In Vitro Diagnostic Regulation (EU) 2017/746
Regulation (EU) 2017/746 of the European Parliament and of the Council of 5 April 2017 on in vitro diagnostic medical devices — the "IVDR" — replaces Directive 98/79/EC and covers tests and devices used in vitro for the examination of human specimens (blood, tissue, urine, saliva). It was adopted alongside the Medical Devices Regulation 2017/745 and entered into force on 25 May 2017. Its date of application was 26 May 2022, but the transitional period for legacy devices was extended substantially by Regulation (EU) 2024/1860 and earlier Regulation (EU) 2022/112 in response to severe Notified Body capacity constraints. The IVDR was published in the OJEU as OJ L 117, 5.5.2017, p. 176.
Legal status and timeline
- Adoption: 5 April 2017.
- Entry into force: 25 May 2017.
- Date of application: 26 May 2022.
- Transitional periods (Article 110, as amended by Regulation (EU) 2024/1860). Dates by which legacy devices may be placed on the market:
- Devices with a valid IVDD Notified Body certificate (Article 110(3a)): until 31 December 2027;
- Devices self-declared under the IVDD, with a declaration of conformity drawn up before 26 May 2022, that need a Notified Body under the IVDR (Article 110(3b)): Class D until 31 December 2027; Class C until 31 December 2028; Class B and Class A sterile until 31 December 2029.
- Conditions (Article 110(3c)): continued compliance with Directive 98/79/EC, no significant change in design or intended purpose, no unacceptable risk, and an IVDR quality management system by 26 May 2025. A formal application to a Notified Body and a signed written agreement were also needed by these dates:
- Certified devices and Class D: application by 26 May 2025, agreement by 26 September 2025;
- Class C: application by 26 May 2026, agreement by 26 September 2026;
- Class B and Class A sterile: application by 26 May 2027, agreement by 26 September 2027.
- In-house devices: Article 5(5) points (b), (c) and (e) to (i) have applied since 26 May 2024; point (d) applies from 31 December 2030 (date set by Regulation (EU) 2024/1860).
- Status in October 2026: applies; legacy devices may be placed on the market only if the Article 110(3c) conditions are met. For Class C the application and agreement deadlines have now passed; for Class B and Class A sterile they fall in 2027. The first four EUDAMED modules have been mandatory since 28 May 2026 (Commission Decision (EU) 2025/2371).
The IVDR's transitional regime is long because the IVDD let manufacturers self-declare many IVDs that now need a Notified Body under the IVDR, and Notified Body capacity for the IVDR was limited when the Regulation began to apply.
Scope: products covered
Article 2(2) of the IVDR defines an in vitro diagnostic medical device as "any medical device which is a reagent, reagent product, calibrator, control material, kit, instrument, apparatus, piece of equipment, software or system, whether used alone or in combination, intended by the manufacturer to be used in vitro for the examination of specimens, including blood and tissue donations, derived from the human body". The purpose must be solely or principally:
- To provide information about a physiological or pathological process or state;
- To provide information about congenital physical or mental impairments;
- To provide information about the predisposition to a medical condition or a disease;
- To determine the safety and compatibility with potential recipients;
- To predict treatment response or reactions;
- To define or monitor therapeutic measures.
Examples include laboratory analysers, PCR kits, blood-grouping reagents, glucose self-test devices, pregnancy tests, HIV/SARS-CoV-2 antibody tests, and companion diagnostics. The Regulation extends explicitly to "companion diagnostics" — IVDs essential for the safe and effective use of a specific medicinal product (Article 2(7)) — and to genetic testing.
Risk classification (Annex VIII)
The IVDR classifies IVDs into four classes A through D according to a rule-based system in Annex VIII:
- Class A — Low individual and low public health risk. Examples: laboratory instruments not used for medical decisions, specimen receptacles. Subdivided into Class A sterile (Notified Body required for sterility aspects) and Class A non-sterile (self-declaration).
- Class B — Moderate individual or low public health risk. Examples: pregnancy tests, urine analysis reagents.
- Class C — High individual or moderate public health risk. Examples: blood glucose self-monitoring, infectious disease tests not in Class D, genetic tests, companion diagnostics.
