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Is UDI required for Class I devices under MDR before May 2025?

Anonymous · Published December 27, 2025 · 1 comment
Is it necessary to have a UDI (Unique Device Identification) for Class I medical devices under the EU MDR before May 2025? I have seen conflicting information, with some sources indicating a 2024 deadline. I would appreciate clarification and any official references.

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Anonymous 6 months ago
Some legal experts may interpret the requirement differently depending on whether you mean UDI assignment or UDI carrier application.
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2 Answers

Accepted answer Dr. Oliver Eidel · Founder & CEO, OpenRegulatory ·
I was looking into this for my own product and found that for Class I devices, the UDI carrier does not need to be on the device until 26 May 2025. This is stated in the official FAQ from the European Commission and also on the UDI Helpdesk site: If someone is saying you need it earlier, it might be worth asking what specific requirement they mean.

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Anonymous ·
There is a difference between UDI assignment (such as Basic-UDI, UDI-DI, and UDI-PI), which should be included in your technical documentation, and the requirement to apply the UDI carrier to the device itself. MDR-compliant devices need UDI assignment now, but the physical carrier deadline depends on the risk class. For Class I, the deadline for the UDI carrier is 26 May 2025.

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