EU market entry for manufacturers outside the European Union

Sell medical devices in Europe. Start with the correct EU route.

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

If your legal manufacturer is outside the EU, appointing an EC REP may be mandatory — but it is not the entire launch route. MEDDEV maps the workstreams, reviews the agreed file and accepts the Article 11 mandate only when the criteria are met.

For medical-device and IVD manufacturers that want an accountable route into the European Union, with responsibilities and blocking gaps recorded in writing.

European Union flag
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 · qualification response 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.
Direct answer

Selling medical devices in the European Union requires more than buying an address.

For a legal manufacturer established outside the EU, an EC REP is required when Article 11 of the MDR or IVDR applies. But representation comes after the device, conformity route and evidence are understood. MEDDEV begins with that map, then accepts the mandate only when the agreed file and liability criteria are met.

Outcome first

One written route showing what is ready, what is missing, who owns each action and which items block EU market placement.

Representation with boundaries

MEDDEV acts as the EU Authorized Representative after acceptance. It does not replace the manufacturer, notified body, importer or distributor.

Ongoing control

The mandate covers defined EC REP duties, EUDAMED coordination, document access and authority communication throughout the agreed scope.

Official basis: the European Commission describes the duties of manufacturers, authorised representatives, importers and distributors and publishes a step-by-step factsheet for manufacturers.

EU launch route

Five workstreams between a home-market file and EU sales.

The exact sequence depends on the product and conformity route. These are the workstreams that must be assigned rather than collapsed into a single “registration” task.

01

Define the product

Confirm the intended purpose, medical-device or IVD status, classification and applicable MDR or IVDR route.

02

Complete conformity evidence

Organise the technical documentation, quality system, clinical or performance evidence and notified-body work where required.

03

Prepare the market release

Align the declaration of conformity, CE marking, UDI structure, labels and product families.

04

Appoint and register

For a non-EU manufacturer, appoint the EC REP when Article 11 applies and complete the applicable EUDAMED actor and device work.

05

Control the supply chain

Assign importer and distributor roles and maintain post-market surveillance, vigilance and authority-response processes.

Map my EU route →
Portfolio readiness

Prepare the evidence that determines the route.

The initial form contains no document upload. It qualifies the manufacturer and portfolio. MEDDEV provides a controlled transfer route after the parties and review scope are confirmed.

  1. 01

    Legal-manufacturer extract, authorised signatory and manufacturing-site list.

  2. 02

    Device list with intended purpose, classification and proposed EU launch countries.

  3. 03

    Conformity route, current certificates and EU declaration of conformity draft.

  4. 04

    Technical-documentation index, quality-system evidence and current labelling.

  5. 05

    Post-market surveillance, vigilance and complaint-handling arrangements.

  6. 06

    Product-liability insurance and the proposed EU importer structure.

Role clarity

What MEDDEV takes on — and what remains elsewhere.

MEDDEV

Pre-appointment review, an accepted Article 11 mandate, agreed verification and record duties, EUDAMED coordination and ongoing authority communication.

Manufacturer

Device conformity, technical-documentation accuracy, quality management, declarations, safety investigation, corrective decisions and truthful EUDAMED device data.

Other parties in the route

A notified body where the conformity route requires one, plus separately assigned importer and distributor duties in the Union supply chain.

Start from your home market

Choose the guide that matches the legal manufacturer.

Home-market evidence changes what can be reused, which databases remain separate and what must still be completed for the Union file.

Home market versus EU route

What can support the EU file — and what must be rebuilt.

The table is a starting map, not a conformity assessment. The exact answer depends on intended purpose, classification, device family and the evidence available for the proposed Union portfolio.

Origin
Home-market evidence
EU workstream
United StatesMap intended purpose and evidence before reusing FDA records.
FDA clearance, QMS evidence and US labelling
MDR/IVDR classification, EU conformity route, CE documentation, EUDAMED and EC REP
SwitzerlandReconcile Swiss and EU legal-manufacturer data.
Swissmedic / swissdamed records
Separate EU actor and device records; Swiss systems do not replace EUDAMED
Great BritainConfirm Great Britain versus Northern Ireland establishment.
MHRA registration and UK market records
Separate EU mandate, EU labelling and EUDAMED workstream
CanadaMap Canadian product families to the EU portfolio.
Health Canada, MDSAP and ISO 13485 evidence
MDR/IVDR route, EU declarations, labels and Union post-market duties
Australia / New ZealandKeep Australian and New Zealand legal manufacturers distinct.
ARTG or WAND records, depending on jurisdiction
Separate EU conformity and EUDAMED route
Japan / South KoreaBuild an evidence map instead of assuming equivalence.
PMDA/MHLW or MFDS/KGMP evidence
EU classification, clinical/performance evidence and MDR/IVDR labels
Saudi Arabia / UAEVerify the legal manufacturer and local-agent structure.
SFDA or local authority records
EU conformity, liability, importer and EUDAMED responsibilities
Ukraine / Türkiye / IsraelCheck continuity, signatory authority and device scope early.
National technical or market records
Separate Union route, Article 11 mandate and EU post-market duties

Next step: choose the country guide for the legal manufacturer, then submit the portfolio for a documented MDR or IVDR scope review.

Questions before EU launch

What “ready to sell” actually requires.

How can a manufacturer outside the EU sell medical devices in the European Union?

The manufacturer must identify the applicable MDR or IVDR route, complete the required conformity work, prepare compliant declarations and labelling, appoint an EU Authorized Representative when Article 11 applies and complete the applicable EUDAMED and supply-chain steps before market placement.

Does appointing an EC REP mean that a device is ready for EU sale?

No. The EC REP mandate is one part of the route. It does not replace conformity assessment, technical documentation, CE marking, an EU declaration of conformity, UDI and labelling work, importer verification or post-market obligations.

Can FDA, Swissmedic, Health Canada, TGA or other home-market evidence be reused?

Relevant quality, risk, clinical, performance and post-market evidence may support the EU file. MEDDEV maps it against MDR or IVDR rather than assuming that a home-market licence or registration creates EU conformity.

Does every medical device need a notified body?

No. The answer depends on the applicable regulation, device type, classification and conformity route. Where notified-body involvement is required, MEDDEV reviews the certificate and scope but does not act as the notified body or issue a conformity-assessment certificate.

What does MEDDEV review before accepting an EC REP mandate?

The review covers the legal manufacturer and device identity, intended purpose and classification, conformity route and certificates, the agreed technical-documentation index, quality-system evidence, labelling, post-market and vigilance arrangements, product-liability insurance and sanctions screening.

Is MEDDEV also the EU importer or distributor?

The EC REP mandate does not itself make MEDDEV the importer or distributor. Those are separate economic-operator roles with their own MDR or IVDR duties and must be assigned within the manufacturer’s supply chain.

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
Vancouver–:–
New York / Toronto–:–
Warsaw–:–
Dubai–:–
Tokyo / Seoul–:–
Sydney–:–
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
Map my EU route →
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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