EU MDR 2017/745: qualify and classify devices, plan conformity assessment, and maintain clinical, technical and post-market evidence.
Regulation
2017/745
Classification
Technical file
Annex II + III
Clinical evaluation
Article 61
Traceability
01Overview
Understand EU Medical Device Regulation
This MDR hub explains how Regulation (EU) 2017/745 applies to a medical device, accessory, medical-device software or Annex XVI product, then connects that scope decision to classification, market access and lifecycle evidence.
Start with the manufacturer's and EU supply-chain role. Then justify the class, choose the Article 52 conformity route, and keep quality, technical, clinical and post-market records aligned for the device's full lifecycle.
Follow the recommended path from scope and operator role to classification, conformity assessment, technical and clinical evidence, /, post-market controls and conditional legacy-device transition. Since 28 May 2026, the EUDAMED Actor, UDI/Devices, Notified Bodies and Certificates, and Market Surveillance modules have been mandatory; the Clinical Investigations and Vigilance/PMS modules follow the separate gradual-rollout timetable. documents explain practical approaches but do not replace the binding Regulation or implementing acts.
02At a glance
Quick scan
Start with intended purpose
The MDR qualification question turns on what the manufacturer intends the product to do for human beings. Software, accessories and Annex XVI products need the same disciplined scope record before classification or CE planning.
Classify before choosing the route
Record the applicable rule, invasiveness, duration of use, active or implantable status, substance or nanomaterial features, software decision impact, and any rule that drives a higher class.
Build a living evidence file
Keep Annex II and III technical documentation, risk management, GSPR mapping, clinical evaluation report, PMCF plan or non-applicability justification, PMS plan, vigilance procedure, data and actor/device records aligned with the released device.
Confirm the manufacturer's , accessory or software status, Annex XVI coverage, exclusions and borderline interfaces before applying a classification rule.
Separate manufacturer, authorised representative, importer and distributor duties; apply , including Rule 11 where relevant; then map the class to the Article 52 route and notified-body involvement.
Tie QMS and risk management controls, technical documentation, clinical evaluation and PMCF, PMS and vigilance, and data, corrective action and any conditional legacy-transition claim to one controlled device history.
04Timeline
Key records for medical device compliance
Track MDR application, Article 120 legacy-device conditions and the applicable 31 December 2027 or 31 December 2028 transition end date, application and agreement evidence, technical documentation updates, clinical evaluation and PMCF outputs, PMS/vigilance records, assignment, applicable mandatory actor and device registration, certificate status, and market-surveillance correspondence for each device family.
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05Focused guides
Check whether your device needs an SSCP
Start with the Summary of Safety and Clinical Performance (), the public safety and clinical evidence summary required for specified devices under the EU Medical Device Regulation (MDR). Use the guide library below for qualification, classification, conformity assessment, clinical evidence, and lifecycle work.
Which devices need an SSCP?
requires an for implantable and devices, except custom-made and investigational devices. For example, a class IIb dental implant needs one because it is implantable, while a non-implantable class IIb imaging system does not. Follow Medical Device Coordination Group () guidance for the content, notified-body validation, translations, and publication process.
New to the MDR? Start by documenting , product qualification and economic-operator role. If scope is settled, jump to classification, conformity assessment, technical or clinical evidence, traceability, transition, post-market controls, enforcement or a focused comparison.
Start here: qualification and scope
Decide whether the product is a medical device, accessory, medical-device software, Annex XVI product or an interface with another regime before classification begins.
Apply to the documented device facts, resolve software and special-rule questions, select the Article 52 route and confirm the 's designation scope where third-party assessment is required.
Turn manufacturer and supply-chain duties into owned controls, a traceable Annex II and III file, GSPR and risk evidence, supplier records and release gates that reopen when the device changes.
Connect the clinical evaluation plan and report to GSPRs, benefit-risk, equivalence limits, clinical investigations, PMCF, PMS signals and notified-body review.
Control actor and device data separately from conditional Article 120 transition claims, and distinguish fixed legal dates from recurring internal review events.
Post-market surveillance, vigilance and enforcement
Route complaints and signals through PMS, PMCF, PSUR or PMS reporting, vigilance clocks, FSCA and CAPA decisions, technical-file updates and national enforcement follow-up.
Keep MDR qualification and evidence distinct from adjacent regimes, or go directly to the FAQ for a specific question about software, accessories, clinical evidence, , or transition.
Grounds the Annex XVI references for products without an intended medical purpose, common specifications, risk management expectations and clinical evaluation considerations for non-medical purpose products.
"common specifications for the groups of products"
Supports the EUDAMED overview, including the six module areas and the mandatory status since 28 May 2026 of Actor, UDI/Devices, Notified Bodies and Certificates, and Market Surveillance.
Supports the notified body discussion, including designation by Member States, conformity assessment tasks where third-party intervention is required and use of NANDO lists for MDR-designated bodies.
Supports the hub's UDI and EUDAMED device-registration references, including manufacturer submission of UDI/device information and use of the UDI/device registration module.
"manufacturers submit in EUDAMED the UDI/Device information"
Supports the UDI implementation references and the need to treat UDI assignment, labelling and device data as controlled traceability evidence rather than a late formatting task.
"Questions and Answers on the Unique Device Identification system"
Supports the Annex XVI clinical-evidence caution: equivalence for products without an intended medical purpose requires careful comparison, and clinical data from medical devices may not be sufficient for non-medical purpose products.
"demonstration of equivalence for Annex XVI products"
Supports the legacy-device framing, including Article 120 conditions, QMS and notified body application milestones, extended transitional periods, surveillance transfer logic and removal of the former sell-off limit.
Binding amendment that permits individual EUDAMED electronic systems to become mandatory after their functionality notice and transition period, rather than waiting for all six modules to be fully functional.
Next steps
Assign MDR device and evidence responsibilities
This hub helps route MDR work by device family, , risk class, economic-operator role, status, clinical evidence route and EU market path. Build a controlled device file that stays current throughout the lifecycle.
Start with the product boundary, , claims, user population, EU market route, manufacturer and economic-operator roles, Annex XVI or software signals, and any borderline facts that change qualification.
Use Assessment Autopilot to request classification rationale, applicable rules, GSPR mapping, risk management records, Annex II and III technical documentation, clinical evaluation, PMCF or justification, PMS plan, PSUR where applicable, vigilance process, data and registration evidence.
Use Research Copilot for cited questions about MDR scope, Annex XVI common specifications, Rule 11 software classification, designation scope, conformity assessment routes, clinical evidence expectations, modules and Article 120 legacy-device conditions.
Keep design, quality, regulatory, clinical, post-market, distributor, importer, and authority-response records connected to the same device model and Basic -DI.