NB deficiency response · EU MDR 2017/745 · Ex TÜV SÜD reviewer

Answer the deficiency letter, and close it in one submission.

Facing a Notified Body deficiency letter or a list of major and minor non-conformities on your technical documentation, CER or clinical evidence? Eclevar responds with a structured, root-cause strategy led by a former TÜV SÜD clinical reviewer, built to resolve findings in a single round rather than patch them across many.

Deficiency letters Major & minor non-conformities CER & Article 61(10) Technical documentation 48-hour response capability
Eclevar MedTech regulatory team preparing a Notified Body deficiency response for an EU MDR technical file Platinum Award 2026

Eclevar MedTech and Milo took the Platinum Award at xShare & EUCROF.

Top prize in the xShare x European CRO Federation "EHDS & Clinical Research" Open Call, awarded to Eclevar MedTech and its Milo Health platform, presented at the EUCROF 2026 conference in Amsterdam.

Co-funded by the European Union

Horizon Europe · Grant Agreement No. 101136734 · Amsterdam, 2 Feb 2026

Social proof

Trusted by MedTech manufacturers.

Device leaders rely on Eclevar to get their files through Notified Body review. Read all client success stories.

TERUMO Meril NIHON KOHDEN VYGON Coloplast SHOFU ASAHI INTECC RegenLab TERUMO Meril NIHON KOHDEN VYGON Coloplast SHOFU ASAHI INTECC RegenLab
Dr Mark Da Costa, COO at Eclevar MedTech and former TÜV SÜD Notified Body clinical reviewer
Dr Mark Da Costa COO · Former Head of Clinical Review, TÜV SÜD · Senior Consultant Surgeon Former reviewer at TÜV SÜD
Regulatory leadership

We read the intent behind a finding, not just its wording.

Dr Mark Da Costa, COO and former Head of Clinical Review at TÜV SÜD, leads a team of senior experts who previously assessed device files as Notified Body clinical reviewers. That background lets us respond to what a reviewer actually needs to see, so a deficiency response corrects the underlying strategy across the CER, CEP, IFU and Risk Management File rather than patching one document at a time. The result is a defensible, harmonized submission built to close findings in a single round.

Ex NBFormer Head of Clinical Review, TÜV SÜD
48hResponse capability when a round is pending
Art. 61(10)CER repositioning & clinical evidence route
Former NB reviewer CER & PMCF ISO 14155:2026
LinkedIn
Aligned with EU MDR 2017/745 ISO 14155:2026 ISO 13485 MDCG guidance GSPR mapping
What we do

Three ways we resolve Notified Body findings.

From the first deficiency letter to a meeting with your reviewer, we bring former Notified Body experience to the response. It sits alongside your EU MDR regulatory strategy and your MDR technical documentation review.

Service 01

Deficiency response consulting

Root-cause analysis of your deficiency letter, then a full response strategy designed to close major and minor non-conformities in one submission rather than across repeated rounds.

Service 02

CER deficiency resolution

Targeted support for Clinical Evaluation Report findings under Article 61(10): state of the art, benefit-risk analysis and PMCF gaps, harmonized with the CEP and IFU.

Service 03

Expert at NB meetings

A former Notified Body reviewer joins your clarification calls and formal meetings to translate the findings and defend the file in real time, next to your team.

Engagement

Flexible, no retainer

Work with us at £250 per hour, with no retainer and no minimum project size. You set the scope and duration, whether that is a single deficiency letter, a full CER rebuild or an expert on a call. Underpinned by our ISO 13485 quality management system.

Why files stall

Each round of patching creates the next deficiency.

Incremental edits that address only the literal wording of a finding leave the underlying strategic flaw in place. Because the technical documentation is interrelated, one fix creates the next inconsistency. We break that cycle.

The patching trap

Editorial fixes, strategic flaws

  • A reworded CER paragraph contradicts the Clinical Evaluation Plan
  • An IFU change no longer matches the Risk Management File
  • GSPR mapping drifts out of line with the clinical evidence
  • The reviewer opens a new finding where the last one was closed
The Eclevar response

Fix the strategy, then the file

  • Root-cause analysis of open and at-risk findings first
  • Reposition the clinical evidence route before any rewriting
  • Harmonise the CER, CEP, IFU, Risk Management File and GSPR together
  • Build one defensible response pack, supported by real-world evidence and PMCF where needed
How we work

From deficiency letter to closed finding, in five steps.

1

Root-cause analysis

Read the open and at-risk findings to their intent, not just their wording.

2

Reposition strategy

Correct the conformity or clinical evidence route before any document is rewritten.

3

Harmonise documents

Align the CER, CEP, IFU, Risk Management File and GSPR mapping as one file.

4

Response pack

Assemble a defensible submission designed to close findings in a single round.

5

Defend the file

Join the Notified Body call or meeting to explain and support the response.

On the ground

Studies and monitoring, if the response needs new evidence

Where closing a finding means generating fresh clinical data, our clinical monitoring team and operational infrastructure run the PMCF or study behind the response, so the evidence and the paperwork stay in step.

FAQ

Deficiency questions manufacturers ask us.

How many assessment rounds does a Notified Body allow?

Notified Bodies permit a finite number of assessment rounds, commonly up to four depending on the Notified Body's procedures. Once the rounds are exhausted, unresolved deficiencies can lead to a negative decision, so each response needs to close findings rather than defer them.

Why does patching a deficiency letter often create new findings?

Incremental edits that address only the literal wording of a finding leave the underlying strategic flaw in place. Because the technical documentation is interrelated, a change to the CER can create a new inconsistency in the Clinical Evaluation Plan, IFU or Risk Management File. Eclevar starts from root-cause analysis so the whole file is harmonized in one response.

What happens after several unsuccessful assessment rounds?

After multiple unsuccessful rounds the root cause is usually strategic rather than editorial. That means repositioning the conformity or clinical evidence route, for example moving to Article 61(10), rather than making further incremental edits to the existing documents.

Can a former Notified Body reviewer attend our meetings with the Notified Body?

Yes. Former Notified Body reviewers can join clarification calls and formal Notified Body meetings to translate findings, explain the intent behind them and defend the file in real time alongside your team.

How fast can Eclevar turn around a deficiency response?

When an assessment round is pending, Eclevar can work to a 48-hour response capability so you meet Notified Body deadlines without rushing the underlying strategy.

What does resolving a CER deficiency involve?

CER deficiency resolution addresses Article 61(10) findings and issues around state of the art, benefit-risk analysis and PMCF gaps, then harmonises the Clinical Evaluation Report with the CEP, IFU, Risk Management File and GSPR mapping so the clinical evidence route holds together.

Guaranteed response within 24 hours

Send us your deficiency letter before the next round.

Talk to a former Notified Body reviewer about your findings, your remaining assessment rounds and how to close them in one structured submission.

Book a free consultation

Reforming Clinical Evaluation of Medical Devices in Europe