This page helps organize the core requirements for a medical device under Regulation (EU) 2017/745: qualification, classification, GSPR, conformity assessment, technical documentation, , clinical evaluation, UDI, EUDAMED, , vigilance, and economic-operator duties.
Build a traceable requirements register that links each device, role, obligation, owner, source, and evidence record before EU market placement or a major product change.
EU MDR requirements work should start with the exact product, intended purpose, EU role, and market activity. A useful record then links the device to its classification, conformity route, , technical documentation, clinical evidence, post-market controls, UDI and EUDAMED records, and economic-operator obligations.
1
Section 1
1. Qualification and classification
Decide first whether the product is a medical device, an accessory, an Annex XVI product without an intended medical purpose, software driving or influencing a device, a , a custom-made device, or outside MDR scope. The decision should be based on the manufacturer's intended purpose, claims, functionality, patient or user context, and how the product is placed on the EU market.
Once the product is in scope, classify it under MDR Article 51 and Annex VIII. Record the class I, IIa, IIb, or III outcome, the classification rule used, any sterile, measuring, or reusable-surgical-instrument status for class I devices, and any special features such as implantable use, medicinal substances, animal or human tissue derivatives, nanomaterials, active diagnosis or therapy, or software functions.
Keep a qualification memo with intended purpose, claims, user group, patient population, operating environment, inputs and outputs, and borderline assumptions.
For software, identify medical-purpose modules separately from administrative storage, transfer, archive, or simple-search functions, and reassess qualification when functions or intended use change.
Keep a classification table with each Annex VIII rule considered, the rule selected, why stricter or special rules do or do not apply, and the downstream impact on notified-body involvement.
Commission guidance index listing MDR borderline, classification, and software qualification guidance used to support practical classification records.
Regulation (EU) 2017/745 on medical devices (MDR)
2
Section 2
2. GSPR, technical documentation, and conformity route
For each in-scope device, build a matrix against Annex I. The matrix should state whether each GSPR is applicable, the rationale for exclusions, the standard, common specification, test, analysis, label, usability file, risk-control record, or clinical evidence used to show conformity, and any open gap.
Technical documentation should be maintained under Article 10 and Annexes II and III. It should contain device identification, intended purpose, design and manufacturing information, risk management, verification and validation evidence, clinical evaluation outputs, labels and instructions, planning, and any declarations, certificates, notified-body submissions, or authority correspondence needed to show the conformity route. Retain the technical documentation, declaration, and relevant certificates for at least 10 years after the last covered device is placed on the market, or at least 15 years for implantable devices.
Map the conformity assessment path under Article 52 before market placement, including whether the route is self-declaration for class I, limited notified-body involvement for sterile class I devices, class I devices with a measuring function, or reusable surgical instruments, or notified-body assessment under Annex IX, X, or XI.
Claim the Article 8 presumption of conformity only for requirements covered by a harmonised standard whose reference is published in the Official Journal. Record other standards, applicable common specifications, or justified equivalent solutions used to demonstrate conformity.
Keep technical documentation current after design, manufacturing, software, supplier, standard, clinical, , or market changes.
Articles 8, 9, 10, and 52 plus Annexes I, II, and III ground GSPR, standards/common specifications, technical documentation, conformity assessment routes, and the 10-year documentation-retention period extended to 15 years for implantable devices.
Commission overview sources support the role of harmonised standards and OJEU publication references in demonstrating conformity.
The references of harmonised standards must be published
3
Section 3
3. QMS and clinical evidence
The manufacturer's should cover the MDR obligations listed in Article 10(9), including regulatory strategy, GSPR identification, management responsibility, supplier and subcontractor control, risk management, clinical evaluation and PMCF, product realization, UDI verification, , authority and notified-body communications, vigilance, corrective and preventive action, and data-driven product improvement.
Maintain clinical evaluation throughout the device lifecycle. Article 10 and Article 61 require a clinical evaluation, and Annex XIV expects the clinical evaluation plan, report, evidence, PMCF plan, and PMCF evaluation outputs to support conformity and feed the and risk-management system. For higher-risk routes, record expert-panel or notified-body interactions where they apply.
Keep evidence as procedures, process owners, training records, supplier controls, design-change records, CAPA records, audit outputs, management review inputs, and release gates tied to MDR duties.
Keep clinical evidence with the clinical evaluation plan, literature and investigation strategy, equivalence rationale if used, favourable and unfavourable data, clinical evaluation report updates, PMCF plan, and PMCF evaluation reports.
Link clinical conclusions back to benefit-risk, intended purpose, GSPR claims, warnings, residual risks, and post-market follow-up actions.
