Sell medical devices in the EU from Saudi Arabia · MDR / IVDR Article 11

EU Authorized Representative for Saudi manufacturers.

Our name goes on the label only after your file stands up to review.

A manufacturer established in Saudi Arabia is outside the European Union for MDR and IVDR purposes. MEDDEV reviews the available home-market evidence, defines the EU file and accepts the Article 11 mandate only when the documentation and liability criteria are met.

For Saudi medical-device and IVD manufacturers preparing EU market entry, transferring an existing mandate or coordinating EUDAMED responsibilities.

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Established in the European UnionWarsaw, Poland · EC REP under MDR and IVDR Article 11
Online intake Secure connection

Apply for MEDDEV mandate review

A short, three-step intake. We confirm eligibility, define the review scope and decide whether to proceed.

Step 1 of 3 · Manufacturer

No document upload at this stage · reply usually the same working day · in English

Confidential files are handled separately through one-time access, private EU storage and automatic deletion after expiry. Review our security and data handling controls.

MEDDEV brand serving medical-device companies since 2012 MDR 2017/745 & IVDR 2017/746 Mandate accepted only after review
Manufacturers who have worked with MEDDEV
CHM Sp. z o.o.MDD Sp. z o.o.WDI Wise Device EuropeGlobal Pharma CMSensiMedUSP ZdrowieAdamed Consumer HealthcarePiórex S.A.
Saudi Arabia → European Union

The dossier behind the MDMA travels better than the MDMA itself.

Saudi manufacturers arrive with a marketing authorization built under the Medical Devices Law: registration with the SFDA through the GHAD system and a Medical Device Marketing Authorization for the authorized device grouping. Since the beginning of 2021 the SFDA no longer accepts applications based on approvals from other jurisdictions, so an MDMA applied for after that date is supported by the manufacturer’s own technical documentation against the Essential Principles of safety and performance. That is a real starting position for the EU route — the work is mapping the dossier to MDR or IVDR, not writing one from zero.

The MDMA is a Saudi authorization, not an EU conformity decision

Under SFDA requirements a medical device may be made available in the KSA only if it is registered at the SFDA and a Medical Device Marketing Authorization has been obtained, with applications submitted through the GHAD system. The MDMA evidences Saudi market status. The EU requires its own conformity assessment under MDR or IVDR, with obligations placed on the legal manufacturer.

The reliance route closed in 2021 — and that works in your favour

The SFDA announced that 1 January 2021 was the last day for accepting marketing-authorization applications via the GHTF route, which had relied on approvals from founding GHTF jurisdictions. An MDMA applied for after that closure therefore rests on the manufacturer’s own technical documentation: an Essential Principles checklist, a risk management file and clinical or performance evidence. An authorization that still traces back to a pre-2021 GHTF application is a different starting point, which is why we ask about the original basis. Where the file is the manufacturer’s own, much of its substance can be reused for the EU route — the structure and the legal tests are what change.

Saudi classes are not MDR classes

The SFDA classifies medical devices as Class A, B, C and D, with sub-categories for sterile Class A devices, those with a measuring function and reusable surgical instruments, under twenty-two classification rules for devices other than IVDs; in vitro diagnostics have their own, separate set of classification rules. The vocabulary is close to the EU’s, and the SFDA describes its annexes as harmonized with international regulatory requirements, but the EU classification is argued from the MDR or IVDR rules and the intended purpose as it will be worded for the Union market — not read across from the Saudi class.

Official basis: SFDA MDS-REQ 1: requirements for medical devices marketing authorization, SFDA: closure of the GHTF marketing-authorization route, European Commission: authorised representatives, MDR Article 11, European Commission: EUDAMED UDI/Device registration.

Local review focus

What usually needs attention for Saudi Arabia manufacturers.

For Saudi manufacturers, SFDA records and local-market documentation may support the assessment, while the EU route remains separate. The mandate review focuses on the legal manufacturer, intended purpose, product-liability arrangements and the evidence needed for European importers and authorities.

Qualification file

What to prepare for the first EU review.

The initial website form contains no document upload. After the parties and scope are confirmed, MEDDEV provides a controlled transfer route for the records below.

  1. 01

    SFDA establishment registration and licence details from the GHAD system, and the legal-manufacturer identity for the proposed EU portfolio.

  2. 02

    MDMA certificates with their authorized scope and grouping, plus the application route and date — an authorization issued via the pre-2021 GHTF route may rest on another jurisdiction’s approval rather than on a full in-house file.

