Two-minute brief
EU MDR requirements explained: video brief
A two-minute brief on the articles and annexes of Regulation (EU) 2017/745 that shape a medical device manufacturer's programme.
Key takeaways
- Annex VIII has twenty-two classification rules.
- The QMS must cover at least thirteen aspects listed in Article 10.
- Clinical evaluation shows the general safety and performance requirements are met.
- UDI and EUDAMED registration provide traceability.
- Post-market surveillance and vigilance continue for the device's life.
Classification and the quality management system
The Medical Device Regulation runs to 123 articles and seventeen annexes, but the obligations that shape a manufacturer's programme sit in about a dozen of them. This short film maps them. Annex VIII classifies each device as class I, IIa, IIb or III under twenty-two rules, by intended purpose and inherent risk; the class fixes the conformity route and whether a notified body is involved. Plain class I devices self-declare, while sterile, measuring and reusable surgical class I devices need a notified body.
Article 10 and Annex IX require the manufacturer to establish, implement, maintain and continually improve a quality management system covering at least thirteen aspects, from the regulatory compliance strategy and resource management to product realisation, post-market surveillance, vigilance and corrective and preventive action.
Evidence, traceability and life after launch
Clinical evaluation must show, with sufficient clinical evidence, that each device meets the general safety and performance requirements and the evaluation is updated throughout the device's life on the market. Technical documentation sets out the device, its labelling, design and manufacture, the requirements met, risk management and verification and validation. Traceability comes from unique device identification and EUDAMED registration, and the manufacturer names a person responsible for regulatory compliance.
After launch, post-market surveillance, vigilance reporting and periodic safety update reports or post-market surveillance reports continue for the life of the device. The Regulation has applied since 26 May 2021 and has been amended by later regulations extending transition periods. A notified body designated for the MDR assesses devices above plain class I, and the manufacturer signs the EU declaration of conformity and affixes the CE mark; there is no MDR certificate as such.
Every manufacturer needs at least one person responsible for regulatory compliance with the qualifications in Article 15; micro and small enterprises may have one permanently at their disposal rather than employ them. Notified bodies are listed with their scopes in the Commission's NANDO database. An ISO 13485 certificate gives a presumption of conformity only for the requirements it covers, not for UDI, vigilance or EUDAMED.
EU MDR 2017/745 at a glance
- Purpose
- CE marking of medical devices for the EU market, backed by a quality management system, assessed technical documentation, traceability and post-market surveillance
- Relevant to
- Legal manufacturers anywhere in the world placing devices on the EU market, their authorised representatives, importers and distributors, and their suppliers
- Edition
- Regulation (EU) 2017/745, applicable since 26 May 2021, as amended by Regulations (EU) 2020/561, 2023/607 and 2024/1860; the Commission's simplification proposal of 16 December 2025 is not yet law
- Certification
- No "MDR certificate" as such. A notified body designated by an EU Member State assesses the QMS and technical documentation above basic class I; the manufacturer signs the EU declaration of conformity and affixes the CE mark
- Sterling's role
- QMS, 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 MDR compliance depends on the current maturity of your processes, the scope, locations and number of employees. The process typically takes 9 to 18 months, before the notified body's review
EU MDR 2017/745: questions people ask
Is there such a thing as EU MDR certification?
Not in the way ISO certification exists. The outcome is the CE mark, affixed by the manufacturer under its own EU declaration of conformity. Where a notified body is involved it issues the EU certificates listed in Annex XII. An "MDR certificate" from a consultant or a certification body is not one of them.
Does our ISO 13485 certificate make us MDR compliant?
No. EN ISO 13485:2016 with A11:2021 is harmonised under the MDR, so conformity gives a presumption of conformity for the requirements it covers. It does not cover the regulatory strategy, the Annex I requirements, UDI, the PRRC, PSURs, vigilance timelines or EUDAMED, and it is certified by an accredited certification body, not a notified body.
Which devices need a notified body?
Every class IIa, IIb and III device, and class I devices placed on the market sterile, with a measuring function or as reusable surgical instruments, for those aspects. Only plain class I devices are self-declared. Classification under Annex VIII is the manufacturer's responsibility; get it wrong and the whole route is wrong.
What is a notified body, and how do we choose one?
A conformity assessment body designated by an EU Member State to audit quality systems and assess technical documentation under the MDR; the designated bodies and their scopes are listed in the Commission's NANDO database. Choose one whose scope covers your device codes and whose capacity matches your deadline. Sterling is not a notified body.
Do we need a person responsible for regulatory compliance, and can it be outsourced?
Every manufacturer needs at least one PRRC with the Article 15 qualifications. Micro and small enterprises need not employ the person but must have one permanently and continuously at their disposal. Whoever holds the role signs off release, documentation, surveillance and vigilance, so the arrangement has to be real.
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