Commission guidance index listing clinical investigation, clinical evaluation, PMCF, PMS, vigilance, UDI, and standards guidance relevant to MDR implementation records.
Guidance documents are regularly reviewed
Recommended next step
Build an EU MDR requirements register
Turn MDR scope, classification, GSPR, conformity, QMS, clinical, UDI, EUDAMED, PMS, vigilance, and operator duties into one cited evidence register for product, quality, regulatory, clinical, and engineering teams.
Include UDI work in the requirements register from the start. Article 10 links the manufacturer's to UDI assignment and consistency of information submitted under Article 29. Article 29 requires a Basic UDI-DI before placing devices other than custom-made devices on the market, and Article 31 covers actor registration for manufacturers, authorised representatives, and importers.
Manufacturers must plan, establish, document, implement, maintain, and update for each device in proportion to its risk class and type. The system should proactively collect and review experience from devices on the market; vigilance should capture serious incidents, field safety corrective actions, trend and periodic reporting where applicable, and follow-up with competent authorities, notified bodies, distributors, importers, users, and customers. Feed the results back into the technical documentation and risk file. Since 28 May 2026, four EUDAMED modules are mandatory: Actor, UDI/Devices, Notified Bodies and Certificates, and Market Surveillance. Clinical Investigations and Vigilance/PMS follow separate later milestones.
Maintain Basic UDI-DI, UDI-DI, UDI-PI type, label carrier placement, EMDN, device registration data, EUDAMED submission evidence, and SRN records where applicable.
The Commission UDI/device registration page states that the UDI/Devices module has been mandatory since 28 May 2026. Apply the legal exceptions and legacy-device registration rules rather than assuming every custom-made, investigational, or legacy record follows the standard UDI/device workflow.
Keep plans, PMS reports or PSURs where applicable, PMCF outputs, complaint files, trend analysis, serious-incident assessments, field safety notices, corrective actions, and authority communications connected to the device and Basic UDI-DI.
Commission page supports EUDAMED UDI/device submission expectations, UDI helpdesk context, EMDN, and the 28 May 2026 mandatory-use date for the UDI/Devices module.
manufacturers submit in EUDAMED
5
Section 5
5. Systems and procedure packs
Article 22 assigns the statement to the person who combines CE-marked devices and, where applicable, products that comply with the legislation applying to them. The combination must be compatible with each item's intended purpose and manufacturer instructions. That person must verify mutual compatibility, package the combination, supply the relevant manufacturer information to users, and apply suitable internal monitoring, verification, and validation methods.
The route changes when the combination includes a device without CE marking, uses a device outside its intended purpose, or combines products in a way that is not mutually compatible. The combination is then treated as a device in its own right and the assembler takes on manufacturer obligations, including the applicable Article 52 conformity assessment. A person who sterilises an Article 22 combination follows the specified conformity route only for the sterility aspects unless another fact triggers the full device route.
Procedure-pack producer: keep the constituent-device list, CE and intended-purpose checks, compatibility assessment, packaging and user-information review, signed Article 22 statement, UDI and EUDAMED records, and internal verification approvals.
Sterilisation provider: document the assembler relationship, manufacturer sterilisation instructions, validated process, affected packaging, conformity-assessment scope, notified-body evidence where required, and release records.
Hospital-kit example: a kit of CE-marked devices used within their intended purposes can follow Article 22 only after compatibility and instructions are verified; adding a non-CE-marked instrument or changing a constituent's intended use triggers a device-in-its-own-right review.
Retain the statement for at least 10 years after the last is put together, or 15 years when it contains implantable devices.
Article 22 sets the compatibility, packaging, information, internal-control, sterilisation, conformity-assessment, statement and retention routes for systems and procedure packs.
Systems and procedure packs
6
Section 6
6. Implant cards and patient information
For a covered implantable device, Article 18 requires the manufacturer to provide information that identifies the device, including its name, serial or lot number, UDI, model and manufacturer details. The patient information must also include warnings, precautions, measures for safe interaction with reasonably foreseeable external influences or medical examinations, expected device lifetime and necessary follow-up, and other information needed for safe patient use.
The health institution must make that information available to the patient by a means that allows rapid access and must provide the completed . Sutures, staples, dental fillings, dental braces, tooth crowns, screws, wedges, plates, wires, pins, clips and connectors are excluded from the Article 18 duties unless the Commission changes the list. The implant card remains separate from the instructions for use and the summary of safety and clinical performance.
Manufacturer file: controlled implant-card template, device name and model, serial or lot number, UDI, manufacturer name, website, patient-information version, languages, expected lifetime, follow-up and external-interaction warnings.
