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EU IVDR Transition Update 2024

IVDR Transitional Provisions – Something had to give!

On the 23 April 2024, the European Parliament unanimously approved the proposal to amend the EU MDR (2017/745) and IVDR (2017/746) regarding the gradual roll out of Eudamed, information obligation in case of interruption of supply and the transitional arrangements for certain in vitro diagnostic medical devices (IVDs).

The amendment has been requested by industry to ensure continued access to critical diagnostic products, essential for a smooth running European healthcare system, and offering a hight level of protection to patients and users of diagnostic tests.

Why was change needed?

The IVDR has applied for placing IVDs onto the EU market since 26 May 2022, replacing the existing IVD Directive 98/79/EC, this required that all devices, including legacy devices, must meet a higher level of regulatory compliance. In January 2022, the European Parliament and Council adopted an extension to the transitional arrangement, with extended timelines based on the risk classification of devices:

Risk ClassCurrent deadlines for compliance
Class D (Highest Risk)26 May 2025
Class C26 May 2026
Class B, Class A Sterile26 May 2027
New devices, Class A (Lowest Risk)26 May 2022 (No extension)
Devices used in Healthcare Institution26 May 2028

The original transitional extension was intended to ease the pressure on implementation issues and delay experienced with infrastructure (including Eudamed), Notified Body availability and manufacturing readiness, all of which were impacted by the Covid-19 outbreak.

While the transitions had allowed some breathing space, the industry is facing an uphill struggle to be ready to meet these dates.

What is changing?

  1. Further transitional extension for some devices

With the exception of legacy devices that do not require conformity assessment (Class A and devices used on Healthcare Institutions), additional time is being added to the transition time for IVDR, and existing devices can continue to be placed on the EU market until the following dates:

Risk ClassCurrent deadlines for compliance
Class D31 December 2027
Class C31 December 2028
Class B, Class A Sterile31 December 2029

To use these timelines however, manufacturers must comply with certain conditions including:

  • The devices are CE marked under the IVD Directive,
  • There are no significant changes to the design or intended purpose,
  • A Quality Management System compliant to IVDR shall be put in place by 26 May 2026,
  • A formal application shall be lodged with a notified body 2 years prior to the dates above.

2. Bringing forward the mandatory use of Eudamed

The Eudamed database includes seven electronic elements including UDI, Vigilance and Market Surveillance. The earlier mandatory use of some Eudamed module would offer an enhanced adoption for this critical element of IVDR deployment.

3. Prior notice if supply of IVD is stopped

To reduce the risk of device shortages, the proposal includes a requirement whereby Manufacturers are required to inform their relevant competent authority and health institutions if there is a temporary, or permanent interruption in the supply of their IVDs, especially if there are few or no alternative products, or where there is a risk of serious harm to patients or public health.

How will this impact industry readiness to IVDR?

The proposal offers a short term solutions for the current state of readiness in the industry for IVDR, especially for Class D devices, which often include low volume, but highly critical diagnostics which were at risk of not meeting IVDR compliance before the deadline of May 2025.

The proposal also encourages an increased usage of Eudamed, which has seen low adoption (caused in part by the delays to each module) by manufacturers within the UDI and Devices module.

In a wider sense, the commission is trying to mitigate the risk of supply shortages as a result of the IVDR transition, although it is currently up to the manufacturer to determine the severity of risk to supply for their products.

Don’t delay

The proposal allows a collective sigh of relief, allowing the industry more time to prepare the technical documentation and engage with a notified body. However in reality, the additional timelines do not offer time to pause. The additional 2 year delay allows the completion of the conformity assessment process, it does not provide any further time for getting the QMS ready for the IVDR. The amendment also allows manufacturers to also ensure their clinical evidence is compliant as we know that legacy devices require additional performance testing before they are IVDR compliant.

In the long term it remains to be seen how significant this amendment will elevate the challenges facing the industry as they transition from IVDD to IVDR. It remains to be seen to what extent the industry will be ready in another 2 years time.

While this should be seen as a positive, we would encourage Manufacturers to press forward with their IVDR transition planning now. For more information on how IVDeology have supported our customers achieve IVDR compliance, contact [email protected].

Note: This blog contains a summary of the key changes within the proposal, it is important that Manufacturers read and understood the proposal in full, and get independent legal advice if required.

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Notified Bodies Survey on certifications and applications (MDR/IVDR)

Last week saw the revised version of the Notified Bodies Survey on certifications and applications (MDR/IVDR) published by the European Commission. [Survey NBs availability (]

While there are still no conclusions made from the results of the survey, it does offer a useful insight on the current state of play for the transition to the MDR for medical devices and IVDR for in-vitro diagnostics.

