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Two-minute brief

EU IVDR requirements explained: video brief

A two-minute brief on the articles and annexes of Regulation (EU) 2017/746 that shape an IVD manufacturer's programme.

  • Two-minute brief
  • 2 min

Key takeaways

  • Classification under Annex VIII decides the conformity route.
  • Article 10 requires a quality management system proportionate to risk.
  • Performance evaluation covers scientific validity, analytical and clinical performance.
  • UDI and EUDAMED registration provide traceability.
  • Post-market surveillance and vigilance continue for the device's life.

Classification decides the route

The obligations that shape an IVD manufacturer's programme sit in a handful of IVDR articles and annexes. This short film maps them. Annex VIII sets seven classification rules that place each device in class A, B, C or D by intended purpose; the class decides the conformity route and how closely a notified body looks. Blood screening, high-risk transmissible agents and certain blood grouping tests are class D; companion diagnostics, genetic and cancer tests are class C; self-tests are class C except some, such as pregnancy, fertility and cholesterol tests, which are class B; and IVD instruments and specimen receptacles are class A.

Article 10 requires a quality management system proportionate to the risk class and the type of device, covering everything from regulatory strategy and resource management to product realisation, post-market surveillance and corrective action.

Evidence, traceability and post-market duties

Performance evaluation must show scientific validity, analytical performance and clinical performance, documented in a performance evaluation report and kept current through performance follow-up after the device reaches the market. Technical documentation sets out the device description, labelling, design and manufacturing information, the general safety and performance requirements met, the risk management and the verification and validation behind them. Unique device identification and registration in EUDAMED provide traceability, and a person responsible for regulatory compliance is required.

Post-market surveillance, vigilance reporting and periodic safety reporting continue for the life of the device. A notified body designated under the IVDR assesses class B, C and D devices and sterile class A devices; plain class A devices are self-declared. The Regulation has applied since 26 May 2022, with its transition extended by Regulations (EU) 2022/112 and 2024/1860. There is no IVDR certificate as such: the manufacturer signs the declaration of conformity and affixes the CE mark.

An ISO 13485 certificate is the right foundation but not compliance: performance evaluation, UDI, the person responsible for regulatory compliance, vigilance and EUDAMED sit outside it.

EU IVDR 2017/746 at a glance

Purpose
CE marking of in vitro diagnostics for the EU, on performance evidence, a quality system, traceability and post-market follow-up
Relevant to
IVD manufacturers anywhere selling into the EU, their authorised representatives, importers, distributors and suppliers, and health institutions making their own tests
Edition
Regulation (EU) 2017/746, in application since 26 May 2022, with its transition extended by Regulations (EU) 2022/112 and 2024/1860; a simplification proposal of December 2025 still awaits adoption
Certification
No "IVDR certificate" as such. A notified body designated under the IVDR is involved for class B, C and D and sterile class A devices; plain class A is self-declared. The manufacturer signs the declaration of conformity and affixes the CE mark
Sterling's role
Classification, QMS, performance evaluation, technical documentation, PRRC support, UDI and EUDAMED, internal audit and notified body readiness with your team, Effivity, training, then Sustain™
Cost and timing
Total investment for EU IVDR compliance depends on the current maturity of your processes, the scope, locations and number of employees. The process typically takes 6 to 18 months, with the notified body's own review for classes B, C and D on top

EU IVDR 2017/746: the complete guide →

EU IVDR 2017/746: questions people ask

Is there such a thing as EU IVDR certification?

Not in the sense of an ISO certificate. What the market requires is the CE mark, which the manufacturer affixes under its own EU declaration of conformity. For every class except plain class A, a notified body takes part and issues the certificates that declaration relies on. An "IVDR certificate" sold by a consultant or a management-system certification body is not one of them.

Which IVDs need a notified body under the IVDR?

All class B, C and D devices, and class A devices placed on the market sterile. Plain class A devices, such as IVD instruments, specimen receptacles and certain general laboratory products, are self-declared. The class comes from the seven Annex VIII rules applied to the intended purpose, and deciding it is the manufacturer's responsibility.

Does our ISO 13485 certificate make us IVDR compliant?

No, although it is the right foundation. EN ISO 13485:2016 with A11:2021 was harmonised under the IVDR in 2022, which gives a presumption of conformity only for the requirements it addresses. Performance evaluation and PMPF, UDI, the PRRC, PSURs, vigilance reporting and EUDAMED sit outside it. Its certificate is issued under accreditation, not under a notified body designation.

What are the legacy deadlines for IVDs?

Under Regulation (EU) 2024/1860, devices covered by a Directive 98/79/EC certificate and class D devices may stay on the market until 31 December 2027, class C devices until 31 December 2028, and class B and sterile class A devices until 31 December 2029. The conditions: continued compliance with the Directive, no significant change in design or intended purpose, no unacceptable risk, an Article 10(8) quality management system by 26 May 2025, an application by 26 May 2025 (certificate holders and class D), 26 May 2026 (class C) or 26 May 2027 (class B and sterile class A), and a written agreement with the notified body by 26 September of that year. IVDR surveillance, vigilance and registration rules already apply, and the sell-off date has gone.

How are class D devices treated differently?

They receive the closest scrutiny. Where the Commission has designated an EU reference laboratory for the device category, it verifies the performance claimed and tests batches; the first laboratories, designated by Implementing Regulation (EU) 2023/2713, took up these tasks on 1 October 2024 for markers of hepatitis and retrovirus, herpesvirus, bacterial and respiratory virus infections. Without a designated laboratory, notified bodies may still certify. Experts are consulted for a first-of-type device with no common specifications, and each batch is released through the notified body.

More EU IVDR 2017/746 questions and answers →

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