Health-institution handoff: record the implanted device identifiers, patient identity entry, delivery date and the durable or digital means used to give the patient rapid access to the information.
Replacement example: when an implant is revised or replaced, preserve the earlier device record and issue information for the device that remains implanted instead of overwriting the patient's history.
Change triggers: new safety warning, changed follow-up schedule, corrected UDI or model information, website migration, translation update, or a Commission change to the exempt-device list.
Article 18 sets manufacturer content, health-institution delivery, patient-access and implant-card requirements and lists implant types excluded from that article.
information to be supplied to the patient with an implanted device
7
Section 7
7. Economic-operator and evidence records
Economic-operator duties depend on role. Manufacturers own design, manufacturing, conformity, technical documentation, , clinical evaluation, , UDI, registration, corrective action, and vigilance obligations. Authorised representatives, importers, and distributors have separate verification, registration, cooperation, traceability, and record-keeping duties that should be assigned in contracts, procedures, and release controls.
A requirements file is useful only if it can be audited. Keep one register that links each obligation to the device, intended purpose, class, role, owner, source article or annex, evidence record, status, approval, review trigger, and unresolved issue. Review it when claims, software functions, design, manufacturing, suppliers, standards, clinical evidence, signals, complaints, incidents, notified-body feedback, or EUDAMED data change.
For authorised representatives, keep mandates, documentation-access arrangements, SRN and registration evidence, authority communications, and checks that the manufacturer has met UDI and device-registration duties.
For importers and distributors, keep verification checks for CE marking, EU declaration of conformity, labelling, instructions, UDI where applicable, registration status, storage and transport conditions, complaint forwarding, and traceability records.
For all roles, retain the records each actor is legally required to keep. Manufacturer files include technical documentation, EU declarations of conformity, certificates, amendments, supplements, and vigilance records, supplier evidence, labels, instructions, EUDAMED records, and decision logs with dated approvals; importer and distributor files are narrower and role-specific.
Commission page sources support the manufacturer's role in checking applicable requirements, technical documentation, declarations, and CE marking before placing products on the EU market.
Article 51 and Annex VIII ground the risk-class structure and classification analysis for MDR devices.
Articles 8, 9, 10, and 52 plus Annexes I, II, and III ground GSPR, standards/common specifications, technical documentation, conformity assessment routes, and the 10-year documentation-retention period extended to 15 years for implantable devices.
Show 5 more
Article 10(9), Article 61, and Annex XIV ground QMS scope, clinical evaluation, clinical evidence, and PMCF requirements.
Articles 27, 29, 31, 83, and 87 ground UDI, device and actor registration, PMS, and vigilance requirements.
Article 22 sets the compatibility, packaging, information, internal-control, sterilisation, conformity-assessment, statement and retention routes for systems and procedure packs.
Article 18 sets manufacturer content, health-institution delivery, patient-access and implant-card requirements and lists implant types excluded from that article.
Articles 10 to 14 and Article 25 ground manufacturer, authorised representative, importer, distributor, and traceability obligations.
"laying down rules concerning the placing on the market"
More quoted passages
"Devices shall be divided into classes I, IIa, IIb and III"
"technical documentation for those devices"
"establish, document, implement, maintain, keep up to date"
"the obligations relating to the UDI system"
"Systems and procedure packs"
"information to be supplied to the patient with an implanted device"
Commission guidance index for MDR guidance on borderline/classification, software, clinical evaluation, PMCF, PMS, vigilance, UDI, EUDAMED, standards, and economic operators.
Commission guidance index listing MDR borderline, classification, and software qualification guidance used to support practical classification records.
Commission guidance index listing clinical investigation, clinical evaluation, PMCF, PMS, vigilance, UDI, and standards guidance relevant to MDR implementation records.
"assist stakeholders in applying"
More quoted passages
"Regulation (EU) 2017/745 on medical devices (MDR)"
Commission page for UDI/device registration in EUDAMED, including manufacturer submission context, UDI helpdesk, EMDN, legacy-device registration links, and the stated 28 May 2026 mandatory-use date for the UDI/Devices module.
Commission page supports EUDAMED UDI/device submission expectations, UDI helpdesk context, EMDN, and the 28 May 2026 mandatory-use date for the UDI/Devices module.
Commission page supports manufacturer responsibility for checking applicable EU requirements, preparing technical documentation, drawing up declarations, and affixing CE marking.
Commission page sources support the manufacturer's role in checking applicable requirements, technical documentation, declarations, and CE marking before placing products on the EU market.