I am wondering regarding the requirement for an implant card for injectable lubricant, injected to the knee joint (intraarticular hyaluronic acid product) .
I couldn’t find any rational for such a product can be exempted.
Article 18 relates to implant information. Exemptions are noted in 18(3):
3. The following implants shall be exempted from the obligations
laid down in this Article: sutures, staples, dental fillings, dental braces, tooth crowns, screws, wedges, plates, wires, pins, clips and connectors. The Commission is empowered to adopt delegated acts in
accordance with Article 115 to amend this list by adding other types of
implants to it or by removing implants therefrom.