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EU MDR: Transition Deadlines2026 Field Guide

The class ladder, the conditions, and the sell-off reset — with the EU practice you need.

Class III
Dec 27
Class II
Dec 28
Sell-off reset
2024/1860

Sourced from verified 2026 publications.

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What's inside

Five pages, zero fluff

Every figure in this guide traces to a named source — verified 2026 publications.

The class ladder

The legacy ladder: custom-made III (ended May 2026), Class III/IIb implantable to Dec 2027, the rest to Dec 2028.

The conditions

The cumulative conditions: MDR QMS, signed NB agreement, no significant changes — extension is never automatic.

The sell-off reset

Regulation (EU) 2024/1860 removed fixed sell-off deadlines: lawfully placed devices stay available without a time limit.

Sources & scope

  • oxfordcorp.com, EU MDR Transition Deadlines (2026–2028).
  • jamasoftware.com, EU MDR Compliance: Requirements, Timeline & Deadlines.
  • bsigroup.com, (EU) 2024/1860 – IVDR 26 September 2026 deadline approaching.

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

EU legacy on your 2026 roadmap? Start with the full picture.

A Market Access Strategy Session maps your MDR route — class-ladder positioning, NB strategy, and transition conditions.

Professional review is required before business use.