How do you create technical documentation that passes the notified body audit?
We write and maintain technical documentation for medical devices, in-vitro diagnostics and medicinal products: from the instructions for use (IFU) and the technical documentation under Annex II/III to GMP SOPs. The sticking point is rarely the language, it is consistency. A notified body finding usually arises not because a document is poorly worded, but because the IFU, the risk management file and the clinical evaluation make the same statement in different ways.
- Pharma
- Biotech
- MedTech
- IVD
Overview
Which documentation requirements arise under MDR and IVDR?
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: 2026-06-12
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. Four points where documentation gets caught in an audit:
- The technical documentation under MDR/IVDR Annex II/III must be consistent throughout: the device description, the risk management per ISO 14971:2019 and the clinical evaluation must not contradict one another.
- The instructions for use (IFU) must meet the requirements of MDR Annex I Chapter III, use standard-compliant symbols per EN ISO 15223-1:2021 and be available in the official languages of the target markets.
- Residual risks from risk management and findings from usability engineering per IEC 62366-1:2015 must be traceably reflected in the IFU as warnings and instructions.
- GMP SOPs under the EU GMP Guidelines (EudraLex Volume 4) require consistent terminology, clear process steps and traceable version control; gaps surface during inspection.
Services
How we support you
Technical documentation under MDR/IVDR
Preparation and review of complete technical documentation under MDR/IVDR Annex II/III, with verified consistency between the device description, the risk management per ISO 14971:2019 and the clinical evaluation.
Learn more →Instructions for use (IFU) & labelling
Standard-compliant IFU per MDR Annex I Chapter III and EN ISO 15223-1:2021, derived from usability engineering per IEC 62366-1:2015, including multilingual IFU packages and eIFU per EU 2021/2226.
Learn more →Regulatory SOPs for GMP & QMS
SOPs for pharmaceutical manufacturing, quality assurance and validation under the EU GMP Guidelines (EudraLex Volume 4), with consistent terminology and defined version control.
Document lifecycle & maintenance
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.
Terminology & consistency review
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
What it comes down to
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 labelling are not built per EN ISO 15223-1:2021 and MDR Annex I Chapter III from the start, rework follows. We start at source reconciliation before the first sentence is written, and at the end we check all documents against one another in the consistency review. This shifts the effort to where corrections are cheap, rather than into the audit, where a deficiency request delays market access. It does not save documents, but it does save the expensive loops at the end of the project.
Our approach
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
Where projects commonly fail
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 labelling 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.
Electronic instructions for use are permitted only for certain devices and 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 the controllability of the process into question.
FAQ
Frequently asked questions
Sources
- Regulation (EU) 2017/745 (MDR): primary text, Annex I Chapter III, Annex II/III
- Regulation (EU) 2017/746 (IVDR): primary text, Annex II/III
- EN ISO 15223-1:2021: symbols to be used with medical device labels
- IEC 62366-1:2015: application of usability engineering to medical devices
- ISO 14971:2019: application of risk management to medical devices
- EU GMP Guidelines (EudraLex Volume 4), Regulation (EU) 2021/2226 (eIFU)
- Writer source file: technical-writing.md (Regulatory & Compliance)
- https://theentourage.de/expertise/technical-writing/ (existing page content, revised)
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Case Studies
What this looks like in practice
Related insights
All insights →Regulations & standards considered
- EU 2017/745 (MDR) Annex II/III (technical documentation)
- MDR Annex I Chapter III (requirements for instructions for use and labelling)
- EU 2017/746 (IVDR) Annex II/III (technical documentation)
- EN ISO 15223-1:2021 (symbols for the labelling of medical devices)
- IEC 62366-1:2015 (usability / usability engineering)
- Regulation (EU) 2021/2226 (electronic instructions for use, eIFU)
- ISO 14971:2019 (risk management for medical devices)
- EU GMP Guidelines (EudraLex Volume 4)
Related topics
Labeling & IFU Creation →
Labelling and IFU per EN ISO 15223-1 in detail
MDR Consulting →
Technical documentation in the overall context of MDR certification
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
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