  3. 03

    The technical documentation behind the MDMA: Essential Principles checklist, risk management file, clinical or performance evidence and the quality-system certificate to SFDA.MD/GSO ISO 13485 or its equivalent.

  4. 04

    Intended purpose as it will be worded for the EU market, with the MDR or IVDR classification rationale built from the Union rules.

Typical transition gaps

Issues to resolve before the mandate starts.

The Saudi AR read as an EC REP

Saudi manufacturers know the authorized-representative institution from their own system: a foreign manufacturer selling into the KSA appoints an SFDA-licensed representative resident in the Kingdom, licensed separately for each manufacturer it represents. The EU role under Article 11 of the MDR and IVDR is the mirror image — same words, different law. An SFDA licence carries no weight in the Union, and the EU mandate, vigilance duties and EUDAMED responsibilities have to be established on EU terms.

Authorization mistaken for conformity

The records behind an MDMA can reduce duplicated work, subject to their completeness and their conformity with MDR or IVDR requirements. The authorization itself does not demonstrate conformity with the general safety and performance requirements and does not replace conformity assessment, CE marking, the EU declaration of conformity or, where required, notified-body involvement.

Class mapped across, not re-derived

Treating a Class B device as “the same as” a particular MDR class skips the step that determines the conformity route, the evidence expected and whether a notified body is involved. The EU class is derived from the Union rules each time.

EUDAMED is no longer a future obligation

Four modules — actor registration, UDI/Devices, notified bodies and certificates, and market surveillance — have been mandatory since 28 May 2026 under Commission Decision (EU) 2025/2371 and Regulation (EU) 2024/1860. For devices placed on the market earlier and still being placed on the market, Regulation (EU) 2024/1860 allows no later than twelve months from publication of the Commission notice, which was published on 27 November 2025. Registration data therefore belongs in the market-entry plan, not after it.

Financial coverage: what the law says, and what we ask for

MDR Article 10(16) — mirrored for in vitro diagnostics by IVDR Article 10(15) — requires manufacturers to have measures in place providing sufficient financial coverage for potential liability under Directive 85/374/EEC, in a manner proportionate to the risk class, type of device and size of the enterprise. It does not prescribe a particular insurance policy. MEDDEV asks to see those measures because Article 11(5) makes the authorised representative legally liable for defective devices on the same basis as, and jointly and severally with, a manufacturer that has not met its Article 10 obligations. Reviewing the arrangement is our acceptance condition, and that provision is why.

Country-specific route

From home-market records to EU representation.

01

Trace each MDMA to its basis

Establish, per authorization, when it was issued and on what documentation — an own-file MDMA and a pre-2021 reliance MDMA set up very different EU projects.

02

Map the dossier to the Union rules

Set the MDR or IVDR classification and conformity route independently, then record which parts of the Saudi technical file meet the EU requirements and which items remain open.

03

Close the gap list

Complete the technical file review, agree the registration data and coordinate the mandate, labelling and EUDAMED work against the confirmed entity and scope.

Check this portfolio →
Questions from Saudi Arabia

What manufacturers ask before appointment.

Does an SFDA marketing authorization help with CE marking?

It helps as evidence, not as a route. An MDMA applied for after the GHTF route closed in 2021 is supported by the manufacturer’s own technical documentation against the SFDA’s Essential Principles, and much of that substance — risk file, bench and clinical or performance evidence, quality-system records — can be reused where it meets MDR or IVDR requirements. The authorization itself is a Saudi decision and does not transfer.

We appoint an authorized representative for foreign suppliers in the KSA. Is the EU role the same?

It is the same idea pointing the other way, under different law. In the Saudi system the AR is licensed by the SFDA, resident in the Kingdom and licensed per manufacturer. In the EU the authorised representative is designated under Article 11 of the MDR or IVDR, with statutory duties and liability conditions defined by the Regulation. Neither appointment substitutes for the other.

Do SFDA classes A to D carry into the EU?

No. The systems use similar language and similar risk logic, but the rules differ and the EU class follows from the MDR or IVDR classification rules applied to the intended purpose as worded for the Union market. The class determines the conformity route, so it is re-derived rather than translated.

Does every manufacturer from this country need an EC REP?

Article 11(1) of the MDR and IVDR states that where the manufacturer of a device is not established in a Member State, the device may only be placed on the Union market if the manufacturer designates a sole authorised representative. MDCG 2022-16 explains what “sole” means in practice: across a portfolio a manufacturer can have more than one authorised representative where the devices fall under different generic device groups, but for any one generic device group only one. It is a condition of placing the device on the market, not a formality afterwards.

