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      Keep Your Drug-Device Combination Products Variation-Ready

      We’ve experienced, that even long established drug–device combinations can fall short of current regulatory data expectations—putting variations at risk. We support you in assessing and strengthening your DDC data package to ensure robust, compliant submissions.

      DDC Variation Readiness

      EU Submission Readiness for Global Pharma

      Avoid Late Surprises in Your EU Submission. FDA approval is not a guarantee of EU readiness. European regulators apply different expectations for data, documentation, and operational infrastructure. Many US companies encounter gaps that lead to delays, rework, or regulatory friction.

      EU Readiness Checks

      SPOTLIGHT: EU AI Act Q&A Competition

      From May to June 2026, we are hosting the first competition to assess the ability of AI agents to answer truthfully, concisely, and effectively to questions of the AI Act.

      AI Act Competition
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regenold GmbH
Zöllinplatz 4
79410 Badenweiler
Germany

Phone: +49 7632 82 26-0
Email: info@regenold.com

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Regulatory Compliance Roles & Legal Representation

Placing a product on the EU market, running a clinical trial, or holding a marketing authorisation requires defined regulatory compliance and/or legal roles to be in place. These include positions such as QPPV, QP, Responsible Person, Legal Manufacturer, EU/UK/CH Representative, and others depending on the product and market.

We take these roles on behalf of clients, providing the required licensed infrastructure, named individuals, and operational systems across the EU, UK, and Switzerland. This is not advisory work, but the assumption of defined regulatory responsibilities that are required for market access and ongoing compliance.

Examples of How We Support

Below are examples to illustrate the kind of work we do day to day. The fastest way to find out more is usually via a short call; this will help us to understand your specific challenges and to explore how we can help.

MAH and named roles

You’re a non-EU company and need to place a pharmaceutical product on the European market, but you have no EU entity, no MAH infrastructure, and no named compliance personnel. You need someone who can hold the marketing authorisation, provide the EU QPPV, the Stufenplanbeauftragter, the Drug Information Officer, and the QP for batch release, , all under one roof. We can also provide contract RPs.

Device legal manufacturer

You're developing a medical device and need EU market access, but you don't have an ISO 13485 QMS or the infrastructure to act as the legal manufacturer under MDR or IVDR. You need a partner who can take on the legal manufacturer role, provide the PRRC, and manage the conformity assessment process so your product reaches the EU market without you building an entire QM or regulatory infrastructure from scratch.

Combination product QM requirements

You're a pharmaceutical company developing a combination product or companion diagnostic and your existing pharma QMS doesn't cover device requirements. Rather than extending your GMP system to include ISO 13485, you want a partner who can act as the legal manufacturer for the device component under a separate, dedicated device QMS.

CTR sponsor and IMP release

You're a non-EU sponsor planning a clinical trial in Europe and need either an EU legal representative or someone to take on the full sponsor role under the Clinical Trials Regulation. You need a partner who can submit the CTA via CTIS, manage safety reporting, and handle regulatory correspondence with member state authorities. You also need an EU QP named on an IMP MIA to release the IMP to the clinical site.

Consolidating named roles

You already have products on the EU market but your compliance roles are scattered across multiple providers. Your QPPV is with one firm, your QP with another, your DIO with a third. You want to consolidate under a single partner who can provide all named compliance roles, coordinated and on existing licences (excl. WDA).

Local vigilance network

You need local pharmaco- or device vigilance contact persons across multiple EU countries but don't want to contract separately in each market. You need a single point of contact that can provide local QPPVs and safety officers across the EU and CEE through a coordinated network.

Understanding Regulatory Compliance Roles & Legal Representation

In life sciences, “legal representation” refers to formally defined regulatory roles that must be assigned to named individuals or entities. These roles differ by product type:

  • Pharmaceuticals: MAH, QPPV, QP, RP, DIO
  • Medical Devices & IVDs: Legal Manufacturer, EU Authorised Representative, PRRC
  • Clinical Trials: EU Sponsor or EU Legal Representative
  • Food & Cosmetics: Responsible Person (RP), Food Business Operator (FBO)

This page covers all of these. It is about the roles where regenold takes on formal legal responsibility on behalf of clients, not advisory services. For food and cosmetics legal representation specifically, these services are delivered by NutraCompliance, our dedicated food and cosmetics team. For the broader regulatory strategy and submission work, see Regulatory Strategy & Operations. For the QMS infrastructure and licensing that underpins these roles, see Quality & Compliance. For clinical trial design and operations, see Clinical Development.

What We Do

Each of the roles below means regenold carries a legal obligation on behalf of the client. We take these on deliberately, typically as part of a broader regulatory or development engagement where we already understand the product, the regulatory strategy, and the compliance landscape. We operate on our own licences and certified infrastructure in Germany, the UK/Ireland, and Switzerland and can also be named on client licenses.