- Class D — High individual and high public health risk. Examples: tests that detect transmissible agents in blood, blood components, cells, tissues or organs to assess suitability for transfusion or transplantation; tests for life-threatening transmissible agents with a high risk of spread (Rule 1); certain blood-grouping tests (Rule 2).
Class B, C and D devices require Notified Body involvement; the routes are set out in Article 48 and listed below. For Class D devices, where an EU Reference Laboratory has been designated the Notified Body must request laboratory verification (Article 48(5) and Article 100), and where no common specifications exist for a first certification of that type of device, relevant experts are consulted on the performance evaluation report (Article 48(6)).
Essential requirements (Annex I)
Annex I sets the general safety and performance requirements, structured similarly to Annex I of the MDR but adapted for IVDs:
- Chapter I — General requirements (points 1–8): risk management, intended use, benefit-risk analysis.
- Chapter II — Requirements regarding performance, design, and manufacture (points 9–19): scientific validity, analytical performance, clinical performance, chemical and physical properties, infection control, software requirements, devices for self-testing and near-patient testing.
- Chapter III — Requirements regarding information supplied with the device (point 20): label and instructions for use, requirements for self-testing devices.
Performance evaluation
Article 56 and Annex XIII require a performance evaluation comprising:
- Scientific validity — the association of the analyte with the clinical condition or physiological state, supported by scientific literature.
- Analytical performance — the device's ability to correctly detect or measure the analyte (sensitivity, specificity, precision, accuracy, limits of detection).
- Clinical performance — the device's ability to yield results that correlate with the intended clinical condition or physiological state. For Class C and D devices, performance studies are typically required.
The Performance Evaluation Report (PER) is part of the technical documentation and is updated throughout the device's lifecycle. The Periodic Safety Update Report (PSUR) is required for Class C and D devices (Article 81).
Conformity assessment procedures
Article 48 and Annexes IX, X, XI:
- Class A (non-sterile) — Annex II + Annex III; manufacturer self-declares.
- Class A sterile — as Class A, plus Notified Body assessment of sterility under Annex IX or XI.
- Class B — Annex IX Chapters I and III (QMS + assessment of the technical documentation of at least one representative device per category of devices) (Article 48(9)).
- Class C — Annex IX Chapters I and III (QMS + assessment of the technical documentation of at least one representative device per generic device group), or Annex X (type-examination) + Annex XI except Section 5 (Article 48(7) and (8)). Self-tests, near-patient tests and companion diagnostics have additional steps.
- Class D — Annex IX Chapters I, II (except Section 5) and III, or Annex X (type-examination) + Annex XI (production QA), plus EU Reference Laboratory verification of performance and compliance with common specifications where designated.
Technical documentation
Annexes II and III of the IVDR set the contents — analogous to MDR but adapted for IVDs. Annex II covers the device description, design and manufacturing information, GSPR mapping, benefit-risk analysis, performance evaluation, and information supplied with the device. Annex III covers post-market surveillance including PMS plan, PSUR, and trend reporting. Retention period is 10 years from the last unit placed on the market (Article 10(7)).
EU Declaration of Conformity and CE marking
Article 17 and Annex IV set the Declaration's contents — including the Basic UDI-DI, Notified Body certificate references, and Single Registration Number. Article 18 requires the CE marking; the four-digit Notified Body identification number appears next to the mark for all classes except Class A non-sterile.
UDI and EUDAMED
The UDI system mirrors the MDR (Articles 24–26). EUDAMED's modules for actors, UDI and devices, Notified Bodies and certificates, and market surveillance became mandatory for IVDs on 28 May 2026, on the same timetable as the MDR. Under Article 113(3):
- 28 November 2026: point (fa) gives manufacturers 6 months from 28 May 2026 to enter device data for devices first placed on the market earlier, including legacy devices, if units continue to be placed on the market after that date.
- 28 May 2027: point (fb) gives Notified Bodies 12 months from 28 May 2026 to enter certificate information.
The vigilance and performance studies modules are not yet mandatory, because no notice has been published for them.
In-house IVDs (Article 5(5))
Article 5(5) provides an exemption for IVDs manufactured and used only within health institutions, subject to strict conditions: the institution must have a quality management system, justify that target patient needs cannot be met at the appropriate level of performance by an equivalent CE-marked device on the market, draw up documentation on manufacturing and performance, and report serious incidents. Points (b), (c) and (e) to (i) of Article 5(5) have applied since 26 May 2024; point (d) — the justification that no equivalent CE-marked device is available — applies from 31 December 2030.
