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United Kingdom · Global Market Access

Entering the UK Market: Medical Devices

UK medical device legislation and MHRA registration.

Market
United Kingdom
Site
European
Mark
UK MDR

01What is it?

The United Kingdom medical device legislation governs the placing of devices on the Great Britain market. Devices must be registered with the MHRA and foreign manufacturers must appoint a responsible person established in the United Kingdom.

02Why Does This Scheme Exist?

The United Kingdom medical device arrangement is one of the most complex consequences of leaving the EU, because departure coincided with a period in which the EU was fundamentally changing its own medical device regime. The result was this: the country continued with a national regime based on the EU's OLD directive arrangement, while the EU moved to the new regulation.

The practical meaning of that divergence is that the evidential thresholds of the two regimes are no longer the same. A file prepared to the EU's new regulation may be more than sufficient to meet the national regime's requirements; but the national regime's own registration and marking arrangement is still followed.

The defining condition of the regime is the RESPONSIBLE PERSON ESTABLISHED IN THE COUNTRY: a foreign manufacturer must appoint a responsible person established in the country and register its device with the national authority. Registration ran on staged timetables according to the device's risk class.

On the assessment side, bodies designated in the country come into play; a certificate from a notified body established in the EU does not as a rule count as a decision under this regime. Under transitional arrangements the acceptance of EU certificates was secured for certain periods, but this is a temporary solution and the dates may change.

Northern Ireland stands apart here too: EU medical device rules continue to apply in the region, so two different regimes can be valid for the same device within the same country. The national regime is itself being reformed; the rules and dates in force are therefore confirmed at the start of every project.

03Whose Obligation?

For foreign manufacturers a UK RESPONSIBLE PERSON IS MANDATORY: MHRA registration is made through that party and it carries responsibility before the legislation.

04Required Documents

  • Device description, classification and intended purpose
  • Technical documentation
  • Quality management system records
  • The UK Responsible Person appointment agreement
  • The MHRA registration record
  • A notified body certificate (where required)

05Process

  1. 01Scope DeterminationIt is determined which legislation and marking scope the product falls under in the target market. This step defines the entire process; getting it wrong wastes all subsequent work.
  2. 02Determining Applicable StandardsThe standards accepted by the market and any national deviations are identified. The same IEC standard may apply with different deviations in different markets.
  3. 03Establishing the Test PlanIt is assessed which part of existing test reports will be accepted; missing tests are planned. A CB Scheme report, if available, reduces retesting.
  4. 04Local Party and RegistrationIf the market requires an established representative, importer or applicant, this party is designated and the necessary registrations are made.
  5. 05Tests and Technical FileTests are conducted and the technical file is prepared. Some markets require testing to be performed within their own country.
  6. 06Certification or DeclarationDepending on the market's regime, a manufacturer's declaration is drawn up or a certificate is obtained from the authorised body; a factory audit is carried out if required.
  7. 07Marking and LabellingThe mark and label are applied according to the market's format and language rules. The language requirement is checked at customs in most markets.
  8. 08Shipment and CustomsIf a pre-shipment document is required, it is obtained; the document set to be presented at customs is completed.

06Points to Watch

  • Registration cannot be made without appointing a UK Responsible Person
  • Transitional arrangements for the acceptance of CE-marked devices are conditional
  • EU rules apply for Northern Ireland
  • The device class determines the route to be followed

07Neighbouring Schemes and the Difference

  1. 01UK MDR and EU MDRThe national regime rests on the EU's old directive arrangement, while the EU moved to the new regulation. The evidential thresholds are no longer the same and the documents are not treated as mutually valid.
  2. 02Great Britain and Northern IrelandEU rules continue to apply in the region; two regimes can be valid for the same device within the same country and marking is established accordingly.
  3. 03National registration and body assessmentRegistration is not an approval; assessment by a designated body is also required according to the risk class. Neither takes the place of the other.
  4. 04The responsible person and the authorised representativeAn authorised representative established in the EU is not valid under this regime; a responsible person established in the country is appointed and is the point of contact with the authority.

08Scheme Detail

There is no separate certification page for this mark; the scope and process are as described on this page. The roadmap specific to your product is provided in writing at the quote stage.

09Other Marks in the United Kingdom Market

10Frequently Asked Questions

This section's content is being prepared. The roadmap specific to your product and target market at the quote stage in writing.

The certification timeline varies with the product, the required test workload, sample shipping time and the authority's workload; for this reason, no duration in days or weeks is given on these pages. The main factors determining the timeline are: whether testing must be performed in the target country, whether a factory audit is required, the time to appoint a local representative, and the current maturity of the technical file. A realistic timeline for your product is provided in writing at the quote stage.

Market access regimes change frequently: scope lists are updated, transition periods are extended, new requirements are added. These pages describe the structure of the regime and who bears the obligation; the applicable scope and dates for your product are confirmed from the current legislative text at the quote stage.

United Kingdom · UK MDR roadmap for

Tell us about your product; we'll share the required steps, documents and timeline in writing.

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