Briefing note

What you can upload as a requirement

Public binding texts are on us. What you add here is what is yours alone: your procedures, your charters, the standards you hold a licence for. That pile is what turns a generic review into yours.

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01 Before you upload

Requirement or evidence? The question settles in one sentence.

This is the only thing to understand before you start. The two piles do not serve the same check, and a document filed on the wrong side will not be used the way you expect.

The requirements pile

What your document is allowed to say.

Regulations, standards, procedures, charters, internal rules. Everything that judges the wording, regardless of what it claims.

The evidence pile

What your document has grounds to say.

Publications, evaluation reports, internal data. Everything that supports a specific claim, figure by figure.

The case that catches everyone out

Some documents are both. The SmPC is the textbook example.

It is binding and promotional material must comply with it: that makes it a requirement. It carries the tolerability and posology data: that makes it evidence too. Upload it on both sides. The same goes for an approved leaflet, a clinical evaluation report or a health technology assessment opinion.

02 Who brings what

Three kinds of requirement, three origins.

We do not claim to know everything, and we are not allowed to distribute everything. The split is simple.

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Public binding texts

Regulations, codes, authority doctrine. They are modelled by our regulatory team, with a published scope. You have nothing to upload.

Today: MDR and ANSM doctrine. Planned: FDA 21 CFR Part 11, ISO 13485, EMA, ICH, IVDR.

For you to provide

Licensed standards

ISO, EN and IEC standards are not freely distributable. We are not allowed to supply them to you. You, on the other hand, have bought your copy.

First check that your licence permits upload to a hosted tool. Failing that, upload the internal procedure that implements it: it belongs to you, and it is often the one that counts.

For you to provide

Your internal frameworks

By definition, only you have them. This is the most useful pile and the least often uploaded: it encodes your doctrine, the one written down nowhere else.

Today our team sets them up for your account. Self-service upload from your own interface is coming.

03 By sector

What other teams upload.

An indicative list, not an exhaustive one. The set that actually applies depends on the exact status of your product and on the target market, which is precisely the first thing to establish. If a document looks borderline to you, send it over and we will tell you whether it is usable.

Your internal frameworks

All sectors · the pile that makes the difference

  • Promotional review charter or approval procedure

    Who approves what, in which order, against which criteria.

    To provide
  • Labelling and leaflet management procedure

    In-house mandatory mentions, order of blocks, required formats.

    To provide
  • Internal medical information rules

    What a field response may state, and in what form.

    To provide
  • Matrix of approved claims, and of prohibited ones

    The document that prevents the most arguments.

    To provide
  • Glossary and mandated terminology

    Denominations, abbreviations, units, how values are written.

    To provide
  • Editorial charter and brand guidelines

    Feeds the form axis: structure, headings, typography, footer mentions.

    To provide
  • Mandatory templates and models

    The skeleton expected for each document type.

    To provide
  • Commitments made to an authority or a notified body

    The corrections promised after an audit or an inspection finding.

    To provide

Medical devices

Manufacturers · authorised representatives · QARA

  • Regulation (EU) 2017/745, MDR

    Scope covered: technical file (annexes II and III), leaflet, labelling and UDI traceability, clinician materials.

    Active
  • Regulation (EU) 2017/746, IVDR

    In vitro diagnostics, complementary to the MDR.

    Planned
  • ISO 13485, quality management system

    Document control, review and approval.

    Planned
  • ISO 14971, risk management

    Consistency between the risks identified and what the leaflet says about them.

    To provide
  • ISO 15223-1, symbols to be used with information supplied

    The most mechanical check, and the one most often caught out.

    To provide
  • ISO 20417, information to be supplied by the manufacturer

    Minimum content of labelling and of the leaflet.

    To provide
  • IEC 62366-1, usability engineering

    Legibility and comprehension of the instructions by the intended user.

    To provide
  • EN ISO 14155, clinical investigation

    For protocols and investigator brochures.

    To provide
  • MDCG guidance applicable to your class

    Public documents, to be pinned to the version that concerns you.

    To provide
  • MedTech Europe Code of Ethical Business Practice

    For materials aimed at healthcare professionals.

