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Frequently Asked Questions About MDR

Adapted: 8 October 2026. Practical guidance reviewed: 15 September 2026.

Direct answer

The practical questions below concern own-brand responsibility, Class I body involvement and clinical evidence. These decisions shape the device's actual MDR route. Compare the answers with intended purpose, design and technical documentation; classification and evidence cannot be established merely by the product's commercial name or a supplier's certificate.

Practical questions for this decision

Who is the manufacturer when a contract-made device is sold under our brand?

Determine how the device is marketed and each party's MDR role. Own-brand supply may create manufacturer duties; assess specific contractual arrangements against the relevant provisions. Clarify technical file access, quality systems and post-market responsibilities. Do not treat the factory's certificate as transferring all your duties.

Is a notified body never needed for a Class I device?

Assess classification alongside sterility, measuring functions and reusable surgical instrument characteristics. Some Class I devices need body involvement limited to specific aspects. Self-declaration routes still require technical documentation and other obligations. Classification should not be determined from the product name alone.

Are publications about a similar device sufficient clinical evidence for ours?

Explain relevance to intended use and technical and biological characteristics. Assess equivalence conditions and data access; use for the same disease alone is insufficient. Develop a device-specific clinical evaluation and additional-data plan. Do not assume clinical investigation is universally required or universally unnecessary.

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