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30 Jun 2026

The European Union’s Long-awaited Rollout of the European Database on Medical Devices Enters a Critical New Phase

Beginning May 28, 2026, mandatory use of key European Database on Medical Devices (EUDAMED) modules officially took effect under the EU Medical Device Regulation (MDR) and In Vitro Diagnostic Regulation (IVDR). For manufacturers, authorized representatives, importers, and notified bodies, the deadline marked a major compliance milestone that will directly impact market access across Europe.

EUDAMED was designed to strengthen transparency, traceability, and regulatory oversight within the European medical device market. While the system has been introduced gradually over several years, the European Commission has now confirmed functionality for the first four core modules, triggering legally enforceable obligations. Companies that fail to prepare risk delays in product placement, compliance gaps, and increased scrutiny from regulators.

The first major deadline arrived on May 28, 2026, when mandatory use officially begins. From that date forward, all new MDR and IVDR devices must be registered in the UDI/Device Registration module before they can be placed on the European market. Manufacturers must ensure their Basic UDI-DI information, device records, and associated data are accurately uploaded and maintained within EUDAMED prior to commercialization.

A second important milestone will arrive six months later, on November 28, 2026. This deadline applies to legacy devices that were already CE marked and available on the market before May 28, 2026. These products must also be registered in EUDAMED, creating a substantial administrative workload for companies managing broad portfolios or older product lines. Organizations should begin reviewing existing device data now to avoid bottlenecks as the deadline approaches.

Another key compliance requirement impacts notified bodies. By May 28, 2027, notified bodies must complete the upload of relevant legacy certificate information into EUDAMED. The European Commission has effectively provided an 18-month grace period for this activity, recognizing the complexity and scale of historical certificate migration. Nevertheless, manufacturers should coordinate closely with their notified bodies to ensure certificate records remain accurate and aligned across systems.

The mandatory obligations currently apply to four fully functional EUDAMED modules. These include Actor Registration, which enables economic operators to obtain a Single Registration Number (SRN); UDI & Device Registration, which manages product and UDI data; Notified Bodies & Certificates, which tracks certificates and conformity assessments; and Market Surveillance, which supports regulatory cooperation and post-market oversight. Together, these modules create the foundation for a more connected and transparent European regulatory framework.

Two additional modules, Vigilance and Clinical Investigation & Performance Studies, are still pending full mandatory implementation. While these modules are already available in varying capacities, the European Commission has not yet issued formal notices confirming their full functionality. As a result, legally binding activation dates for these components have not yet been established. Industry stakeholders should continue monitoring regulatory updates, as future implementation timelines are expected to follow once readiness is confirmed.

For medical device companies, the message is clear: preparation can no longer be postponed. Successful EUDAMED compliance will require coordinated efforts across regulatory affairs, quality assurance, IT, supply chain, and commercialization teams. Organizations should begin validating SRN registrations, reviewing UDI data structures, aligning technical documentation, and conducting internal readiness assessments well ahead of the 2026 deadlines.

Companies that proactively prepare now will be in a far stronger position to maintain uninterrupted access to the European market as EUDAMED enters its mandatory era.

Headshot of Clarissa Benfield
Clarissa Benfield

Global Director and Business Leader, Medical, Laboratory, and Life Safety & Security

With 15 years of experience supporting the Assurance, Testing, Inspection, and Certification industry, Clarissa is dedicated to Intertek’s mission of bringing quality, safety, and sustainability to life. As a leader in the medical and laboratory space, she is passionate about working with manufacturers bringing innovative technologies and life-altering products to market.  

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