See how long your legacy device can stay on the EU market, in a few clicks.

  • Your end dateDecember 31, 2027 or 2028 for your device class, and how many days are left.
  • Every condition checkedQuality system, notified body dates and design changes, each marked yes, no or to check.
  • Next steps and referencesWhat to do now, with the MDR article or Commission Q&A behind each rule.
Check my deviceFree · No sign-up · MDR rules as of October 22, 2026

The short answer

Under the EU Medical Device Regulation (MDR), a legacy device, one certified or declared under the old directives (MDD, AIMDD) before May 26, 2021, can be placed on the market until December 31, 2027 (Class III and most Class IIb implants with a certificate) or December 31, 2028 (other devices that need certification by a notified body under the MDR). The date holds only if you had an MDR quality management system and a notified body application by May 26, 2024, a signed agreement by September 26, 2024, and make no significant change.

How it works

  1. Answer a few questionsGive the class under the MDR rules (Annex VIII), which can differ from the class on your MDD certificate, and say what covered the device before May 26, 2021.
  2. We apply Article 120The tool follows Article 120 of the MDR (Regulation (EU) 2017/745) as amended by Regulation (EU) 2023/607, checked on October 22, 2026, and not the Commission’s 2025 proposal.
  3. You get your end dateIt comes with each condition and your answer to it, and the next steps for your case.

The old certificate must have been valid on May 26, 2021 and not withdrawn. Until the end date, the device must keep complying with the MDD or AIMDD and pose no unacceptable risk to health or safety. If a condition fails, the device loses the transition and new units can be placed on the market only under the MDR, although moving the application to another notified body under a new agreement at the same time does not end it.

EU MDR transition deadlines by device class

Legacy device (class under the MDR)Covered before May 26, 2021 byMay be placed on the market untilArticle
Class IIIMDD or AIMDD certificateDecember 31, 2027120(3a)(a)
Class IIb implantableMDD or AIMDD certificateDecember 31, 2027120(3a)(a)
Class IIb implantable sutures, staples, dental fillings, dental braces, tooth crowns, screws, wedges, plates, wires, pins, clips and connectorsMDD or AIMDD certificateDecember 31, 2028120(3a)(b)
Class IIb, not implantableMDD or AIMDD certificateDecember 31, 2028120(3a)(b)
Class IIaMDD or AIMDD certificateDecember 31, 2028120(3a)(b)
Class I placed on the market sterile or with a measuring functionMDD or AIMDD certificateDecember 31, 2028120(3a)(b)
MDD Class I without a notified body that needs one under the MDR, for example a reusable surgical instrumentEC declaration of conformityDecember 31, 2028120(3b)
Class III custom-made implantableApplication by May 26, 2024, written agreement by September 26, 2024May 26, 2026 (ended)120(3f)
Class I with no notified body under the MDREC declaration of conformityNo transitional period: must meet the MDR120(3b)
End dates for legacy devices under Article 120 of Regulation (EU) 2017/745 as amended by Regulation (EU) 2023/607. Each date applies only while the conditions hold. Data as of October 22, 2026.

The check leaves out in vitro diagnostic devices, which have their own transitional periods under Article 110 of the IVDR (Regulation (EU) 2017/746), and custom-made devices other than Class III implantable ones, which are placed on the market with the statement under Annex XIII of the MDR. National measures under Articles 59 and 97 beyond its date test, and rules in markets outside the EU, are not covered either. The engineering behind MDR certification, such as redesigns, replacements for obsolete components and test evidence, is outside it too; our cost calculator estimates that work by phase.

What OVA does here, and where our responsibility ends

220devices developed62engineers$125per hourISO 13485certified quality system

We design the electronics, firmware and mechanics of medical devices and take them from concept to design for manufacturing. We are not a regulatory consultancy and not a contract manufacturer: the regulatory strategy and the submission stay with you or your regulatory consultant.

The result is an orientation, not a regulatory opinion. OVA Solutions is not a notified body: confirm the end date and the conditions with your notified body. The tool runs in your browser. Your answers are not sent to us; with your cookie consent, Google Analytics records only that the tool was used and the category of the result.

Questions

Can I still sell MDD devices after 2027 or 2028?

Yes, for units placed on the market by the end date: they can still be made available and put into service, with no time limit other than their own shelf life or expiry date. Regulation (EU) 2023/607 deleted the sell-off date that used to stop such units one year after the end of the transitional period. Any new unit after the end date needs an MDR certificate.

My MDD certificate has expired. Is it still valid?

Yes, if it was issued from May 25, 2017, was valid on May 26, 2021 and on March 20, 2023, and has not been withdrawn: the law extended it to the end date for the device class while the conditions hold. If it expired before March 20, 2023, it counts only with a written agreement with a notified body signed before the expiry, or a national derogation or required conformity assessment before March 20, 2023.

Do I need a new certificate or letter to prove the extension?

No, the extension applies by law once the conditions are met. The Commission says you should be able to provide a self-declaration that they are fulfilled, stating the end date. A confirmation letter from your notified body is optional extra evidence.

What counts as a significant change?

The guidance is MDCG 2020-3 Rev.1 from the EU’s Medical Device Coordination Group, and it is worth confirming with your notified body before you change the device. Administrative changes, such as a new company name, address or legal form, are generally not changes in design or intended purpose. A replacement device needs the full MDR conformity assessment first; once it is certified, it can be on the market in parallel with the legacy device until the legacy end date.

Will the EU extend the MDR deadlines again?

No further extension has been adopted. The Commission’s proposal of December 16, 2025 (COM(2025) 1023) keeps the 2027 and 2028 dates and would let legacy orphan devices, the ones for small patient groups, stay on the market after them with an expert panel opinion. As of October 22, 2026 the proposal was awaiting a committee decision in the European Parliament, with an indicative plenary date of December 14, 2026.

Related pages

Sources

Data as of October 22, 2026. By Lisa Voronkova, CEO of OVA Solutions. Updated on October 22, 2026.