    To provide

Medicinal products

Pharmaceutical companies · promotional review · medical affairs

  • ANSM recommendations on advertising

    Scope covered: promotional materials aimed at professionals, approvals and doctrinal compliance, mandatory mentions, detail aids, brochures, monographs, e-learning modules.

    Active
  • French Public Health Code, articles L.5122-1 to L.5122-16

    The ANSM doctrine we cover rests on it. Upload the text if you want the report to cite the article rather than the recommendation.

    To provide
  • Directive 2001/83/EC, title VIII

    The European basis for advertising of medicinal products for human use.

    To provide
  • Approved SmPC, patient leaflet and labelling

    Binding and evidence at the same time. To be uploaded in both piles.

    To provide
  • Promotional information charter and certification framework

    The frame for detailing and prospecting.

    To provide
  • LEEM code of practice, EFPIA code

    Industry commitments applicable to your materials.

    To provide
  • Marketing authorisation scope and internal off-label positions

    What the medical team may answer, and where the answer stops.

    To provide
  • EMA guidelines, including the QRD templates

    For the SmPC and the patient leaflet.

    Planned
  • ICH guidelines

    Not covered to date. For protocols and clinical reports.

    Planned

Cosmetics, food supplements

Product claims · consumer communication

Cosmetics

  • Regulation (EC) No 1223/2009

    The general framework for cosmetic products.

    To provide
  • Regulation (EU) No 655/2013, common criteria for claims

    Truthfulness, fairness, evidential support. The central text for a claims review.

    To provide
  • ARPP recommendation on cosmetic products

    For consumer-facing communication.

    To provide
  • Your product information file and your claim substantiation

    On the evidence side: what supports each effect you announce.

    To provide

Food supplements and foodstuffs

  • Regulation (EC) No 1924/2006, nutrition and health claims

    Together with the register of authorised claims.

    To provide
  • Regulation (EU) No 1169/2011, food information to consumers

    Labelling, legibility, mandatory particulars.

    To provide

Hospitals, laboratories, agencies

Quality · accreditation · service providers

  • HAS certification manual for healthcare establishments

    For quality documents, protocols and patient information materials.

    To provide
  • ISO 15189, medical laboratories

    Document control within the accreditation framework.

    To provide
  • Your procedures, protocols and standard operating procedures

    The quality framework as it actually applies at your site.

    To provide
  • The client's brief

    For an agency: the client's rules, on top of your own.

    To provide
  • The client's approval charter

    What your deliverable will be judged on at handover.

    To provide
04 The most useful one

The document nobody thinks to upload: your past rulings.

Every regulatory team has settled the same questions dozens of times. Those decisions live in email threads, in review comments, and in the heads of two people. They are written in no regulation, and yet they are what carries authority internally.

Upload them. A plain list of “we already settled this, this way, for this reason” is enough. This is the framework that makes a review recognisably yours, and that stops a closed debate from reopening every month.

  • “Indirect comparisons are refused, even when sourced.”
  • “The word ‘innovative’ is not used without qualifying the innovation.”
  • “A subgroup result is always announced as such in the sentence, not in a footnote.”
05 To make it usable

Five points that change the quality of the result.

A badly uploaded framework produces vague findings. These five points take five minutes and save you a disappointing review.

Text, not an image

A digital PDF or an office file. A photographed scan makes it impossible to quote a passage to the line, and therefore impossible to trace a finding back to its source.

A dated version

The one that carries authority at your site, with its date of application. Two versions of the same procedure produce two different verdicts, and that is normal.

Numbering kept

Keep article, section and paragraph numbers. That is what lets the report write “§4.2” rather than “your procedure”.

An extract is enough

If only chapter 4 concerns you, upload chapter 4 with its original pagination. A shorter, relevant text beats a whole corpus.

The point to check before uploading a standard

ISO, EN and IEC standards are licensed. Check that yours permits upload to a hosted tool. If it does not, upload instead the internal procedure that implements it: it belongs to you, it is often more precise than the standard, and it is the one your notified body will ask you to apply.

Unsure about a document?

Send it over, we will tell you whether it is usable

We will tell you whether it works as a requirement, as evidence, or whether it serves no purpose in your case. The analysis starts from the supplied documents alone, and no data is used for training.