Pharmaceutical representation
  • Act as Marketing Authorisation Holder (MAH) across EU, UK, and Switzerland
  • Maintain QMS, manage inspections, and support MA transfer when required
  • Provide QPPV, QP, RP, Stufenplanbeauftragter, and DIO roles
  • Act as the EU batch release site for commercial and investigational medicinal products
  • Coordinate local pharmacovigilance networks across EU and CEE
Medical device representation
  • Act as Legal Manufacturer under MDR/IVDR with full ISO 13485 infrastructure
  • Provide EU Authorised Representative, UK Responsible Person, and Swiss Authorised Representative
  • Appoint PRRC and manage EUDAMED registration and Notified Body interactions
Clinical trial representation
  • Act as EU Sponsor or EU Legal Representative under the Clinical Trials Regulation
  • Submit CTAs via CTIS, manage safety reporting, and handle authority interactions
Food & cosmetics (via NutraCompliance)
  • Act as Food Business Operator (FBO) and Responsible Person (RP)
  • Manage compliance, registration, safety documentation, and post-market obligations

For AI governance roles in regulated environments (similar in concept to an external DPO, but for AI oversight under the EU AI Act), see our AI Governance & Compliance service page.

Our Workstreams

Legal representation engagements are structured around the type of legal responsibility involved. In most cases, these roles are part of a broader regulatory or development programme rather than standalone appointments.

MAH Holding & Market Entry

Act as MAH in EU, UK, and Switzerland. MA application and holding (long-term or interim). Local QMS maintenance, batch release to market, authority inspection management, authority liaison, and MA transfer when ready. All four EU registration routes supported: centralised, MRP, DCP, and national.

Pharmacovigilance Representation

EU QPPV appointment and oversight. UK NCP (national contact person). Local QPPVs in IE, DE, UK, CH, AT directly, plus all EU and CEE countries via regulanet®. PSMF establishment and maintenance. 24/7 authority contact. Stufenplanbeauftragter for Germany.

Quality & Compliance Roles

QP for batch release (manufacturing/import). RP for wholesale distribution. DIO / Informationsbeauftragter in most EU member states via regulanet®. Roles provided on our own licences (MAH, MIA, QP, DIO) or on client licences (QP, RP, DIO).

Device Legal Representation

Legal Manufacturer under MDR/IVDR Article 10 with full ISO 13485 and ISO 27001 infrastructure. EU REP under Article 11 for non-EU manufacturers. UK Responsible Person and Swiss Authorised Representative. PRRC under Article 15. EUDAMED registration. Notified Body coordination. Post-market surveillance system operation.

Food & Cosmetics Representation

Food Business Operator (FBO) services: regulatory compliance management, product registration and notification, label compliance, post-market surveillance. Responsible Person (RP) for cosmetics under EU Regulation 1223/2009: safety assessment oversight, CPNP/SCPN submissions, PIF management. Delivered by NutraCompliance, our dedicated food and cosmetics team.

Clinical Trial Representation

EU Sponsor role under CTR: CTA via CTIS, trial insurance, safety reporting, GCP oversight. EU Legal Representative for non-EU sponsors. Regulatory correspondence with national competent authorities across member states.

Multi-Country Coordination via regulanet®

Local compliance roles (QPPVs, DIOs, safety officers) across 90+ countries through our network of independent regulatory consultancies. Single contract, single contact point. Emerging: ex-EU MAH holding in Southeast Asian markets.

Where This Fits in the Development Journey

Legal representation roles apply at different points depending on the product type and regulatory pathway. The roles required shift as a product moves from clinical investigation through to post-market lifecycle management.

Clinical

EU Sponsor or EU Legal Representative for clinical trials. CTA submission via CTIS, trial insurance, safety reporting, GCP compliance, IMP QP appointment for batch release to clinical sites.

Regulatory Submission & Approval

MAH setup in preparation for MA grant. Legal Manufacturer or EC REP appointment for device conformity assessment. QP, RP, and QPPV appointments before the MA is issued, ensuring named compliance personnel are in place ahead of approval.

Launch & Market Access

Activate MAH infrastructure and provide all named compliance roles for commercial launch. Register with EUDAMED for devices. Appoint local QPPVs and DIOs in launch markets via regulanet® to ensure full coverage from day one.

Post-Market & Lifecycle Management

Ongoing MAH operations: variations, renewals, PV system maintenance, inspection readiness, and batch release. Device PMS and vigilance. Expand into new markets with additional local roles via regulanet®.

