limited clinical investigation of a device early in development. It typically enrolls a small number of subjects to evaluate the device design concept for initial clinical safety and device functionality; the findings may guide device modifications. FDA's EFS guidance addresses the development and review of IDE applications for early feasibility studies of significant-risk devices, including certain first-in-human studies.
EU clinical investigation
The applicable European legal framework, under Regulation (EU) 2017/745 together with the relevant national requirements.

FIH and FDA EFS are not synonyms. An EFS does not necessarily involve the first clinical use of the device, and a first-in-human study is not automatically an FDA EFS. A European clinical investigation should not be described as an FDA Early Feasibility Study conducted in Europe, and is not a European equivalent of the EFS Program.

Location

When Europe May Be Appropriate for First Clinical Use

Europe is a clinical and operational choice. It is right when the investigators, population, pathway and infrastructure match the device, and when the observations will carry weight in the next global development decision.

Europe may be appropriate when

  • relevant investigators and sites are available;
  • the target population is accessible;
  • clinical practice is applicable to the intended use;
  • the sponsor also has a European development objective;
  • the imaging, procedural and rescue infrastructure exists;
  • the first clinical observations can support the next global decision.

Europe may not be the right choice when

  • the population or clinical practice is materially US-specific;
  • essential preclinical or manufacturing evidence remains incomplete;
  • device logistics or rescue support are not defensible;
  • the sponsor expects Europe automatically to replace a US IDE study;
  • the motivation is only assumed speed or cost.

Europe is not selected as a regulatory shortcut. A location that produces first cases nobody can interpret is not a fast route to the next stage. It is a route that has to be run twice.

Selection

Select the Country, Investigator and Site as One Evidence System

These are not three procurement decisions in sequence. The country sets the legal and ethics route, the site sets what can be measured and rescued, and the investigator sits inside the result. Choose them together, or one undoes the others.

Figure 2 · European FIH country and site selection framework

Layer 01

Clinical fit

  • Procedure performed routinely, at volume
  • Protocol-eligible population reachable
  • Care pathway matches intended use
  • Imaging and rescue capability present
Layer 02

Regulatory and ethics route

  • Applicable framework for this device status
  • Current national submission requirements
  • Ethics review model and documentation
  • Safety reporting arrangements defined
Layer 03

Operational feasibility

  • Contracting, insurance and indemnity
  • Importation, storage and accountability
  • Research-team capacity and proctoring
  • Follow-up capacity and retention

Gate. A country is carried forward only when all three layers hold.

Conceptual framework. Requirements and site capability differ by jurisdiction, device and investigation type.
Decision factors applied to each candidate country and site.
Decision factorWhy it matters for FIHEvidence required
Investigator expertiseFirst cases may be dominated by operator experience.Procedure volume, training and relevant clinical experience.
Patient populationEarly observations must address the intended clinical question.Protocol eligibility and site-level availability.
Site infrastructureRescue, imaging and procedural support may be safety-critical.Facilities, team, equipment and escalation pathways.
Submission pathwayRequirements vary by jurisdiction and investigation type.Current regulatory and ethics assessment.
Device logisticsFirst-use devices require strict traceability and control.Importation, storage, accountability and returns.
Follow-up and data qualityEarly safety and functionality may require intensive follow-up.Visit capacity, retention plan and source documentation.

Figure 3 · Investigator expertise without investigator bias

Procedural relevance

Technique, case selection and complication management in comparable procedures.

Protocol discipline

The procedure performed in accordance with the approved protocol and applicable study instructions, with deviations recorded.

Outcome

Interpretable first-case evidence

Participant-centered safety judgment

Participant rights, safety and well-being take priority over program timelines or commercial milestones.

Documentation quality

Contemporaneous, specific and complete records.

Site capability

Training, rescue, imaging and follow-up matched to the endpoints.

Conceptual framework. It does not score, rank or rate individual investigators.

Reputation, enthusiasm and availability may be relevant, but they do not replace procedural relevance, protocol discipline, independent safety judgment, documentation quality and site capability. We also do not publish approval timelines by country, and no country is universally fastest: review practice differs by jurisdiction, device and investigation type, and timing is assessed per device.

Design and control

Design the Study Around Decisions, and Treat Every Case as a Controlled Cycle

A first-in-human protocol earns its length by what it controls, not by what it collects. The design starts from the decision the sponsor must make next and works back to the smallest set of observations that can support it. Each early case then runs as a cycle: it opens with a readiness confirmation and closes with a written decision.

