Knowledge
Deadlines, terms and guides
The basics of EUDAMED device registration, with sources. This information replaces neither legal advice nor an expert review of your specific case.
Device registration deadlines
| Device | Obligation | Deadline |
|---|---|---|
| First unit placed on the market on or after 28 May 2026 | Registration in the UDI/Device module before placing on the market | since 28 May 2026 |
| First unit placed on the market before 28 May 2026, further units after that date. Applies to devices under the MDR and to legacy devices. | Registration in the UDI/Device module | by 28 November 2026 |
| No unit placed on the market since 28 May 2026 | Registration only required if a vigilance or post-market surveillance report requires it | only if a report is due |
| Legacy device, where the same device is already registered under the MDR | No additional registration of the legacy device, with exceptions for certain vigilance reports | as a rule not required |
| Custom-made devices and investigational devices | No registration in the UDI/Device module (for custom-made devices, Article 29(1) MDR) | not applicable |
Legacy devices are not only devices with a legacy certificate
Legacy devices are devices that, under the transitional provisions of Article 120 MDR, continue to be placed on the market on the basis of the former directives (for the term, see MDCG 2021-25). They include devices with a still valid notified body certificate issued under the directives but, under certain conditions, also devices for which a declaration of conformity under the former directive was drawn up before 26 May 2021. Whether a device is a legacy device is for your RA team to determine.
For your specific case, an expert review of the deadlines is advisable. We do not give legal advice.
Sources:
- Commission Decision (EU) 2025/2371, published in the Official Journal on 27 November 2025 (EUR-Lex)
- Regulation (EU) 2024/1860 amending the MDR (EUR-Lex)
- European Commission: EUDAMED overview, modules mandatory since 28 May 2026 (health.ec.europa.eu)
- European Commission: Q&A on the gradual roll-out of EUDAMED, in particular questions 7, 8 and 14 (PDF, health.ec.europa.eu)
- European Commission: timeline for legacy and Regulation devices placed on the market before mandatory use (PDF, health.ec.europa.eu)
Dates from Medregia's fact source, last compared with the European Commission publications listed above on 26 October 2026. This does not replace a legal assessment of your specific case.
Terms used in device registration
- Basic UDI-DI
- The main key of a device in EUDAMED. It groups devices with the same intended purpose, the same risk class and the same essential design and manufacturing characteristics, and does not appear on the device label.
- UDI-DI
- The identifier of a specific device of a manufacturer, for example a variant or pack size. Each UDI-DI belongs to exactly one Basic UDI-DI.
- SRN
- The single registration number of an economic operator in EUDAMED. It is issued with the actor registration and is a prerequisite for device registration.
- EMDN
- The European Medical Device Nomenclature. For registration, the lowest available level counts: the terminal code.
- EUDAMED DI, EUDAMED ID
- Legacy devices are registered with a EUDAMED DI in place of a Basic UDI-DI. The device identifier is a EUDAMED ID or, where available, a UDI-DI.
- Device family
- In Medregia projects, a group of devices with shared details that we record and evidence once. As a rule, one family corresponds to one Basic UDI-DI.
- Record
- The registration data of a single device, as a rule one per UDI-DI.
How expert review, the manufacturer's sign-off, submission and technical acceptance differ
Guides
In-depth articles on individual registration questions. The guides are currently available in German only.
- Zwei Fristen, nicht eine: 28.05.2026 und 28.11.2026 (Document in German)
Which devices have to be registered by when, with official sources.
- EUDAMED-Frist 28.11.2026: Wer muss was bis wann registrieren? (Document in German)
Who has to register what and by when: deadlines, actors concerned and a task list.
- EUDAMED DI und EUDAMED ID: was bei Bestandsprodukten anders ist (Document in German)
What is different for legacy devices: EUDAMED DI and EUDAMED ID.
- Importeur oder Hersteller? Die EUDAMED-Falle bei Eigenmarken (Document in German)
When own-brand suppliers become manufacturers under Article 16 MDR, and what this means for EUDAMED.
