US Sponsors / European Clinical Delivery

European Medical Device Clinical Trials for US Sponsors

Design and deliver your first-in-human, feasibility, or pivotal study in Europe while keeping the intended FDA evidence pathway in view.

Running medical device clinical trials in Europe is a strategic choice, not a cost decision. Eclevar helps US sponsors determine whether a US-only, Europe-led, or hybrid model answers their clinical and regulatory question, then delivers the European component under one specialist program governance, from strategy and protocol through sites, data, and reporting.

Specialized exclusively in medical device clinical evidence
Clinician-led study strategy
Former Notified Body clinical review experience
European multicountry delivery
Clinical Operations, Data Management, and Biostatistics integrated
30+medical device evidence programs
2,000+participants across delivered programs
MulticountryEuropean clinical delivery
Pre-marketthrough post-market evidence

Experience across cardiovascular, orthopedics, neuromodulation, wound care, and continence care.

The decision before the country

US-Only, Europe-Led, or Hybrid: Choose the Evidence Model First


The question is not whether Europe is less expensive, but which geography and study model can answer the question your program has to close. Eclevar assesses all three options before recommending a delivery model. If Europe does not provide a defensible evidence or operating advantage, the recommendation should say so.

Model 01

US-only

When it may fit
The population, standard of care, or procedural context is materially US-specific, or FDA feedback points to US representation.
Principal benefit
The study is conducted within the intended US clinical context, reducing, but not eliminating, questions about population and practice applicability.
Principal evidence risk
Access to enough qualified sites and eligible patients, and the cost and timeline of building a US site network.
Confirm first
Site-level recruitment assumptions, IRB and contracting timelines, and the IDE strategy.
Model 02

Europe-led

When it may fit
Specialist investigators and procedure volumes exist in Europe, European market access is also in scope, and the population and practice are applicable to the intended US use.
Principal benefit
One investigation can be planned against both an EU MDR conformity assessment need and a defined FDA use.
Principal evidence risk
Differences in standard of care, comparator, or follow-up practice that weaken the applicability argument to US medical practice.
Confirm first
Population and practice applicability, endpoint definitions that hold for each intended use, and whether FDA feedback should come first.
Model 03

Hybrid US and Europe

When it may fit
US representation matters for the pivotal question, but early clinical experience or procedural learning can be resolved in Europe.
Principal benefit
US applicability is addressed directly while European sites carry part of the recruitment and early learning.
Principal evidence risk
Regional differences may introduce heterogeneity or treatment-effect modification that should be anticipated in the design and analysis.
Confirm first
The prespecified pooling and regional-analysis strategy, harmonized training and assessments, and one data standard.

Study model decision architecture

Four shared evidence domains, three candidate models, one decision.

Evidence domain
Model 01US-only
Model 02Europe-led
Model 03Hybrid US and Europe
Population applicabilityAre the patients the ones the submission will be judged on?
Conducted within the intended US clinical context; applicability uncertainty is reduced, not eliminated.
Must be argued: demographics, disease severity, and referral pathway compared to the intended US use.
Partially direct; requires a prespecified regional-analysis strategy.
Clinical practice and standard of careIs the device used the same way, by comparable operators?
Practice setting matches the intended use environment.
Requires comparison of comparator, procedure, adjunctive therapy, and follow-up intervals.
Requires harmonized procedure and training documentation across both regions.
Endpoint alignmentDoes one endpoint definition serve every intended regulatory use?
Endpoints defined against a single review framework.
Endpoints defined once, then checked against each intended regulatory use before lock.
Definitions, windows, and procedures sufficiently harmonized to support the prespecified pooling strategy.
Data quality and regulatory documentationCan the conduct be reconstructed and inspected?
Conducted under the US framework applicable to the investigation.
Good clinical practice, ethics review, consent, monitoring, and source data accessibility documented for the intended use.
Each site complies with its local requirements, with one data standard and one governance chain.
Conceptual framework. The table sets out the questions each model has to answer, not a score: no ranking or numerical comparison between models is implied.

Europe tends to strengthen the program when

  • Relevant specialist investigators and site-level recruitment support the protocol.
  • European market access is also being pursued, so one investigation serves more than one purpose.
  • The study can be designed around an agreed global evidence question.

A US or hybrid model may remain preferable when

  • The intended population, comparator, or standard of care is materially US-specific.
  • FDA feedback indicates meaningful US representation is expected.
  • The procedure or training model cannot be transferred reliably, or US investigator experience is central to adoption.