Product Type Considerations

The legal representation roles differ depending on what you're developing. These highlight the key roles and considerations by product type.

Pharmaceuticals

MAH holding in EU, UK, and Switzerland. EU QPPV and local QPPVs. QP for batch release. RP for wholesale. Stufenplanbeauftragter. DIO / Informationsbeauftragter. Full infrastructure across all three jurisdictions.

Digital Health & SaMD

Depending on classification: Legal Manufacturer for software as a medical device under MDR/IVDR. EU REP for non-EU software developers. We also provide contract development for medical device software including AI-based solutions.

Clinical Trial Products

EU Sponsor or EU Legal Representative under the CTR. Applies to all product types being investigated in EU clinical trials, including pharmaceuticals, biologics, and devices.

Medical Devices & IVDs

Legal Manufacturer (MDR/IVDR Article 10). EU REP (Article 11). Importer (Article 13). PRRC (Article 15). EUDAMED registration. Requires ISO 13485 QMS infrastructure, which we operate in Badenweiler.

Combination Products

Dual representation may be needed: MAH for the drug component, Legal Manufacturer or EU REP for the device component. Coordinated under one relationship to avoid gaps and overlap.

Food & Cosmetics

Food Business Operator (FBO) for food products. Responsible Person (RP) for cosmetics under EU Regulation 1223/2009. Delivered by NutraCompliance, our dedicated food and cosmetics team.

Sample Deliverables

icon MAH setup package: MA application documentation, establishment licence applications (MIA, WDA, PEL), QMS documentation, named person appointments (QP, RP, QPPV, Stufenplanbeauftragter, DIO), and GDP compliance documentation for EU, UK, or Swiss market entry.
icon EU QPPV service agreement with PSMF establishment, SOP framework, safety database access, and Article 57 database registration.
icon Local QPPV network setup: appointment of local pharmacovigilance contact persons across target EU/CEE markets, with service agreements and reporting lines to the EU QPPV.
icon Legal Manufacturer onboarding package: kick-off workshop, MDR/IVDR compliance gap assessment of technical documentation, contractual agreements including definition of functional roles and responsibility matrix.
EU site of batch release: review of supply chain, licence variations, QMS documentation, quality agreements, and ongoing oversight of CMOs, packaging sites, importation sites, and EU testing sites.
icon Clinical trial sponsor package: CTA application via CTIS, trial insurance certificate, safety reporting SOPs, GCP oversight plan, and regulatory correspondence framework.
icon EC REP service agreement with authority registration, incident reporting procedures, and ongoing compliance monitoring.
icon Consolidated compliance role documentation: single service agreement covering MAH, QPPV, QP, RP, Stufenplanbeauftragter, and DIO for a client's full EU product portfolio.

Example Projects

icon
Medical Device Startup: Legal Manufacturer under MDR

A US-based device manufacturer needed to place a Class IIa product on the EU market but had no ISO 13485 QMS or EU entity. We took on the Legal Manufacturer role through our ISO 13485-certified NEXTEC medical daughter company, managed the technical documentation, coordinated the conformity assessment with the Notified Body, registered the device in EUDAMED, and provided the PRRC. The manufacturer focused on product development and US market while we handled all EU regulatory obligations. CE marking achieved within 10 months.

icon
US Biotech: EU Sponsor for Phase II Clinical Trial

A US biotech needed to run a Phase II trial across three EU member states but had no EU presence. We acted as the EU sponsor under the CTR: submitted the CTA via CTIS, arranged trial insurance, managed SUSAR reporting to EudraVigilance, and served as the regulatory contact for all three national competent authorities as well as performing IMP batch release for the clinical trial. The biotech retained scientific oversight while we carried all EU legal and regulatory obligations.

Related Services

Quality & Compliance →

The licences, QMS, and infrastructure that underpin the legal roles described on this page. MAH and MIA applications are detailed there.

Clinical Development →

EU Sponsor and EU Legal Representative roles for clinical trials, including CTA submission, trial insurance, and safety reporting.

Pharmacovigilance & Device Vigilance →

EU QPPV services, local QPPV network, PV system establishment, PSMF, and ongoing safety reporting.

Market Access & HTA Strategy →

MAH infrastructure and market entry coordination. Legal representation roles are a prerequisite for commercial launch.

Post-Approval & Lifecycle Management →

Ongoing compliance role management, variations, renewals, and expansion into new markets.

Considering EU Market Entry and Need to Understand Which Legal Roles Apply to Your Product?

Tell us what you're developing and which markets you're targeting. We'll assess the requirements and outline what we can provide. Start with a focused discussion. A short call is often the fastest way to clarify your current position, identify the roles required, and define the most efficient path forward.

