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MDRC – Medical Devices Regulatory Compliance

Regulation (EU) 2017/745 · Regulation (EU) 2017/746

EU medical device regulations MDR and IVDR

The MDR and IVDR are two parallel legal frameworks. The correct route starts with the product’s intended purpose, not with a preferred risk class or a registration form.

Manufacturers must determine which regulation applies, classify the product, build the required evidence, complete the applicable conformity assessment and maintain compliance throughout the product lifecycle.

MDR applicable since26 May 2021 IVDR applicable since26 May 2022 Normal market-access resultCE marking

CE conformity assessment is not product registration

The normal EU pathway does not end in a central authority granting a generic “medical-device approval.” The manufacturer demonstrates conformity with the applicable regulation and, where required, a notified body assesses the relevant quality system and technical documentation.

After the applicable assessment is complete, the manufacturer signs the EU declaration of conformity and affixes the CE marking. Actor and product data submitted to EUDAMED support identification and transparency; that submission does not replace conformity assessment.

01

Qualify

Confirm that the product falls within the MDR or IVDR.

02

Classify

Apply the legal rules to the intended purpose and design.

03

Demonstrate

Build technical, clinical or performance and quality evidence.

04

Maintain

Use post-market data to keep conformity current.

Choose the regulation before building the dossier

Product qualification depends on the intended purpose, claims, mode of action, specimen or patient interface and the information the product is intended to provide.

MDR

Regulation (EU) 2017/745

Medical devices

Covers devices intended for human beings whose principal intended action is not achieved by pharmacological, immunological or metabolic means. It also covers certain products without an intended medical purpose listed in Annex XVI.

Risk classes
I, IIa, IIb and III
Core evidence
Clinical evaluation
Applicable since
26 May 2021
View the MDR regulatory process
IVDR

Regulation (EU) 2017/746

In vitro diagnostic medical devices

Covers devices intended to examine specimens derived from the human body in vitro to provide medical information, including reagents, instruments, kits, software, calibrators, control materials and systems.

Risk classes
A, B, C and D
Core evidence
Performance evaluation
Applicable since
26 May 2022
View the IVDR regulatory process

Build the route in the right order

Classification controls the assessment route, but it does not replace the broader work needed to demonstrate conformity with every applicable requirement.

  1. 01

    Define intended purpose

    Fix the medical purpose, target population, user, environment, indications, limitations and operating principle.

  2. 02

    Qualify and classify

    Select MDR or IVDR, document the applicable Annex VIII rules and identify any special provisions.

  3. 03

    Build the evidence system

    Connect risk management, GSPR, verification and validation, clinical or performance evidence, labelling and manufacturing controls.

  4. 04

    Complete conformity assessment

    Use self-declaration where legally permitted or involve a notified body under the applicable assessment procedure.

  5. 05

    Declare conformity and apply CE

    Issue the EU declaration of conformity, apply the CE marking correctly and complete the required actor, UDI and product-data steps.

  6. 06

    Control the lifecycle

    Operate PMS and vigilance, update evidence and risk controls, manage changes and maintain current registration data.

The class changes the conformity-assessment route

Annex VIII rules must be applied to the concrete intended purpose and design. A product name or an existing competitor classification is not a sufficient rationale.

FrameworkClassesNormal notified-body involvementEvidence focus
MDR medical devicesI · IIa · IIb · IIIClasses IIa, IIb and III; limited involvement for class Is, Im and IrClinical evaluation, safety and clinical performance
IVDR diagnostic devicesA · B · C · DClasses B, C and D; limited involvement for class A sterileScientific validity, analytical performance and clinical performance
Lowest-risk route

Self-declaration is limited

It normally applies to class I devices that are not sterile, measuring or reusable surgical instruments, and to class A IVDs that are not sterile.

Higher-risk route

Notified-body assessment

The scope and depth of assessment increase with risk and may include QMS review, technical-documentation sampling, type examination or product verification.

Special pathways

Additional procedures may apply

Companion diagnostics, class D IVDs, medicinal-substance combinations, animal tissues and certain high-risk devices may trigger consultation or verification procedures.

Market access depends on a controlled operator chain

The manufacturer remains responsible for the product. Other economic operators have distinct verification, cooperation and traceability obligations.

01

Manufacturer

Owns conformity, the QMS, technical documentation, evidence, CE marking, PMS, vigilance and corrective action.

02

EU authorised representative

Required for a manufacturer established outside the EU and appointed through a written mandate for the covered devices.

03

Importer

Verifies key compliance elements before placing a device from a non-EU manufacturer on the Union market.

04

Distributor

Checks specified information, protects storage and transport conditions and supports traceability and corrective action.

