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Clinical Evidence & Product Safety
Biological evaluation, chemical characterization, toxicology and clinical evaluation built as one line of evidence, aligned with the regulatory strategy from the start.

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In numbers
Sources: European Commission, notified body survey (data to February 2025); Team-NB, survey of European notified bodies, 2025 data; ISO 10993-1:2025.
The evidence chain
Planning the sequence avoids repeated tests and reports that do not talk to each other.
When it is usually needed
For devices in contact with the body, as part of the technical file.
Usually includes
When it is usually needed
When you need to know what the material may release, such as extractables and leachables.
Usually includes
When it is usually needed
When chemical data must be assessed for risk to the patient.
Usually includes
When it is usually needed
To show safety and performance with clinical data, according to class and market.
Usually includes
When it is usually needed
Before notifying or registering, to check ingredients and concentrations in each market.
Usually includes
When it is usually needed
To show the product is safe before placing it on the market.
Usually includes
When it is usually needed
After launch, to follow undesirable effects and formula changes.
Usually includes
In each market
The science is the same. What changes is the format and the level of evidence each market asks for.
Brazil · ANVISA
Medical devices
ANVISA usually asks for the biological evaluation in the technical dossier and for clinical evidence in proportion to the device class and risk.
Cosmetics
For cosmetics, the responsible company keeps the product safety data, and cosmetovigilance follows the post-market.
European Union · EU MDR
Medical devices
The MDR requires a clinical evaluation for every device, updated throughout its life cycle. Biocompatibility is usually assessed with the ISO 10993 series.
Cosmetics
Each cosmetic needs a safety report (CPSR) signed by a qualified safety assessor, kept in the product information file.
United Kingdom · MHRA
Medical devices
The UK follows a similar logic: biological evaluation with the ISO 10993 series and clinical evidence according to class.
Cosmetics
UK rules also require a cosmetic product safety report.
USA · FDA
Medical devices
The FDA has its own guidance on the use of ISO 10993-1, and the need for clinical data depends on the pathway: 510(k), De Novo or PMA.
Cosmetics
MoCRA requires the responsible person to keep substantiation of each cosmetic’s safety.
Canada · Health Canada
Medical devices
Health Canada asks for evidence of safety and effectiveness in proportion to the class, and the ISO 10993 series is usually the reference for biocompatibility.
Cosmetics
The manufacturer is responsible for the cosmetic’s safety and notifies the product to Health Canada.
The exact requirement depends on the product, the class and the route. We confirm it in your assessment.
Two teams, one dossier
The regulatory strategy defines what each market will ask. The safety evidence shows the product meets it. When both teams plan together, every test and every report has a clear destination from the start.
How we work
You follow every step in the Sobel Client Workspace.

Related
Questions, answered
Rules cited on this page: ISO 10993-1:2025 · ISO 10993-17 · ISO 10993-18 · ISO 14971:2019 · EU MDR · Regulation (EC) 1223/2009 · MoCRA
No. Tests are run by qualified labs, chosen by you or recommended by us. Sobel plans the strategy, coordinates the lab and interprets the results.
Not always. In general, a gap assessment shows what can be reused and what needs to be added. We confirm it in your assessment.
It is usually possible to start from a common base and adapt it to the format and level of evidence each authority asks for.
Yes, for medical devices, with literature review and equivalence analysis where applicable, aligned with what each market usually asks.
We support the safety assessment and coordinate the report with a qualified assessor, according to each market’s rules.