Recent and upcoming changes
- Regulation (EU) 2022/112 — first extension of transitional periods.
- Regulation (EU) 2024/1860 (13 June 2024; OJ 9 July 2024) — second extension, including the in-house date of 31 December 2030; mandatory EUDAMED rollout module by module; Article 10a duties to give notice of a supply interruption or discontinuation, generally at least 6 months in advance.
- Common specifications under Article 9 — adopted for Class D devices by Commission Implementing Regulation (EU) 2022/1107.
- EU reference laboratories for Class D devices — designated by Commission Implementing Regulation (EU) 2023/2713, with their Article 100(2) tasks applying from 1 October 2024.
- Proposed targeted revision. On 16 December 2025 the Commission proposed amending the MDR and IVDR (COM(2025) 1023, procedure 2025/0404(COD)). It is not law and may change. As of late October 2026 we found no report of a Parliament committee vote or a Council general approach.
Related legislation
- Medical Devices Regulation 2017/745 — companion regulation for medical devices.
- Regulation (EU) 2024/1860 — joint amendment of MDR and IVDR.
- General Product Safety Regulation 2023/988 — the IVDR takes precedence for the risks it covers; the GPSR applies to a consumer product only for aspects not covered by specific Union legislation.
- Directive 2001/83/EC on medicinal products — for companion diagnostics linked to specific medicines.
Common errors
- Continuing to place legacy devices on the market without meeting the conditions in Article 110. Conditions include no significant change of design or intended purpose, an IVDR quality management system by 26 May 2025, and the class-specific application and agreement deadlines. IVDR requirements on post-market surveillance, vigilance and registration apply to legacy devices (Article 110(3d)).
- Misclassification under Annex VIII. Many devices have moved from self-declared status under the IVDD to Class B, C, or D under the IVDR. Classification using IVDD rules is not sufficient.
- Missing Notified Body engagement. Class B, C, and D devices require Notified Body involvement; the manufacturer must engage a Notified Body designated under the IVDR (listed in NANDO).
- Inadequate performance evaluation. The IVDR's three-part performance evaluation (scientific validity, analytical performance, clinical performance) goes substantially beyond IVDD requirements.
- Missing PRRC. Article 15 requires a Person Responsible for Regulatory Compliance equivalent to the MDR's.
Frequently asked questions
When did the IVDR start to apply?
It entered into force on 25 May 2017 and has applied since 26 May 2022. Legacy devices have transitional periods running to 31 December 2027, 2028 or 2029 under Article 110.
What is the IVDR deadline for each risk class?
Devices self-declared under the IVDD that now need a Notified Body may be placed on the market until 31 December 2027 (Class D), 31 December 2028 (Class C) or 31 December 2029 (Class B and Class A sterile). Devices with an IVDD Notified Body certificate have until 31 December 2027. All of these depend on the Article 110(3c) conditions.
Do Class A devices need a Notified Body?
Non-sterile Class A devices do not: the manufacturer issues the EU declaration of conformity. For Class A sterile devices a Notified Body assesses only the aspects of establishing, securing and maintaining sterile conditions (Article 48(10)).
When does the in-house justification requirement apply?
Article 5(5)(d), the justification that no equivalent device on the market meets the patient group needs, applies from 31 December 2030. Regulation (EU) 2024/1860 replaced the earlier date of 26 May 2028. The other Article 5(5) conditions have applied since 26 May 2024 or, for point (a), since 26 May 2022.
Has the IVDR revision been adopted?
No. COM(2025) 1023 was proposed on 16 December 2025 and is still in the ordinary legislative procedure, so the current IVDR continues to apply.
Sources
- Regulation (EU) 2017/746 (IVDR) — EUR-Lex consolidated text.
- Regulation (EU) 2024/1860 (transitional extension) — EUR-Lex.
- Commission Decision (EU) 2025/2371 (EUDAMED notice) — EUR-Lex.
- Commission Implementing Regulation (EU) 2023/2713 (EU reference laboratories) — EUR-Lex.
- European Commission — Medical devices sector — new Regulations.
- Medical Device Coordination Group (MDCG) — Guidance documents.
- Commission Implementing Regulation (EU) 2022/1107 (common specifications, Class D) — EUR-Lex.