What the study observes

  • the clinical objective, as a decision;
  • initial clinical safety in the intended population;
  • device functionality in the clinical environment;
  • procedural feasibility and device handling;

How the study stays controlled

  • stopping and pausing rules written before the first case;
  • staged enrollment, with sentinel cases where risk justifies;
  • device deficiency and protocol deviation capture;
  • a predefined modification pathway with its approval route;
  • procedure and device-version traceability across cases.

What it is not for

  • establishing definitive clinical effectiveness;
  • supporting comparative claims against other devices;
  • being assumed to replace later confirmatory or pivotal evidence that may be required for the intended regulatory and clinical claims.

Figure 4 · Controlled first-case learning cycle

  1. 1

    Pre-case readiness confirmation

    Device status, eligibility, informed-consent completion, study-team readiness, training, imaging, rescue capability and required documentation are confirmed before enrollment and before the investigational procedure begins.

  2. 2

    Procedure and device use

    The procedure performed in accordance with the approved protocol and applicable study instructions, with handling, sequence and difficulty captured as they occur.

  3. 3

    Immediate safety and functionality review

    Peri-procedural safety and device performance reviewed by the medical monitor within a defined window.

  4. 4

    Device, procedure and data review

    Clinical, engineering and data review of what the case showed, including deficiencies and deviations.

  5. 5

    Documented decision

    Continue, modify, pause or stop, recorded with the reasoning and the evidence behind it.

  6. 6

    Documented release of the next case or cohort

    The sponsor and designated study-governance functions document whether the protocol-defined conditions for proceeding have been met. If a proposed device, protocol, procedure or risk-control change requires regulatory or ethics submission, notification, authorization or approval, that requirement is completed before the change is implemented and, where required, before enrollment continues.

  • Continue under the existing approved protocol
  • Controlled operational clarification
  • Protocol deviation management
  • Non-substantial modification
  • Substantial change requiring submission or authorization
  • Pause or stop pending additional evidence
Conceptual governance model. Requirements for modifications depend on the jurisdiction, the authorization and the change.

On sample size. There is no standard number. Participant numbers, number of sites, staging and review intervals depend on the clinical objective, device maturity, risk profile, endpoints, participant population and the decision the study must support. ISO 14155:2026 informs the design, conduct, recording and reporting of medical-device clinical investigations, but it does not prescribe a standard first-in-human sample size or independently determine the applicable regulatory route.

Safety

First Clinical Use Requires Defined Escalation Before the First Participant

Escalation designed after the first problem is not escalation. Three things are settled beforehand, in writing.

Adverse events, responsibilities and reporting

  • adverse event and device deficiency definitions agreed in advance;
  • medical-monitoring responsibilities, named and reachable;
  • reporting pathways and the timelines that apply;
  • the investigator escalation route, and where sponsor authority sits.

Review, pause, stop and escalate

  • engineering involvement when device performance is implicated;
  • pausing and stopping criteria defined before enrollment;
  • a required review step before the next case proceeds;
  • independent oversight where the risk profile justifies it.

Documentation and conditions to proceed

  • the adverse event or device deficiency, the assessment and the decision, recorded;
  • communication to sites and, where required, to authorities and ethics committees;
  • traceability between the finding, any change made and the cases that follow.

Not every first-in-human study requires a DSMB or CEC. Independent oversight should be determined from the risk profile, population, endpoints and study design, and justified in the protocol rather than assumed.

Delivery

From FIH Readiness Through the Next Development Decision

One program governance across four phases, integrating clinical operations, regulatory submissions, data management, biostatistics, medical oversight and decision reporting.

  1. Phase 1

    Readiness and route

    We assess the evidence, clinical rationale and residual risk, then build the country and investigator model.

    Addresses: whether first clinical use is justified, and where.

    You receive: a readiness position, the named gaps, and a route recommendation.

  2. Phase 2

    Design, submissions and study authorization

    We write the protocol, endpoints, statistical approach and escalation framework, then run regulatory and ethics submissions through each country's own national process. Requirements vary by country and device, and there is no single uniform European approval.

    Addresses: whether the study can be authorized in each chosen country and executed as designed.

    You receive: the authorizations obtained, and sites activated against contracts, documentation, training and local readiness.

