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How to Comply with the Environmental Requirements of the Medical Devices Regulation

Medical Devices Regulation

The Medical Devices Regulation (MDR) is a set of regulations for medical devices in the European Union (EU) to ensure safety, efficacy, and quality. Environmentally related requirements can also apply. Indeed, some strict obligations for device design and manufacturing mandate restricting, labeling, and tracking substances. The EU Database on Medical Devices (EUDAMED) and the Global Unique Device Identification Database (GUDID) are useful for this purpose.

What is the EU Medical Devices Regulation?

The EU MDR was initially adopted by the EU in 2017 to improve the safety and efficacy of medical devices distributed within the EU. This replaced the 1993 Medical Devices Directive and its amendments. MDR has since been amended by Regulation 2020/561. Moreover, this medical device regulation is a component of the European CE marking requirements, along with other environmental requirements like the EU eco-design and RoHS directives.

The MDR sets out new rules for the design, manufacture, and marketing of medical devices, as well as requirements for clinical investigations and post-market surveillance. For example, the MDR requires manufacturers to perform clinical evaluations to demonstrate the safety and performance of their devices before they can be placed on the market. The MDR aims to ensure that medical devices placed on the market are safe, effective, and of high quality while promoting innovation in the medical device industry.

Design and Manufacture Requirements for Medical Devices

Additionally, the MDR places strict requirements on the design and manufacture of medical devices. Specifically, devices must be designed and manufactured to minimize risks from substances or particles that may be released from the device.

Medical Devices Regulation Instruments

For instance, a medical device manufacturer must ensure that their implantable medical devices are designed to minimize wear debris, degradation products, and processing residues.

We can help you comply with the substance control obligations under the medical devices regulation. Contact Enviropass now!

Restrictions of Substances in EU Medical Devices Regulation

Furthermore, the MDR restricts the use of certain substances in medical devices under certain conditions. Specifically, devices may only contain certain substances in concentrations above 0.1% w/w if justified. These substances include:

  • Carcinogenic compounds
  • Mutagenic or toxic substances
  • Endocrine-disrupting chemicals

For example, a medical device that contains a restricted substance above the specified concentration without justification will not be allowed to be marketed in the EU.

Conditions for Exemption from Restrictions on Substances in Medical Devices

In some cases, manufacturers may be able to justify the use of restricted substances in medical devices. To do so, they must provide:

  • An analysis and estimation of potential patient or user exposure
  • Possible alternative substances or designs
  • Argumentation as to why possible substitutes or design changes are inappropriate for maintaining the functionality, performance, and benefit-risk ratios of the product.
blood pressure Medical Devices Regulation

For instance, a medical device manufacturer may be able to justify the use of a restricted substance such as lead in a detector-type device due to the absence of suitable alternatives. Likewise, the use of heavy metals such as lead, cadmium, and mercury are also exempted in infrared light detectors under the EU RoHS Exemption list for medical devices and monitoring and control instruments.

Guidelines on Phthalates and Carcinogenic, Mutagenic, or Toxic for Reproduction (CMR) Substances in Medical Devices

Phthalates are a type of substance that is commonly used in medical devices. However, they are also known to have endocrine-disrupting properties, which can be harmful to patients and users.

In fact, phthalates are regulated in many other European environmental regulations such as in EU RoHS and the EU REACH Substances of Very High Concern (SVHC) List.

To address the issue in medical devices, the European Commission mandates the relevant scientific committee to prepare guidelines for the benefit-risk assessment of the presence of phthalates, CMR, or endocrine-disrupting substances in medical devices.

Labeling Requirements for Medical Devices Containing Restricted Substances

Additionally, medical devices that contain restricted substances above 0.1% w/w must be labeled on the device itself and/or on the packaging for each unit or, where appropriate, on the sales packaging, with the list of such substances. This labeling requirement ensures that patients and users are aware of the substances in the devices they use and can make informed decisions about their use.

The European Union Database on Medical Devices (EUDAMED)

Another method to inform the user is to use EUDAMED. It is an online database developed by the European Commission to support the implementation of the EU Medical Devices Regulation. EUDAMED is specific to medical devices marketed in the EU and contains information on medical device manufacturers, authorized representatives, and other economic operators involved in the supply chain, as well as details on the devices themselves. The database contains the following six modules:

European Union RoHS Flag

1. Actor Registration Module

This module allows manufacturers, authorized representatives, importers, distributors, and other economic operators involved in the supply chain of medical devices to register with EUDAMED and receive a single registration number (SRN).

2. Unique Device Identification (UDI) and Device Registration Module

This module contains information on medical devices, including their unique device identifiers (UDIs), device specifications, and labeling. Manufacturers are required to register their devices in this module before they can be placed on the market.

3. Notified Bodies and Certificates Module

This module provides information on the notified bodies that have been designated to carry out conformity assessments under the EU MDR. It also contains information on the certificates issued by notified bodies, which demonstrate that a device complies with the regulation.

4. Clinical Investigations and Performance Studies Module

This module contains information on clinical investigations and performance studies carried out on medical devices in the European Union. Manufacturers are required to register their studies in this module.

5. Vigilance Module

This module allows competent authorities and manufacturers to report incidents and issues related to medical devices that have been placed on the market. It also contains information on the corrective actions taken by manufacturers in response to these issues.

6. Market Surveillance Module

This module provides information on the market surveillance activities carried out by competent authorities to ensure that medical devices placed on the market comply with the EU MDR.

The Consequences of Non-Compliance with the EU Medical Devices Regulation

Compliance with the EU MDR is crucial for manufacturers who wish to distribute their medical devices in the EU since it is a mandatory regulation. Thus, non-compliance can result in significant penalties, including product recalls and even legal action. Therefore, manufacturers need to understand the key compliance obligations under the MDR and take the necessary steps to meet them.

Global Unique Device Identification Database (GUDID) for Medical Devices in the USA

GUDID, on the other hand, is a database developed by the U.S. Food and Drug Administration (FDA) to support the implementation of the Unique Device Identification (UDI) system in the United States. GUDID contains information on medical devices sold in the United States, including their UDIs, device specifications, and labeling. Manufacturers are required to submit information to GUDID as part of their compliance with the FDA’s UDI system.

Manufacturers must register their devices with the database and provide information on the device’s identification, classification, and substance composition. This information is then used to generate a unique device identifier that can be tracked throughout the device’s lifecycle.

pulse trace Medical Devices

The GUDID also provides a platform for healthcare providers to access information on medical devices, including:

  • Substance composition
  • Potential risks
  • Instructions for use


This allows providers to make informed decisions about which devices to use and how to use them safely.

Need to know more about EU Medical Devices Regulation? Contact Enviropass for a free consultation!