What is reviewed before the mandate?

MEDDEV reviews the legal manufacturer, device identity, classification, conformity route, technical-documentation index, insurance, vigilance arrangements and sanctions screening.

Can documents be sent through the first contact form?

No. The form is for qualification only. A controlled document-transfer route is provided after scope and parties are confirmed.

Post-project client survey

Post-project ratings from real regulatory work.

56published post-project ratings
97%marked MEDDEV “recommended”
5/5 across five criteria WDI Wise Device Europe Readiness audit · 2015
5/5 across five criteria SensiMed Medical device notification · 2015
5/5 across five criteria Piórex S.A. Medical device registration · 2015

Historical MEDDEV post-project survey across regulatory services. Clients rated knowledge transfer, consultant engagement, subject-matter preparation, problem solving and overall service. The individual ratings shown here are from 2015; the summary figures cover the published set from that survey programme. Comments were optional, so most ratings carry none — and no quotation has been reconstructed or written on a client’s behalf.

Acceptance is earned, not purchased

Not every mandate is accepted.

MEDDEV accepts only defined device scopes supported by evidence, working safety controls and a manufacturer we can rely on. A commercial enquiry never guarantees appointment. Our name appears on the label only after the acceptance review is complete.

MEDDEV mandate reviewAcceptance gate
Manufacturer, device and intended purposeAcceptance criterion
Conformity route and regulatory evidenceAcceptance criterion
Safety, post-market and vigilance controlsAcceptance criterion
Communication, response and liability arrangementsAcceptance criterion
Outcome: mandate accepted, conditions issued or mandate declined.
Example of the MEDDEV Mandate Accepted mark displayed on a medical-device manufacturer's website
Example on a manufacturer website. The issued mark should link to the active MEDDEV mandate and its defined device scope.
A status worth displaying

Turn regulatory acceptance into a visible trust signal.

Accepted manufacturers may use the mark where professional buyers assess regulatory readiness. Each use must remain connected to the active MEDDEV mandate and its defined device scope.

  • Manufacturer websiteAlongside EU market-access information and the represented device portfolio.
  • Product catalogueOn pages covering devices included in the accepted mandate.
  • Distributor dossierAs a verifiable representation status during onboarding and due diligence.
  • Sales presentationFor procurement, partner meetings and trade-fair communication.

Use boundary: the mark must not appear as a CE mark, product certificate or safety approval. It should not be added to the regulated device label, instructions for use or sterile-packaging information panel.

Before you enquire

Know what shapes the review and the fee.

We do not publish a one-size-fits-all price because the mandate depends on the device, portfolio and level of responsibility. The initial review identifies the scope before a fee is proposed.

Device and portfolio

Classification, IVD or medical device route, number of families, intended purpose and higher-risk features.

Evidence readiness

Technical documentation, clinical or performance evidence, quality-system records, certificates and labelling.

Ongoing responsibility

EUDAMED coordination, vigilance, authority response, importer interface, PRRC support and required review depth.

Fee principle: after the qualification review, we provide a defined scope and a proposal matched to the accepted mandate. No document upload is required in the first contact form.

01

Legal manufacturer

Confirm the entity, country of establishment, device family and intended EU market.

02

Core evidence

Have the classification rationale, technical-file index, conformity route and quality evidence available.

03

Post-market readiness

Identify complaint, vigilance, field-safety and authority-response owners before the mandate begins.

Check your EC REP readiness →
Typical review scenarios

The questions we resolve before a mandate starts.

These anonymised composite scenarios reflect recurring qualification patterns. They are not attributed client case studies or performance claims; the exact scope and outcome depend on the manufacturer and device file.

01

New EU launch

Problem: home-market approval is mistaken for EU access. Work: map MDR/IVDR, labelling, EUDAMED and importer responsibilities. Typical result: a defined launch route and a documented list of open evidence.

02

Change of EC REP

Problem: the outgoing representative controls records and dates are unclear. Work: plan custody, vigilance ownership and handover steps. Typical result: a controlled transition with responsibilities recorded before the new mandate starts.

03

Higher-risk review

Problem: a Class IIb, Class III or complex IVD portfolio has unresolved evidence or liability gaps. Work: enhanced file and response-readiness review. Typical result: accept, request defined evidence, or decline before exposure is created.

Regulatory briefings

The obligations manufacturers outside the Union ask about most.

Each briefing states the provision it relies on and links to the official text. They are written for companies deciding whether, and in what order, to enter the European market.

EUDAMED · Article 123(3)

Device data falls due on 27 November 2026.

