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Is MDR Mandatory? Requirements Explained

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

Direct answer

First determine whether the product and intended use fall within MDR and identify the target market and commercial role. EU medical-device conformity duties follow the applicable scope and route; exemptions or special arrangements need their own assessment. A similar product's CE mark or an ISO 13485 certificate does not establish your device's regulatory status.

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.

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