- Die häufigsten Fehler bei der EUDAMED-Risikoklassifizierung (Document in German)
Common mistakes in risk classification under Annex VIII MDR and with the EMDN code.
- Artikelliste aus dem ERP exportieren: Der schnellste Weg zum EUDAMED-Überblick (Document in German)
Exporting item master data from Business Central or SAP Business One and checking it for gaps.
Check tools without login
Two small checks for a first impression. They replace neither the project nor an expert review.
Ready-Check: how far along is your device list?
Do you already have a device list as a CSV or Excel file? The Ready-Check recognises selected columns in your list, shows which column was found for each field and checks any EMDN codes given against the stored nomenclature, without AI. The file is discarded after the check. If you do not enter an email address, we store neither the file nor the result.
EUDAMED check: what does EUDAMED currently show about you?
Enter a company name. We query the public EUDAMED database and show which actors are listed under this name and how many devices are publicly visible.
Questions and answers
Why is there no price per product?
The effort depends mainly on the number of device families and variants and on the quality of your documents. Two products with identical details mean less work than two products with details of their own. That is why we review your product list first and then name a binding fixed price for the agreed scope.
Which deadlines apply to registration?
If the first unit of a device is placed on the market on or after 28 May 2026, the device must be registered in EUDAMED beforehand. If the first unit was placed on the market before 28 May 2026 and further units are placed on the market after that date, the deadline is 28 November 2026. This applies to devices under the MDR and to legacy devices, meaning devices still placed on the market on the basis of the former directives under the transitional provisions of Article 120 MDR. Exemptions: custom-made devices and investigational devices are not registered in the UDI/Device module. Devices of which no unit has been placed on the market since 28 May 2026 only need to be registered if a vigilance or post-market surveillance report requires it. A legacy device does not need to be registered additionally if the same device is already registered under the MDR. For your specific case, an expert review is advisable; we do not give legal advice.
How does payment work?
The initial order with one device family is paid before work starts. You know the fixed price beforehand from the proposal. The payment terms for further orders are set out in the respective proposal.
Who carries out the expert review, and who signs off?
The expert review is carried out by your RA team, your consultant or an expert named in the proposal; we agree this with you and record it in the proposal. After the review you give your documented sign-off as the manufacturer. An expert's review verdict does not replace this sign-off. Only then do we submit the data by XML bulk upload in your own EUDAMED account. Software does not replace the expert review. Regulatory responsibility remains with the manufacturer.
What do I receive at the end?
For each device, a prepared record with sources, a completed clarification list, the documented expert review, your documented sign-off and the submission by XML bulk upload in your EUDAMED account. The proposal states the exact deliverables. Technical acceptance by EUDAMED is not regulatory approval by an authority.
What happens to my data?
There are two distinct routes. First, the Ready-Check on medregia.eu: no AI, checked in the Frankfurt am Main server region, and the file is discarded after the check. If you do not enter an email address, we store neither the file nor the result. Second, the file analysis in the customer account: for this we use an AI model via Anthropic's interface. Processing takes place in the USA on the basis of EU standard contractual clauses. Under the provider's contractual terms, your data is not used for training. Account data is held in a database with its storage location in Frankfurt am Main; access by the provider from the USA for operation and support cannot be ruled out. If we process personal data on your behalf, we conclude a data processing agreement before we start. Details are set out in the privacy policy.
Can I start with one device family?
Yes. A limited initial order covers one device family. The fixed price is agreed and paid before we start. You decide on further device families after the initial order.
What happens after registration?
Registration reflects the situation at a point in time. New products, certificate changes or changed details have to be updated in EUDAMED. Whether and to what extent Medregia supports this is agreed separately; it is not part of the initial order.
Clarify scope and way of working in four questions.
The project check gives you initial guidance straight away. Afterwards you can request a project proposal if you wish.
Or write to us directly at kontakt@medregia.eu.