Skip to main content
MDRC – Medical Devices Regulatory Compliance

EU MDR · Regulation (EU) 2017/745

Build the EU pathway around the medical device and its evidence

EU market access for a medical device is not a single registration or approval step. It is a controlled conformity-assessment process connecting intended purpose, risk classification, clinical evidence, the quality system, technical documentation and lifecycle oversight.

Pathway logic

04
Risk classes under Annex VIII
A
Ordinary class I devices normally self-declared
IIa–III
Notified-body conformity assessment
2026
UDI/Devices module mandatory in EUDAMED

Conformity assessment, not central product approval

The MDR does not create one authority that approves every medical device. The manufacturer remains responsible for compliance, selects the applicable conformity-assessment route and issues the EU declaration of conformity. Notified-body involvement depends on the risk class and characteristics such as sterility, a measuring function or reusable surgical use.

Registration in EUDAMED is a required data step within that wider system. It does not replace classification, clinical evaluation, technical documentation, conformity assessment or CE marking.

01

Define

Intended purpose, mode of action and device architecture control the route.

02

Demonstrate

Evidence must support safety, clinical performance and the claimed benefit.

03

Maintain

Compliance continues through PMS, vigilance and change control.

Follow one evidence system through the class-specific route

The class changes the depth and independence of assessment, but every route starts with a defined device and a controlled body of evidence. The diagram shows the principal sequence for a new device placed on the EU market under the MDR.

Scroll horizontally to inspect the complete process map.

EU MDR regulatory process for medical devices The process begins with intended purpose and qualification, moves through classification and a shared evidence system, splits into self-declaration for ordinary class I devices and notified-body assessment for class I sterile, measuring and reusable surgical devices and classes IIa, IIb and III, then joins at UDI, EUDAMED, declaration of conformity, CE marking and post-market lifecycle controls. 01 · DEFINE THE REGULATORY PRODUCT Qualify the product and fix its intended purpose Medical purpose · target population · users · use environment · mode of action · variants 02 · CLASSIFY UNDER ANNEX VIII Class I Lowest risk Class IIa Moderate risk Class IIb Elevated risk Class III Highest risk 03 · BUILD THE SHARED COMPLIANCE SYSTEM Quality system Article 10(9) Regulatory strategy and controls Risk and GSPR Annex I requirements Benefit-risk and verification Technical documentation Annexes II and III Product and lifecycle evidence Clinical evaluation Clinical data · benefit-risk · PMCF Article 61 and Annex XIV 04A · ORDINARY CLASS I Manufacturer self-declaration Complete the applicable MDR evidence and issue the EU declaration of conformity. No notified body for the ordinary route 04B · CLASS Is, Im, Ir AND CLASSES IIa, IIb, III Notified-body conformity assessment Is, Im, Ir · limited to sterility, metrology or reprocessing IIa–III · Annex IX or another permitted class-specific route Certain high-risk devices may add consultation or scrutiny steps Economic operators AR where required · PRRC Identification and data Basic UDI-DI · UDI · EUDAMED Market placement EU declaration · CE marking Lifecycle control PMS · PMCF · vigilance · changes

The exact route depends on the device, class, sterile or measuring status, reusable surgical use, conformity-assessment strategy and any special procedure applicable to the technology.

Download the one-page MDR pathway

Classification determines who assesses the evidence

Classification follows the 22 rules in Annex VIII and the intended purpose defined by the manufacturer. A classification used in another jurisdiction cannot simply be transferred to the European Union.

Class I Ordinary route

Self-declaration route

The manufacturer completes the applicable MDR documentation, issues the EU declaration of conformity and affixes the CE marking without notified-body participation.

Class Is · Im · Ir Special class I aspects

Limited notified-body scope

A notified body assesses the relevant sterility, metrological or reusable-surgical-instrument reprocessing aspects. The remaining class I obligations stay with the manufacturer.

Class IIa Moderate risk

Notified-body assessment

The notified body audits the quality system and assesses technical documentation for at least one representative device for each category under the selected route.

Class IIb Elevated risk

Deeper evidence assessment

Notified-body assessment covers the quality system and representative technical documentation for each generic device group. Implantable devices receive additional device-specific scrutiny under the applicable route.

Class III Highest risk

Additional independent controls

Device-specific technical documentation and clinical evidence receive the greatest scrutiny. Certain devices may also trigger the clinical evaluation consultation procedure.

Technical documentation is a connected system, not a file collection

Annexes II and III define the documentation structure. The content must remain consistent with the intended purpose, risk controls, claims, product configuration, manufacturing controls and clinical evidence.