The challenges the industry has faced to achieve compliance to the new regulations has been widely discussed [refer to previous blogs], resulting in continued delays to the implementation of the regulations, based largely on the state of readiness of the regulatory infrastructure of the EU system.

The regulation has been designed “to ensure the smooth functioning of the internal market as regards in vitro diagnostic medical devices, taking as a base a high level of protection of health for patients and users, and taking into account the small and medium-sized enterprises that are active in this sector.”

From <>

 In reality, the challenge for SMEs to comply to the new IVDR is great, given the additional data burden, time, and money required to obtain a CE mark. I have often wondered if the EU market is a step too far as a 1st launch country for SMEs, over the opportunity of US market access – and the UK (if the regulators can identify a pragmatic approach under IDAP).

It is therefore an interest to see the graph shown in the report:

The survey highlighted that the NB have SMEs as their main clients for conformity assessment, this is a positive message in that SMEs are still preparing for IVDR compliance, and it will be interesting to see how the implementation of IVDR is achieved for small and medium size businesses.

Here at IVDeology, an immediate question that came from the information above is that the definition of SME encompasses a large number of organisations but internally the teams can vary in size, and the ones we commonly work with here at IVDeology would be at the lower end of the scale. It would be good to know the spread of size of SME’s out there so that we can understand the landscape and dynamic of those hoping to grow.

IVDeology works throughout the whole IVD industry, including supporting SMEs along their path to compliance. For further information on how we can support you, contact [email protected]

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MHRA update for future MDR and IVDR

The MHRA held a webinar on March 5th to give an insight into the plans for the future UK regulations for medical devices and IVDs.

The key points for IVDs they made are:

· The definition of IVD will be extended to mirror the definition in the IVDR.

· Devices will be classified into 4 groups, A-D, using a risk based approach. Device classification will follow the IMDRF guidance N64 document – Principles of In Vitro Diagnostic (IVD) Medical Devices Classification, with a couple of UK specifics:

o Devices which monitor infectious loads of life-threatening infectious diseases will be classified as Class D

o Devices with the intended purpose for screening, detecting or diagnosing either neurodegenerative diseases or cardio vascular diseases will be classified as Class C.

Accessories, Independent Software and Companion diagnostics will be classified in their own right. Software that drives a device, calibrators and controls will be classified in the same group as the associated device.

· The Essential Requirements will be updated to generally align with the GSPR under IVDR with differences to reflect the UK specific legislation & national bodies.

o This includes alignment for the requirements for labelling and instructions for use.

The take home message we took away was that they are trying to harmonise with the IMDRF model and the EU IVDR wherever possible to try and reduce the burden on manufacturers whilst still ensuring that the devices on the GB market are safe and effective for users and patients.

Whilst this is good news for manufacturers as a whole and for many they may see very little difference between the UK and EU regulations. However for other manufacturers their devices may end up being classified differently in each regulation. What potential challenges may these differences in classification cause?

As the essential requirements will align, the impact for the technical file will hopefully be minimal. And following the IMDRF model may have advantages too – aligning with other key markets such as Canada and Australia. However differing classifications may have an impact on Post Market Surveillance and whether a PMS report or a Periodic Safety Update Report is required. It may also give notified bodies/UK approved bodies more work as they will have to consider how the differences in classification impact their role. What may the impact on market access be if we diverge from the EU when we know our market are closely linked? We would love to hear some thoughts.

Written by Fiona Thompson – RA specialist at IVDeology

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Updated classification for SARS CoV-2

Recently we saw Team-NB release a Position Paper on the Classification of devices intended to detect SARS-CoV-2. There has been a lot of discussion about whether SARS-CoV-2 IVDs should remain classified as a Class D under the requirement of detecting a transmissible agent that causes a life-threatening disease with a high or suspected high risk of propagation. The Team-NB Position Paper is that this classification should be re-assessed based on the facts that there are effective vaccines available, currently no circulating variants of concerns and evidence that the current circulating variants within the EU indicate no increased impact on immunity or severity for the general population.

There are two possible re-classification routes that are suggested:

· Class B – under rule 6 – devices not covered by the other classification rules.

· Class C – under rule 3c – devices where there is a significant risk that an erroneous result would cause death or severe disability to the individual, foetus or embryo being tested, or to the individual’s offspring.

Team-NB’s position is that Class C should be recommended due to the potential remaining risk for vulnerable populations and the limited data available for the post-pandemic phase. This would also ensure that stricter PMS & Performance Evaluation/Clinical Evidence requirements are applied for these devices.

This could be welcome news to manufacturers of these devices. We will need to see if this leads to a change in the MDCG guidance – watch this space!


Written by Fiona Thompson – Regulatory specialist at IVDeology