  3. Phase 3

    First-case execution

    We run training and proctoring, activation, pre-case readiness confirmation, monitoring and data review between cases.

    Addresses: whether each case is controlled enough to be interpretable.

    You receive: documented decisions between cases, with device accountability throughout.

  4. Phase 4

    Decision package

    We consolidate clinical, device and operational findings with their limitations and residual uncertainty stated.

    Addresses: what the first cases actually support.

    You receive: a recommendation for feasibility, pivotal or further development, with planning assumptions for the next stage.

The endpoint of the engagement is not database lock alone. It is a documented decision on what should happen next.

Experience

Relevant Multicountry European Delivery Experience

The disciplines that make first cases interpretable are the ones that hold a multicountry European investigation together.

Figure 5 · One protocol across three national environments

  • Country ASites, ethics route, contracting
  • Country BSites, ethics route, contracting
  • Country CSites, ethics route, contracting
  • One protocol and one set of study instructions
  • One monitoring and data standard
  • One analyzable dataset
Original schematic. No device geometry, site identity or study result is shown.
Pre-market clinical investigation · Completed

Coloplast A/S · CP348, a multicountry European investigation of an investigational intermittent catheter

A randomized, open-label, crossover pre-market clinical investigation of an investigational compact female hydrophilic intermittent catheter against CE-marked comparators, run across Denmark, France and the United Kingdom with home-use periods and structured follow-up.

Protocol
CP348
Countries
Three European countries
Planned participants
72
Study visits
Four, with two home-use periods

Eclevar contribution

  • clinical evidence architecture for a comparative crossover design;
  • European multicountry delivery across three national environments;
  • investigator and site coordination under a single protocol;
  • endpoint feasibility and device-use documentation in a home-use setting;
  • statistical methodology and analysis planning.

Disciplines relevant to early clinical delivery

  • protocol-to-operation traceability and endpoint feasibility;
  • multicountry coordination and consistent assessments;
  • controlled device logistics and accountability;
  • clinical data architecture and statistical planning;
  • documentation quality that survives later scrutiny.

Public registration: NCT05814211.

This was a European pre-market clinical investigation, not a first-in-human study or an FDA Early Feasibility Study. It is presented as evidence of transferable multicountry delivery disciplines, not FDA acceptance or sponsor endorsement. No clinical outcomes are presented, and the contribution described is limited to Eclevar's contracted scope.

Accountability

The Cross-Functional Team Behind the First-Case Strategy

Not every person shown is assigned to every program, and advisory input does not replace the sponsor's or investigator's regulatory and clinical responsibilities. The final engagement team and individual responsibilities are confirmed for each program according to the device, therapeutic area, countries, study design and contracted scope.

  • Dr Mark Da Costa

    Chief Operating Officer and Head of Cardiovascular

    Mark leads cardiovascular clinical strategy, combining 25 years of Consultant Cardiac Surgery experience with first-hand senior leadership Notified Body experience.

  • Dr. Nikhil Khadabadi

    Chief Medical Officer, Orthopedics and Spine

    Contributes orthopedic and spine expertise to operator learning, procedure definition and investigator qualification, with Notified Body experience.

  • Dawn Heimer, PhD

    Strategic Clinical Advisor, US Clinical Operations

    Dawn provides strategic input on US clinical operations, helping test whether the proposed European operating model is practical for a US sponsor and remains connected to US site, sponsor and delivery expectations. She works with Eclevar's central clinical, medical, data and project leadership as an external strategic advisor.

  • Susanne Höfer

    Head of Clinical Operations, DACH Region

    May lead country, site and first-case delivery: site qualification against the procedure, activation sequence, monitoring around early cases, and readiness confirmation.

  • Sébastien Meier Piantanida

    Chief Data Officer

    Provides input on data management and biostatistics: capture designed so early observations are analyzable, a review cadence fast enough to inform the next case, and analysis suited to small datasets.

  • Charline Petitdemange

    Project Delivery Lead, France and United Kingdom

    Supports program delivery across the four phases: plan, dependencies, escalation between cases, and a single point of contact.

Meet the full Eclevar executive team

Next step

Start With a First-in-Human Study Review

The engagement in full: what you send, and what you get back.

What the sponsor provides

  • device and intended use;
  • development stage;
  • preclinical evidence;
  • risk-management position;
  • proposed population and procedure;
  • candidate endpoints;
  • authority interactions to date;
  • target first-case date.