01

Quality management system

The MDR requires a documented QMS proportionate to the risk class and type of device. ISO 13485 is the usual framework, but the QMS must also cover the specific obligations in Article 10(9).

02

Risk and GSPR evidence

Risk management, benefit-risk determination and the Annex I GSPR checklist must be tied to design inputs, verification, labelling and residual-risk communication.

03

Clinical evaluation

Clinical data must support safety, performance and the claimed clinical benefit. The evaluation plan and report must be updated across the lifecycle and connected with PMCF where applicable.

04

Product and manufacturing data

Device description, variants, raw materials, software, manufacturing processes, verification, validation, software, biocompatibility and release controls must describe the released device.

05

Information supplied

Labels, instructions for use, claims, symbols and language versions must agree with the intended purpose, performance data, residual risks, UDI records and market configuration.

06

Post-market system

PMS, PMCF, vigilance, trend reporting, periodic reporting and CAPA feed new information back into risk management, clinical evaluation and controlled product changes.

Complete the legal and data chain before market placement

These workstreams should be planned early. They affect the label, technical documentation, contractual structure, EUDAMED records and release decision.

01

EU authorised representative

A manufacturer established outside the EU must designate one authorised representative by written mandate. The representative is not interchangeable with a distributor.

02

Person responsible for regulatory compliance

The manufacturer and, separately, the authorised representative must have access to an appropriately qualified PRRC under the conditions of Article 15.

03

UDI and EUDAMED

Assign the Basic UDI-DI and UDI-DI under the selected issuing entity rules, register the actor and submit required device data. EUDAMED does not generate the UDI.

04

Declaration and CE marking

After completing the applicable conformity assessment, issue the EU declaration of conformity and affix the CE marking. Add the notified-body identification number where required.

05

Importer and distributor controls

Verify economic-operator obligations, traceability, storage, complaint exchange and language coverage before commercial distribution begins.

Transition dates apply only when every condition is met

New devices have had to comply with the MDR since 26 May 2021. The dates shown here apply only to eligible legacy devices covered by Article 120 and do not postpone the MDR requirements that already apply during transition.

31 Dec 2027

Class III and relevant class IIb implantable legacy devices

31 Dec 2028

Other class IIb, class IIa and qualifying class I legacy devices

Conditions include

  • No significant change in design or intended purpose
  • No unacceptable risk to health or safety
  • MDR-compliant QMS in place no later than 26 May 2024
  • Formal notified-body application submitted by 26 May 2024
  • Written agreement with the notified body concluded by 26 September 2024

These procedural deadlines have passed. A device that did not meet them cannot newly enter the extended transition in 2026. Continued eligibility must be verified for the specific device and certificate.

Practical MDR distinctions

The route must be confirmed for the actual intended purpose, technology, sterile status, class and regulatory history.

Are medical devices registered or approved in the European Union?

The MDR establishes a conformity-assessment and CE-marking system, not one central product-approval procedure. The manufacturer demonstrates conformity and issues the EU declaration. A notified body participates where the class or product characteristics require it, while EUDAMED registration forms a separate data obligation.

Which medical devices require a notified body?

Classes IIa, IIb and III require notified-body conformity assessment. Ordinary class I devices are normally self-declared. Class Is, Im and Ir also require a notified body, with its scope limited to the relevant sterility, metrology or reprocessing aspects.

Is ISO 13485 certification mandatory?

The legal requirement is an MDR-compliant quality management system under Article 10(9). ISO 13485 is the principal standard used to structure that system, but certification to the standard does not by itself demonstrate complete MDR conformity.

Does every medical device require a new clinical investigation?

Every device requires a clinical evaluation, but a new clinical investigation is not automatically required for every device. The decision depends on the device, risk class, available clinical evidence and Article 61 requirements. Implantable and class III devices generally require clinical investigations unless an applicable exception can be fully justified.

Does EUDAMED issue the UDI?

No. The manufacturer assigns identifiers under the rules of a Commission-designated issuing entity and then submits the required UDI and device data to EUDAMED. The UDI/Devices module has been mandatory to use since 28 May 2026.

Can a legacy medical device automatically use the extended transition?

No. The extended dates apply only to eligible legacy devices when every Article 120 condition has been satisfied. Classification and the existence of an old MDD or AIMDD declaration or certificate are not sufficient on their own.

Define the pathway before building the submission package

Tell us the intended purpose, technology, users, current market status and available clinical and technical evidence. We will identify the classification, conformity-assessment route and the most useful next step.

Discuss your MDR pathway