What the Strategy Review determines

  • US-only, Europe-led, hybrid, or unresolved pending authority feedback
  • Intended use of the European data
  • Population and clinical-practice applicability
  • Initial country and site model
  • Endpoint and protocol risks
  • Regulatory dependencies
  • Critical-path assumptions
  • Preliminary budget drivers

Regulatory use

Design European Data for Its Intended Regulatory Use


FDA may accept clinical data from investigations conducted outside the United States when the applicable requirements are met, including the conditions set out in 21 CFR 812.28 for investigations supporting an IDE or device marketing application. These include well-designed and well-conducted research, good clinical practice, independent ethics committee review, informed consent, supporting documentation, and FDA's ability to validate the data. Separately, the relevance of the population, clinical practice, device configuration, endpoints, and resulting evidence to the intended US use should be assessed for the planned submission.

The limit stated plainly

European clinical data may support an FDA submission when the study is designed, conducted and documented for its intended regulatory use. Final acceptability remains subject to FDA review. Conformity with good clinical practice or with ISO 14155 does not by itself make data acceptable to FDA.

If the European data are intended to support a material FDA decision, the sponsor should assess whether FDA feedback is appropriate before pivotal protocol lock. Early FDA feedback may identify material concerns while the protocol and operating model can still be revised with less disruption. A detailed reading of the requirements is covered in Can European Clinical Data Support an FDA Medical Device Submission?

Evidence architecture

One Evidence Architecture, Jurisdiction-Specific Requirements


The clinical question, population, endpoints, data generation, and analysis may be planned within a shared evidence architecture where the intended regulatory uses are aligned prospectively. Jurisdiction-specific requirements, analyses, documentation, or additional evidence may still be required, and one study does not automatically satisfy both pathways.

One study architecture, two regulatory uses

Five shared layers, two jurisdiction-specific evidence uses.

L1
Clinical questionWhat the program must be able to state at the end, and for whom.
L2
Population and clinical practiceEligibility, disease severity, comparator, and setting of use.
L3
Endpoints and assessmentsDefinitions, assessment windows, imaging, and adjudication rules.
L4
Data generation and quality controlsSource data, monitoring, training, device deficiency and safety reporting.
L5
Analysis and reportingAnalysis populations, statistical methods, and the clinical investigation report.

FDA-specific requirements

  • Good clinical practice statement and supporting information under 21 CFR 812.28
  • Submission-specific relevance to the intended US use, population, and clinical practice
  • Data validation through inspection or other appropriate means

EU MDR-specific requirements

  • Clinical investigation requirements of Regulation (EU) 2017/745
  • Ethics committee and competent authority requirements per member state
  • Clinical evaluation, benefit-risk, and continuity into post-market follow-up
Conceptual framework. Study requirements depend on the device, intended use, regulatory pathway, and authority feedback. A shared clinical foundation does not mean the two frameworks impose the same requirements, and one study will not always satisfy both. For a PMA relying solely on foreign clinical data, 21 CFR 814.15 includes the specific requirement that the data be applicable to the US population and US medical practice; this specific formulation should not be generalized as an identical statutory test for every FDA submission pathway.

Delivery

European Clinical Delivery From Strategy Through Reporting


Four workstreams under one program governance.

Workstream 01

Strategy and protocol

We start from the claim your program has to support and work backward to the study that can support it, including the choice of model and the intended regulatory uses of the dataset.

  • Study route assessment
  • Evidence strategy
  • Protocol or synopsis
  • Endpoint and analysis framework
Uncertainty addressed
Whether the study being contemplated can answer the question, and which design choices are load bearing.
Sponsor outcome
A recommended model and a protocol built for the intended uses of the data.
Workstream 02

Countries, sites, and start-up

Eclevar manages the European regulatory and ethics submission workstream under one program governance, using verified local processes and support where required.

  • Country and site feasibility
  • Regulatory and ethics submissions
  • Contracting and activation
  • Investigator and procedural training
Uncertainty addressed
Whether the recruitment assumption survives contact with real sites, and how long approvals take.
Sponsor outcome
A country and site model with site-level feasibility responses and a documented training standard.
Workstream 03

Clinical operations and safety

Monitoring is planned around the data that carry the primary question, combining on-site and remote work with centralized review. Safety and device deficiency handling runs as a defined process with traceable timelines, under one accountable team.

  • On-site and remote monitoring
  • Site management
  • Safety and device deficiency oversight
Uncertainty addressed
Whether the data will hold up to source verification and regulatory scrutiny of the conduct.
Sponsor outcome
A monitoring plan with documented safety reporting.
Workstream 04

Data, statistics, and reporting

The people who build the database work inside the same program governance as the teams running the sites. Statistical methods are agreed before lock, and the report is written by the team that followed the program.

