Legacy requirements: 26 May 2025 deadline for in-vitro diagnostic medical devices

With Regulation (EU) 2024/1860, the transitional periods for legacy IVDs have been extended. 26 May 2025 marks the first important deadline. By this date:

  • Class D IVDs and IVDs covered by an IVDD CE Certificate must apply to a notified body for an IVDR certificate.
  • All IVDs must have a Quality Management System (QMS) compliant with the In Vitro Diagnostics Regulation (IVDR)

Notified body application for certain high-risk IVDs

The new transitional period for legacy devices extends until December 2027 for Class D devices and for all IVDs covered by an IVDD CE Certificate. However, this extension applies only if the devices are part of a notified body’s application submitted by 26 May 2025 and have a QMS compliant with the regulation’s requirements.

IVDR-compliant QMS for all IVDs

26 May 2025 is also a key deadline for all classes of legacy in-vitro diagnostics medical devices. Manufacturers must set-up a QMS compliant with the IVDR. Additionally, manufacturers must verify which deadline applies to their device to submit an application with a notified body in time (26 May 2026 for Class C and 26 May 2027 for Class B and Class A sterile devices).

Actions: what manufacturer must do

Manufacturers  must contact their notified body and inform them about the status of their transition. Obelis can support you with:

  • Notified body application: Obelis selects the notified body for the manufacturer and applies on their behalf.
  • Quality Management System: Obelis offers different tailored services to support manufacturers of medical devices and IVDs in preparing a QMS conforming with ISO 13485.
  • IVDR and MDR compliance: As your authorised representative or consultant, Obelis guides manufacturers through the Regulations’ requirements.

Do you have any questions on your legacy devices?


References:

Eur-Lex (2024). Regulation (EU) 2024/1860 of the European Parliament and of the Council of 13 June 2024 amending Regulations (EU) 2017/745 and (EU) 2017/746 as regards a gradual roll-out of Eudamed, the obligation to inform in case of interruption or discontinuation of supply, and transitional provisions for certain in vitro diagnostic medical devices. Retrieved on 01/04/2025.

Simona Varrella          
Regulatory Intelligence & Innovation             
01.04.2025


The information contained on obelis.net is presented for general information purposes only, without obligation and it has been compiled with the utmost care to ensure it remains up to date. Nevertheless, Obelis Group cannot be held liable for the accuracy and completeness of the information published. Any reliance placed on such information is therefore strictly at the User’s risk.

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