Four modules became mandatory on 28 May 2026. The twelve-month obligation does not cover every device, and the wording decides which.

Read the EUDAMED briefing →
Cyber Resilience Act

Reporting duties start on 11 September 2026.

Products covered by the MDR are excluded. Companion software without a medical purpose, portals and service tools are not.

Read the cybersecurity briefing →
Article 10a MDR

Withdrawing a device now takes six months of notice.

The notice goes to the authority of the Member State where the manufacturer or its authorised representative is established.

Read the supply briefing →
Manufacturers outside the EU

Not every part of a domestic file has to be rebuilt.

What transfers into a European file, what has no equivalent at home, and where a representative is required by law.

Open the compliance hub →
Published acceptance criteria

Six tests every device scope must pass.

Priority goes to complete, traceable applications with a named regulatory owner. Meeting the entry criteria qualifies a scope for a decision; it does not guarantee acceptance.

  1. 01

    Verified legal manufacturer and scope

    The legal entity, authorised signatory, manufacturing sites, device families, models and intended purposes are consistent and traceable.

  2. 02

    Defensible EU regulatory route

    The qualification, classification and conformity-assessment route are documented, with valid notified-body involvement where required.

  3. 03

    Controlled regulatory evidence

    The EU declaration, agreed technical-documentation index, certificates, labelling and registration data describe the same device scope.

  4. 04

    Working safety and post-market controls

    Risk management, surveillance, complaints, vigilance, recalls and corrective actions have current records, owners and escalation routes.

  5. 05

    Responsive manufacturer relationship

    Named decision-makers can provide records, samples and technical answers and can act within agreed authority-response times.

  6. 06

    Liability and continuity secured

    Insurance, contractual responsibility, document access, sanctions screening, change notification and mandate continuity are acceptable.

What the status means: “MEDDEV Mandate Accepted” confirms MEDDEV’s written acceptance of an EC REP mandate for the defined device scope. It is a trust signal about regulatory readiness and the manufacturer relationship. It is not a CE certificate, product approval, independent safety claim or substitute for the applicable conformity assessment.

Present my device scope →
Meet MEDDEV in your own time zone. Live reference times for manufacturer markets. MEDDEV’s registered office is in Warsaw.
Request a 30-minute online meeting
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The people behind your mandate

Director-level governance. Named specialists for regulatory execution.

Mikołaj Junosza-Szaniawski leads mandate governance, risk oversight and international delivery. Marta Junosza-Szaniawska and Barbara Jęcka-Izdebska remain the named specialists for conformity assessment, registration and ongoing regulatory coordination.

MEDDEV Compliance sp. z o.o. · Warsaw, European Union ul. Mydlarska 47, 04-690 Warszawa, Poland biuro@meddev.pl
Check my eligibility →
Mikołaj Junosza-Szaniawski, Managing Director of MEDDEV EC REP operations and governance

Mikołaj Junosza-Szaniawski

Managing Director · EC REP Operations & Governance

Mikołaj brings more than 25 years of experience at KPMG, including as a Director in Audit Assurance, where he oversaw major sustainability-reporting assurance projects. He combines international project governance with a product-life-cycle perspective encompassing LCA, reuse, recyclability and environmental performance. At MEDDEV, he oversees mandate governance, risk escalation, specialist assignment and continuity of manufacturer communication.

25+ years at KPMG Director, Audit Assurance MBA · Carlson School of Management Specialist LCA training · MIT ESG lecturer · Kozminski University Programme manager · EPD Polska
One accountable contact, specialist depth when the device requires it.

The manufacturer does not need to coordinate a loose group of advisers. The named coordinators define the review scope, assign the relevant specialists and remain accountable for communication and the agreed regulatory work.

Regulatory affairsQuality systemsClinical evaluationPhysiciansBiomedical engineeringSoftware and cybersecurityAesthetic devicesPost-market surveillance
Marta Junosza-Szaniawska, MEDDEV conformity assessment specialist

Marta Junosza-Szaniawska

Conformity assessment & EC REP mandate review

Marta coordinates the initial regulatory assessment, defines the file-review scope and confirms whether MEDDEV can accept the representative mandate.

marta.szaniawska@meddev.pl +48 791 480 270
Barbara Jęcka-Izdebska, MEDDEV registration and notification specialist

Barbara Jęcka-Izdebska

Registration, notifications & ongoing coordination

Barbara coordinates registration and notification work and remains a named contact for the practical steps that follow appointment.

barbara.jecka@meddev.pl +48 730 354 190
Check eligibility →
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