Separate representative role
An authorised representative under Ukrainian technical regulations is not automatically the EC REP required for the European Union market.
Our name goes on the label only after your file stands up to review.
Ukraine has its own medical-device technical regulations and authorised-representative framework. For the European Union market, a Ukrainian manufacturer still needs the separate MDR or IVDR route and an EC REP established in the Union.
For Ukrainian medical-device and IVD manufacturers preparing EU market entry, transferring an existing mandate or organising EUDAMED responsibilities.
Ukraine is bringing its medical-device framework closer to EU rules, but the Ukrainian and Union-market roles remain legally separate. MEDDEV maps the available evidence against the actual EU obligations before accepting representation.
An authorised representative under Ukrainian technical regulations is not automatically the EC REP required for the European Union market.
Existing technical, clinical and quality records are reviewed against MDR or IVDR so the team can see what carries over and what remains open.
The mandate, EUDAMED tasks, labelling and authority communication are assigned to named owners and recorded in writing.
Related briefing: Ukraine is rebuilding its rules on the MDR. What Resolutions 759 and 758 of 10 June 2026 change, and why recognition runs one way.
Official basis: Ministry of Health of Ukraine: technical-regulation guidance, European Commission: authorised representatives, MDR Article 11, European Commission: EUDAMED UDI/Device registration.
For Ukrainian manufacturers, continuity of records, authorised signatory powers and reliable access to vigilance information are central to the first review. Existing Ukrainian evidence can support the assessment, but the EU mandate must identify the legal manufacturer and the people able to respond during an authority request.
Need the wider comparison? Compare home-market evidence with the EU MDR/IVDR route →
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.
Ukrainian legal-manufacturer extract, current ownership information and the authorised signatory for the EU mandate.
Applicable Ukrainian conformity records together with the proposed MDR or IVDR classification and EU conformity route.
Technical-documentation index, ISO 13485 evidence, certificates where required and product-liability insurance.
A device list identifying manufacturing sites, critical suppliers, intended EU importers and planned launch countries.
The contracting manufacturer, owners, signatory authority and payment route need to be documented before liability review.
Backups, document access, complaint handling and vigilance contacts must remain available if staff or infrastructure changes.
Ukrainian conformity records may support the review, but MDR or IVDR declarations, labels and EUDAMED data remain separate outputs.
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.
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.
Confirm the legal entity, ownership, authorised signatory, sites and proposed EU supply chain.
Establish controlled access to current technical, quality and post-market records and record EU-specific gaps.
Complete insurance and sanctions screening, close acceptance items, then coordinate labelling and EUDAMED work.
No. A Ukrainian-established manufacturer remains outside the Union and needs the separate Article 11 arrangement for EU market access.
The legal manufacturer named in the technical documentation and product labelling must be verified together with its authorised signatory.
The EC REP carries defined legal duties and may need reliable access to documents and decision-makers during an authority or vigilance case.
No. The form is for qualification only. MEDDEV provides a controlled transfer route after the scope and parties are confirmed.
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.
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.
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.
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.
Classification, IVD or medical device route, number of families, intended purpose and higher-risk features.
Technical documentation, clinical or performance evidence, quality-system records, certificates and labelling.
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.
Confirm the entity, country of establishment, device family and intended EU market.
Have the classification rationale, technical-file index, conformity route and quality evidence available.
Identify complaint, vigilance, field-safety and authority-response owners before the mandate begins.
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.
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.
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.
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.
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.
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 →Products covered by the MDR are excluded. Companion software without a medical purpose, portals and service tools are not.
Read the cybersecurity briefing →The notice goes to the authority of the Member State where the manufacturer or its authorised representative is established.
Read the supply briefing →What transfers into a European file, what has no equivalent at home, and where a representative is required by law.
Open the compliance hub →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.
The legal entity, authorised signatory, manufacturing sites, device families, models and intended purposes are consistent and traceable.
The qualification, classification and conformity-assessment route are documented, with valid notified-body involvement where required.
The EU declaration, agreed technical-documentation index, certificates, labelling and registration data describe the same device scope.
Risk management, surveillance, complaints, vigilance, recalls and corrective actions have current records, owners and escalation routes.
Named decision-makers can provide records, samples and technical answers and can act within agreed authority-response times.
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.
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.
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.
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.
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 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