Pharma
- What applies
- EU GMP Guidelines (EudraLex Volume 4) set the documentation frame.
Our Technical Writing produces technical documentation for devices, IVDs and medicinal products: instructions for use (IFU), technical dossier per Annex II/III and GMP SOPs. A finding usually arises not from poor wording but because IFU, risk management and clinical evaluation state the same thing differently.
Overview
IFU, technical documentation & SOPs for MedTech, IVD and Pharma · MDR (EU 2017/745), IVDR (EU 2017/746), ISO 15223-1, IEC 62366-1
Last updated: October 3, 2026
The Medical Device Regulation (EU) 2017/745 and the In Vitro Diagnostic Regulation (EU) 2017/746 require technical documentation that is not only complete, but internally free of contradictions.
Industries
Services
SOPs for pharmaceutical manufacturing, quality assurance and validation under the EU GMP Guidelines (EudraLex Volume 4), with consistent terminology and defined version control.
A structured flow of preparation, review, approval, distribution and archiving; event-driven updates to the documentation following product changes, new clinical data or post-market surveillance findings.
Cross-checking existing documents against risk management and clinical evaluation with a documented list of findings. We surface the typical contradictions that lead to notified body deficiency requests.
How we work together
Technical documentation rarely fails on individual sentences; it fails on consistency across multiple documents. The notified body reviews the technical documentation under MDR/IVDR Annex II/III not as a loose collection, but as a coherent argument: the intended purpose must read the same in the device description, the IFU and the clinical evaluation.
Every warning in the instructions for use must trace back to a residual risk from the risk management file per ISO 14971:2019. And the critical use scenarios from usability engineering per IEC 62366-1:2015 must be reflected in the instructions.
If any one of these documents contradicts the others, the finding is inevitable, regardless of how well the individual text is written.
This is why the sequence matters: the IFU can only be written reliably once risk management and usability engineering have delivered the residual risks and use errors; if symbols and labeling are not built per EN ISO 15223-1:2021 and MDR Annex I Chapter III from the start, rework follows.
Source reconciliation comes before the first sentence is written, and at the end we check all documents against one another in the consistency review. An inconsistency that goes unnoticed here becomes a deficiency request in the audit and delays market access.
It does not save documents, but it does save the expensive loops at the end of the project.
Our approach
Step
Result
Inventory & source reconciliation
An overview of the existing documents and their sources (risk management file, CER, specifications), with gaps and contradictions flagged.
Document architecture
A defined structure and terminology that aligns with MDR/IVDR Annex II/III and defines the cross-references between documents.
Preparation & derivation
Technical documentation and IFU, with warnings traceably derived from risk management and usability engineering.
Consistency review
Verified alignment between the IFU, the risk management file and the clinical evaluation; documented list of findings resolved.
Languages & approval
IFU in the official languages of the target markets, approved and placed under version control.
Common pitfalls
The IFU, the risk management file and the clinical evaluation are written separately and never checked against one another.
The notified body reads them together: a warning that fails to cover a residual risk from ISO 14971:2019, or an intended purpose that reads differently in the IFU and the CER, is a classic reason for a deficiency request.
The IFU is drafted before usability engineering per IEC 62366-1:2015 is complete.
Yet instructions and warnings can only be formulated reliably once the critical use scenarios and use errors are known; otherwise the IFU has to be rewritten afterwards.
Symbols and labeling are designed freely instead of per EN ISO 15223-1:2021.
Non-compliant or self-invented symbols lead to findings, just as missing mandatory information under MDR Annex I Chapter III does.
The eIFU is used without checking the conditions of EU 2021/2226.
Since the amendment by (EU) 2025/1234, electronic instructions for use are permitted for devices intended for professional users, and only under defined conditions; if used where it is not allowed, the legally compliant paper IFU is missing.
SOPs grow over time and use different terms for the same procedure.
In a GMP inspection under the EU GMP Guidelines, inconsistent terminology stands out and calls into question whether the process is under control.
Regulatory Affairs
In a first call we assess your situation and say what needs clarifying first in your case. Without obligation, reply usually within one working day.
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Latest insights
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Labeling and IFU per EN ISO 15223-1 in detail
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Technical documentation in the overall context of MDR certification
IVD Consulting & IVDR Readiness →
Technical documentation for in-vitro diagnostics under EU 2017/746
Risk Management →
The risk management file per ISO 14971:2019 as the source of IFU warnings
Briefly outline your situation. We'll respond with an initial assessment, usually within one business day.
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info@theentourage.de