What Eclevar provides

  • a readiness position;
  • the principal gaps;
  • route options;
  • a country and investigator model;
  • the study objective;
  • a safety and escalation framework;
  • operational assumptions;
  • next-stage decision criteria;
  • critical-path and budget drivers.

The review is advisory. It does not produce a regulatory authorization and does not commit any authority or ethics committee to a position.

Official content

Our content, signed by Eclevar

Whitepapers, client voices and publications produced by our own teams and by our partners: BSI, TÜV SÜD and RegenLab.

Cover of the whitepaper written by BSI and Eclevar on the EU MDR

Whitepaper · BSI x Eclevar

A whitepaper by BSI and Eclevar on the EU MDR

Written with the notified body BSI: a practical look at what clinical evidence has to show under EU MDR 2017/745, and at the quality bar the data have to clear. It is the same bar a European dataset meets before it is put in front of any reviewer.

Read the whitepaper

PMCF studies · Regenerative medicine · 5 EU countries

A client voice on Eclevar's ability to run complex studies

Eclevar runs RegenLab's PMCF program on chronic wound products. It is a randomized study of 160 subjects across 14 centers in 5 EU countries, covering both diabetic foot ulcer and venous leg ulcer. The partnership combines Eclevar's ISO 14155 expertise with the Milo Studio platform, from study design through to the final study report.

« Eclevar, with its tailored approach and the advanced Milo Studio platform, represents a significant strategic advantage. »Antoine Turzi, CEO, RegenLab
  • 160Subjects · 14 centers
  • 5EU countries

Watch the testimonial

RegenLab video testimonial on the PMCF program run by Eclevar

Coming soon. Breakthrough Device Technology under the EU MDR, a whitepaper written with TÜV SÜD, co-authored by Dr Nikhil Khadabadi.

FAQ

First-in-Human Studies in Europe: Common Questions

What is a first-in-human medical device study?

A first-in-human medical-device study involves the first clinical use or exposure of the investigational device, or of the relevant new device configuration, in human participants. Because the term may be used differently across development programs, the sponsor should state precisely what is first: the device, configuration, indication, procedure or intended use. A new indication or minor design modification is not automatically first-in-human. FIH describes a development stage rather than a standalone regulatory category.

Can a US medical device company conduct its FIH study in Europe?

Yes. A US medical device company may conduct first clinical use or another clinical investigation in Europe, subject to the applicable European and national requirements. The decision should depend on clinical, regulatory and operational fit, not an assumption that Europe is faster or less demanding.

Which European country is appropriate for an FIH study?

No country is appropriate for all devices. The right country is one where the procedure is performed routinely by suitable investigators, the protocol-eligible population is accessible, the infrastructure supports the procedure and its rescue options, and the submission pathway can be met. We build a country model per program, not a ranking.

How many patients are required?

There is no standard number. Participant numbers, number of sites, staging and review intervals depend on the clinical objective, device maturity, risk profile, endpoints, participant population and the decision the study must support. ISO 14155 and the applicable regulatory requirements inform how the design is justified and controlled; they do not prescribe one standard first-in-human sample size.

Is FIH the same as an FDA Early Feasibility Study?

No. First-in-human describes a development stage. An FDA Early Feasibility Study is a limited clinical investigation of a device early in development, typically involving a small number of subjects to evaluate the device design concept with respect to initial clinical safety and device functionality; its findings may guide device modifications. FDA's EFS guidance addresses IDE applications for early feasibility studies of significant-risk devices, including certain first-in-human studies. An EFS does not necessarily involve the first clinical use of the device, and an FIH study is not automatically an FDA EFS. A European clinical investigation should not be described as an FDA EFS conducted in Europe or as a European equivalent of FDA's EFS Program.

Can European FIH data support a later FDA submission?

Clinical data generated outside the United States can be considered by FDA, subject to its requirements on the acceptance of such data, including conduct standards, participant protection and data quality. Whether a dataset proves useful depends on the design, population and endpoints, so that intention is addressed while the protocol is written.

How are changes managed between early cases?

Through a defined pathway rather than case by case. Every observation is documented contemporaneously, reviewed clinically and technically, and assessed against the risk file and for regulatory and ethics impact before anything changes. Some adjustments are operational refinements within the approved protocol. Others require a formal change and, depending on the jurisdiction, submission, notification or approval before the next case proceeds.

Reforming Clinical Evaluation of Medical Devices in Europe