  • EDC and clinical data management
  • Biostatistics and interim review
  • Clinical investigation report
  • Pivotal or post-market transition
Uncertainty addressed
Whether the analysis answers the prespecified question, and what the result licenses you to do next.
Sponsor outcome
A validated database, the statistical outputs, and the clinical investigation report.

Related capabilities: feasibility and site selection, study start-up, clinical monitoring, clinical data management, and regulatory affairs and strategy.

Country strategy

Select Countries for the Device, Not for a Generic European Footprint


Eclevar builds the country and site model from the indication, procedure, protocol-eligible population, investigator capability, standard of care, infrastructure, and intended evidence use. The output is a small set of countries and named sites with a documented recruitment basis. No approval timeline is published here: timelines depend on the country, the classification, and the dossier.

Country and site selection framework

01
Evidence questionClaim, population, endpoint, and intended regulatory uses.
02
Country screenPopulation, procedure volume, investigator caseload, standard of care, infrastructure, submission route, follow-up burden, device logistics.
03
Site-level feasibilityNamed sites, named investigators, documented recruitment basis.
04
Country and site setThe smallest set that answers the question on a defensible timeline.
Conceptual framework. Countries are an output of this sequence, not an input. Applying the screen to a specific device is covered in How to Select a European Country for a Medical Device Clinical Investigation.

Proof

Relevant Multicountry European Delivery Experience


Coloplast Pre-market clinical investigation, completed

Coloplast A/S, investigation CP348

Coloplast A/S sponsored a pre-market clinical investigation of an investigational compact intermittent catheter for female users. The question: whether the device could be assessed against CE-marked comparators under real conditions of use, including home use, with objective and participant-reported measures collected consistently across countries.

Crossover investigation architecture across four visits Two randomized sequences are shown across four visits. Sequence one uses the investigational device in the first home-use period and the comparator in the second. Sequence two reverses the order. The two home-use periods each last two weeks. This is a generic schematic of the registered design, not a rendering of any commercial device. Visit 1Visit 2 Visit 3Visit 4 Sequence A Sequence B Investigational 2-week home use Comparator 2-week home use Comparator 2-week home use Investigational 2-week home use Assessments and participant-reported outcomes Randomized sequence allocation at Visit 1
Generic schematic of the registered crossover design. Original illustration; it does not depict the geometry of any commercial device.
3countries: Denmark, France, the United Kingdom
72participants planned per the public registration
4visits per participant
2home-use periods of two weeks

Study architecture and operational demands

A multicenter, randomized, open-label, crossover design, publicly registered as NCT05814211. Sequence, timing, and assessment windows had to be identical at every site across three countries with different submission and contracting routes, with part of the data generated at home and participant burden treated as a design constraint.

Eclevar's contribution covered clinical evidence architecture, European delivery, and statistical methodology, within the scope contracted by the sponsor and alongside the sponsor's own responsibilities.

Why this is relevant to a US sponsor

  • Multicountry coordination: the discipline is the same whether the dataset serves one jurisdiction or two.
  • Endpoint feasibility: an endpoint sites cannot assess identically will not survive review anywhere.
  • Participant and site burden: the main determinant of whether a European recruitment assumption holds.
  • Procedural consistency and data quality: the conditions on which applicability arguments later depend.

This was a European pre-market clinical investigation, not a US sponsor program or an FDA Early Feasibility Study. It is presented to demonstrate relevant multicountry European delivery capability, not FDA acceptance or sponsor endorsement. Study facts are taken from the public registration; outcomes and comparator identities are not published here.

Accountability

The Team Behind the European Study Decision


Therapeutic authority sits with the people responsible for delivery. Our physician leadership includes former Notified Body clinical reviewers. Therapeutic practices: cardiovascular and structural heart, orthopedics and spine, neuromodulation and neuro-implants, advanced wound care.

Cardiovascular and structural heart

Dr Mark Da Costa

Chief Operating Officer and Head of Cardiovascular, Senior Consultant Surgeon

Mark leads cardiovascular clinical strategy, combining 25 years of Consultant Cardiac Surgery experience with first-hand senior leadership Notified Body experience. On this pathway he tests whether the proposed model, population, and endpoints will withstand clinical and regulatory scrutiny, including procedural learning, imaging, and event adjudication in structural heart programs.

Orthopedics, spine, and surgical robotics

Dr. Nikhil Khadabadi

Chief Medical Officer, Orthopedics and Spine

Orthopedic surgeon and former Notified Body senior reviewer. He works on programs where operator learning, investigator qualification, and implant, imaging, and procedural evidence determine the study design, and on how those factors are handled when sites sit in more than one country.

