The class ladder
The legacy ladder: custom-made III (ended May 2026), Class III/IIb implantable to Dec 2027, the rest to Dec 2028.
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The class ladder, the conditions, and the sell-off reset — with the EU practice you need.
Sourced from verified 2026 publications.
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What's inside
Every figure in this guide traces to a named source — verified 2026 publications.
The legacy ladder: custom-made III (ended May 2026), Class III/IIb implantable to Dec 2027, the rest to Dec 2028.
The cumulative conditions: MDR QMS, signed NB agreement, no significant changes — extension is never automatic.
Regulation (EU) 2024/1860 removed fixed sell-off deadlines: lawfully placed devices stay available without a time limit.
This guide is market-access intelligence, not regulatory or legal advice. EU MDR/IVDR transition rules, NB capacity, and competent-authority practice change — professional review is required before business use.
Market Access Strategy Session
A Market Access Strategy Session maps your MDR route — class-ladder positioning, NB strategy, and transition conditions.
Professional review is required before business use.
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