Conformity must be traceable, not merely asserted

The technical documentation should show how the released product, its claims, risks, verification and real-world information form one controlled system.

01

Quality management system

Design, supplier, manufacturing, change, complaint, CAPA and post-market processes proportionate to the product and organisation.

02

Risk management and GSPR

Applicable requirements mapped to design controls, risk controls, standards, tests and controlled evidence.

03

Technical documentation

Product definition, design and manufacturing information, benefit-risk rationale, verification, validation and supplied information.

04

Clinical or performance evidence

MDR clinical evaluation or IVDR performance evaluation aligned with the intended purpose and state of the art.

05

UDI and EUDAMED data

Controlled identifiers and actor, device and certificate data consistent with the declaration, certificates and released product.

06

PMS and vigilance

Proactive data collection, trend review, incident reporting, periodic outputs and feedback into risk and evidence updates.

Transition dates are conditional, not automatic extensions

Legacy-device provisions allow certain products to remain on the market during defined periods only when all applicable conditions are met. New devices and devices outside those provisions must comply fully with the MDR or IVDR.

MDR legacy devices 31 Dec 2027

Class III and relevant class IIb implantable devices

MDR legacy devices 31 Dec 2028

Other class IIb, class IIa and qualifying class I devices

IVDR legacy devices 2027 · 2028 · 2029

Class D, class C, and class B or class A sterile respectively

Conditions matter

Deadlines depend on continued legacy eligibility, timely notified-body application and agreement where required, QMS implementation, surveillance and absence of disqualifying significant changes.

The framework continues to evolve after the regulations apply

Consolidated legal texts, implementing acts and current MDCG guidance should be checked when a regulatory decision is made.

EUDAMED

Four modules became mandatory on 28 May 2026

Actor registration, UDI/Device registration, Notified Bodies and Certificates, and Market Surveillance are now mandatory.

Review EUDAMED registration
Supply continuity

Article 10a creates an information duty

For covered devices, an anticipated interruption or discontinuation that may create serious harm or a risk of serious harm can trigger advance notification duties.

Open the Commission Q&A
Guidance

MDCG documents support application of the law

They express a common implementation understanding but do not replace the binding text of the MDR, IVDR or applicable implementing legislation.

Open current MDCG guidance

Questions to answer before planning market access

If these points are not controlled, timelines and notified-body quotations are based on assumptions rather than a defined regulatory route.

Intended purpose

Medical purpose, target population, user, use environment, indications and limitations are fixed.

Qualification

The rationale identifies MDR, IVDR or another legal framework and addresses borderline issues.

Risk class

Every applicable Annex VIII rule has been assessed and the decisive rule is documented.

Conformity route

The applicable annex, notified-body need and any consultation or verification procedure are known.

Economic operators

Manufacturer, authorised representative, importer and distributor responsibilities are allocated.

Evidence plan

Technical, clinical or performance, biological, software, usability and other evidence needs are mapped.

QMS readiness

Required processes and records exist before design transfer, certification and commercial distribution.

Lifecycle plan

PMS, vigilance, PMCF or PMPF, periodic reporting, change control and registration maintenance are resourced.

Questions about the MDR and IVDR

Which regulation applies to my product?

The intended purpose and product characteristics determine the answer. The MDR generally applies to medical devices and Annex XVI products, while the IVDR applies to medical devices intended to examine human specimens in vitro for a medical purpose.

Does a medical device receive EU approval?

The normal route is conformity assessment followed by the manufacturer's EU declaration of conformity and CE marking. Notified-body involvement depends on class and product characteristics. EUDAMED registration is not a substitute for conformity assessment.

When is a notified body required?

Under the MDR, generally for classes IIa, IIb and III and for defined aspects of class Is, Im and Ir. Under the IVDR, generally for classes B, C and D and for the sterile aspects of class A sterile devices.

What must a non-EU manufacturer arrange?

A manufacturer established outside the EU must designate a sole EU authorised representative for the relevant devices. Importer requirements also apply when the product is placed on the Union market.

Can a legacy device use a transition date automatically?

No. Transitional provisions are conditional. Eligibility, notified-body application and agreement deadlines, QMS requirements, surveillance and change restrictions must all be checked for the specific device.

Does CE marking finish the compliance work?

No. The manufacturer must maintain the QMS and technical documentation, operate PMS and vigilance, update evidence and risk controls, manage changes and keep required actor, UDI and product data current.

Define the pathway before committing to the dossier

MDRC can assess qualification and classification, define the conformity route, map the required evidence and organise the manufacturer, authorised-representative, notified-body and EUDAMED workstreams.