US clinical-operations perspective

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.

European clinical delivery

Susanne Höfer with Charline Petitdemange

Head of Clinical Operations, DACH region · Project Delivery Lead, France and United Kingdom

Susanne assesses whether the proposed site model is deliverable and what it takes at site level. Charline owns program accountability: submissions, activation, contracting, and the day-to-day operation that turns an agreed model into open sites and enrolled participants.

Data, statistics, protocol, and reporting

Sébastien Meier Piantanida with Pierre-Marie Boutanquoi

Chief Data Officer · Head of Medical Writing

Sébastien defines the data standard and the analysis approach that has to hold across regions and survive scrutiny of the conduct. Pierre-Marie leads protocol and clinical investigation report writing, drafted by the team that followed the study.

The next step

Start With a US-Europe Study Strategy Review


Resolve the highest-impact assumptions before the pivotal budget is committed.

Uncertainty and cost of change across the program

Illustrative only. No units, and not derived from a clinical or financial dataset.

Conceptual curves of design uncertainty and cost of change across six program stages Two conceptual lines are drawn over six stages: initial development assumptions, first clinical use, feasibility learning, pivotal design lock, pivotal execution and post-market evidence. The first line, design uncertainty, falls steeply between first clinical use and pivotal design lock and then flattens above the baseline, showing that residual uncertainty remains. The second line, cost of changing the design, rises gradually and then steeply after pivotal design lock. The two lines cross between feasibility learning and pivotal design lock, marked as the decision window. No axis values, units or measured data are shown. Higher Lower Decision window Initialdevelopmentassumptions Firstclinical use Feasibilitylearning Pivotaldesign lock Pivotalexecution Post-marketevidence Residual uncertainty remains after every stage.
Design uncertainty Cost of changing the design Decision window: a period in which changes may still be made with less disruption than after activation or enrollment.
Illustrative only. No units, and not derived from a clinical or financial dataset.

What you bring

  • Device and intended use
  • Development stage
  • Existing preclinical and clinical evidence
  • Target population and proposed endpoints
  • FDA interactions to date
  • European objectives
  • Country or investigator preferences
  • Target timeline
  • The principal evidence decision

No confidential documentation is required to start.

What the decision package contains

  • Recommended study model
  • Evidence-use map
  • Population and practice risks
  • Country and site model
  • Endpoint and protocol risks
  • Regulatory dependencies
  • Preliminary critical path
  • Budget drivers and range
  • Questions requiring authority feedback
  • Recommended next-step scope

An informed recommendation, not a regulatory conclusion.

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.

Questions we are asked first

Medical Device Clinical Trials in Europe: Common Questions


Can European clinical data support an FDA medical device submission?

FDA may accept data from clinical investigations conducted outside the United States when the investigation is well designed and well conducted and the conditions in 21 CFR 812.28 are met, including conduct in accordance with good clinical practice and provision of the supporting information the regulation describes. Acceptability of any specific dataset remains subject to FDA review.

Can a US medical device company conduct an FIH or pivotal 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. If the data are later intended to support an FDA submission, the applicable FDA requirements should shape the design and documentation from the start rather than be reconstructed afterward.

When is a hybrid US and European study appropriate?

Typically when US representation matters for the question, but part of the recruitment or early clinical experience can be resolved in Europe. Regional differences may introduce heterogeneity or treatment-effect modification that should be anticipated in the design and analysis, so the pooling strategy, harmonized procedures, and a single data standard are defined before enrollment.

How should European countries and sites be selected?

From the protocol. Population and severity mix, procedure volume, investigator caseload, standard of care, infrastructure, submission route, follow-up burden, and device logistics vary by country and indication. The credible output is a small set of countries and named sites with a documented recruitment basis.

Can one study support FDA and EU MDR evidence objectives?

Sometimes, and it should be assessed rather than assumed. The clinical question, population, endpoints, data generation, and analysis may be planned within a shared evidence architecture where the intended regulatory uses are aligned prospectively. Jurisdiction-specific requirements, analyses, documentation, or additional evidence may still be required, and one study does not automatically satisfy both pathways.

What does Eclevar manage?

Study route assessment, evidence strategy and protocol, country and site feasibility, the European regulatory and ethics submission workstream, contracting and activation, investigator training, monitoring, safety and device deficiency oversight, clinical data management, biostatistics, and the clinical investigation report, under one program governance.

Medical device clinical trials in Europe, planned around your regulatory pathway

The next conversation is about your device, your intended use, and the decision you are trying to close.

Reforming Clinical Evaluation of Medical Devices in Europe