Speak with Our Team

Key Regulations & Guidance +

These are the legal frameworks that define the roles covered on this page.

  • EU Clinical Trials Regulation (EU) No 536/2014 — sponsor and legal representative obligations
  • Directive 2001/83/EC, as amended — MAH obligations, QPPV requirements under Articles 23, 104
  • Regulation (EU) No 726/2004 — centralised procedure, QPPV requirements under Article 23
  • EU MDR 2017/745 — Legal Manufacturer Article 10, Authorised Representative Article 11, Importer Article 13, PRRC Article 15
  • EU IVDR 2017/746 — equivalent device representation roles
  • German AMG §63a — Stufenplanbeauftragter / drug safety officer requirements
  • EMA GVP Module I — QPPV role and responsibilities
  • EU Cosmetics Regulation (EC) No 1223/2009 — Responsible Person obligations
  • EU General Food Law Regulation (EC) No 178/2002 — Food Business Operator obligations
  • Eudralex Volume 4, Rules Governing Medicinal Products in the EU

Frequently Asked Questions (FAQ) +

What is the difference between a Legal Manufacturer and an EU REP for medical devices?

The Legal Manufacturer takes on the full Article 10 obligations under MDR/IVDR: responsibility for design, manufacturing oversight, technical documentation, conformity assessment, post-market surveillance, and vigilance reporting. This requires an ISO 13485-certified QMS. The EU REP (Article 11) represents a non-EU manufacturer in the EU but does not take on the manufacturer's full obligations. The manufacturer retains overall responsibility; the EU REP serves as the EU contact point for authorities and keeps certain documentation accessible. The right choice depends on whether you need someone to carry the manufacturer's obligations (Legal Manufacturer) or simply need EU representation (EC REP).

Can one provider really cover all these compliance roles?

In practice, yes, and there are good reasons to consolidate. When the MAH, the QPPV, the QP, the RP, and the Stufenplanbeauftragter all sit within the same organisation, the compliance system is integrated rather than stitched together across multiple providers. We operate our own licences (MAH, MIA) and certified infrastructure in Germany, the UK/Ireland, and Switzerland. That said, we take on each role based on a proper assessment of the product, the regulatory landscape, and the client's own capabilities. Not every engagement requires every role.

How does the local QPPV network work?

We provide local QPPVs and pharmacovigilance national contact persons directly in Germany, the UK, Switzerland, and Austria. For all other EU and CEE countries, we provide these through regulanet® partners. You have one contract with regenold and one point of contact. We coordinate the appointments, manage the reporting lines to the EU QPPV, and ensure compliance across all markets.

What does "acting as sponsor" mean for a clinical trial?

Under the EU Clinical Trials Regulation, the sponsor is the legal entity responsible for the trial. When we act as sponsor, we submit the CTA via CTIS under our name, arrange trial insurance and indemnity, report SUSARs to EudraVigilance, ensure GCP compliance at all sites, and correspond with national competent authorities. The client retains scientific oversight and funds the trial. This is not the same as a CRO, which performs delegated tasks without carrying the ultimate legal responsibility.

Can you hold the marketing authorisation temporarily and then transfer it?

Yes. We regularly act as interim MAH for companies that are setting up their own EU presence. We hold the MA, operate the compliance infrastructure, and transfer the authorisation when the client is ready. In Switzerland, our entity can apply for the MA, hold it, manage Swissmedic inspections, and execute the transfer. The same applies in the EU and UK.

Do you provide DIO / Informationsbeauftragter services outside Germany?

Yes. We provide Drug Information Officer services in Germany directly and in most other EU member states through regulanet® partners. The client has one contract and one contact point. This is particularly relevant for companies launching across multiple EU markets simultaneously.

Is ex-EU MAH holding available?

Yes, we can hold MAs in both the UK and Switzerland. We are also currently developing MAH holding capabilities in Southeast Asian markets through regulanet® members. This is an emerging service. Contact us for the current status and available markets.

Page Contents

  • Examples of How We Support
  • Understanding Regulatory Compliance Roles & Legal Representation
  • What We Do
  • Our Workstreams
  • Development Journey
  • Product Type Considerations
  • Sample Deliverables
  • Example Projects
  • Related Services
  • Key Regulations & Guidance
  • Frequently Asked Questions (FAQ)
regenold GmbH

regenold is a global, end-to-end integrated development partner for pharmaceuticals, medical devices, and drug-device combination products. We support life sciences companies across the entire product lifecycle, delivering integrated development, regulatory, and market access expertise to enable efficient, compliant advancement from concept to market.

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regenold GmbH
Zöllinplatz 4
79410 Badenweiler
Germany

Phone: +49 7632 82 26-0
Email: info@regenold.com

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