Eu Mdr Medical Device Compliance Registration Service In France
EU MDR medical device compliance registration service in France: filing is not a single French product licence. For most MDR devices, it consists of registering economic operators and devices in EUDAMED, coordinating any notified-body certificate record, and checking whether a separate activity declaration must go to France’s ANSM. An EUDAMED entry or SRN does not itself establish MDR conformity or authorise a non-compliant product.
Since 28 May 2026, the EUDAMED Actor, UDI/Devices, Notified Bodies & Certificates, and Market Surveillance modules have been mandatory. The latter is primarily for authorities; the filing obligations differ by actor. A service provider can prepare records and manage access, but cannot transfer the manufacturer’s legal responsibility for device registration.
Which filing is required, and who submits it?
Use this filing matrix before opening a portal account. “France” refers to the operator’s location or a French statutory activity, not an additional ANSM marketing authorisation for every CE-marked device.
| Record / route | Responsible actor | Filing gate / result |
|---|---|---|
| EUDAMED Actor / Actor ID or SRN | Manufacturer, EU authorised representative, importer or system/procedure-pack producer in its relevant role | Submit actor request with supporting documents; the competent national authority validates it and an actor identifier/SRN is assigned. Existing national registration does not replace this step. |
| EUDAMED UDI/Devices | Manufacturer for its MDR device; Article 22 producer for the relevant system/procedure pack | For new MDR devices, file the device record before first EU placing on the market from 28 May 2026; verify Basic UDI-DI, UDI-DI, EMDN and certificate links. |
| Notified Bodies & Certificates | Notified body, where conformity assessment requires one | The notified body records certificate information; the manufacturer checks consistency and does not upload a purported certificate as its own approval. |
| ANSM national activity filing | Relevant operator carrying on a listed French activity | French declaration can be required for certain distributors (excluding retail sales to the public), custom-made-device makers/representatives and sterilisation activities; use ANSM’s designated form. |
| Legacy / custom-made exception | Manufacturer, with route verified for each device | Some continuing legacy device records fall due by 28 November 2026. Custom-made devices generally follow a different registration route; specified class III implantable or serious-incident cases require EUDAMED action. |
Identifier gate (do not equate Actor ID with SRN). Under the Commission’s EUDAMED guidance, manufacturers, authorised representatives and importers registered under MDR Article 31 receive an SRN. System/procedure-pack producers under Article 22(1)–(3), and manufacturers registered only for certain legacy or custom-made workflows, receive an Actor ID instead. Verify the legal role and applicable record before requesting or citing an “SRN”.
Special device and pack gate. Custom-made devices are not registered in the ordinary EUDAMED UDI/Devices dataset. Depending on the facts, French ANSM declarations and EUDAMED actor, notified-body-certificate or vigilance-specific processes may still apply. Under Article 22(4), a system/procedure pack treated as a device in its own right follows the manufacturer/device registration route, not the ordinary pack-producer route.
Filing dossier: data entered versus evidence retained
Prepare a controlled source file before typing into EUDAMED. The MDR technical documentation under Annexes II–III and the EU declaration of conformity are conformity evidence; they are not, as a rule, uploaded wholesale into the Actor or UDI/Devices registration form. They must remain available through the applicable compliance and surveillance processes.
| Input or evidence | What the team verifies | Submission or retention |
|---|---|---|
| Legal entity and role | Registered name, address, role, EU Login users, signed information-security responsibility declaration; non-EU manufacturer’s authorised representative and mandate summary | Actor module and validation by competent authority; keep signed source files. |
| Device identity | Intended purpose and MDR class rationale, Basic UDI-DI/UDI-DI allocation, EMDN code, variants/trade name and labelling consistency | Structured UDI/Devices entry; retain identifier/label crosswalk. |
| Conformity and certificate evidence | EU declaration of conformity, Annex II–III technical file, assessment route and certificate scope where required | Maintain controlled evidence; coordinate notified body’s certificate record and links. |
| French local data | Whether there is a qualifying distributor, custom-made manufacture, French sterilisation or materiovigilance-correspondent requirement | If applicable, ANSM activity or correspondent form, separate from EU device record. |
| Transition and change baseline | First placing-on-market date, continued supply after 28 May 2026, legacy status, current EUDAMED or prior ANSM record | Classify migration deadline and create the post-filing change log. |
Legacy identifier gate. Ordinary MDR regulation-device submissions need both a Basic UDI-DI and a UDI-DI. An MDD/AIMDD legacy record instead uses an EUDAMED DI, with an existing UDI-DI if assigned or an EUDAMED ID if no UDI-DI exists. Before applying the 28 November 2026 backfill deadline, verify the device's Article 120 transitional status, whether additional units have been placed on the EU market from 28 May 2026, and whether an MDR device entry already covers it. A prior ANSM national registration is not itself an EUDAMED entry.
From intake to accepted records: operational sequence
- Identify the legal manufacturer, importers, authorised representative and actual French activities; separate MDR from IVDR products and mark custom-made or legacy status. Do not file under a distributor’s name merely because it sells in France.
- Freeze the device register: intended purpose, classification rationale, models, Basic UDI-DI/UDI-DI, EMDN, labels, declarations, and notified-body identifiers. Resolve inconsistencies before entry.
- Open the correct EU Login/Actor request and attach the signed information-security declaration; a non-EU manufacturer also needs the active EU representative and mandate summary. Track authority validation and obtain the SRN where applicable.
- Assign approved EUDAMED user access; submit device data under the proper actor, linking Basic UDI-DI, UDI-DI, EMDN and certificate references. Check system validation messages and keep submission evidence.
- Coordinate certificate data with the notified body when required. Separately test ANSM’s French declaration categories and register the materiovigilance correspondent where the French rule applies.
- Reconcile published records against labels, conformity documents and internal registers; log acknowledgements, outstanding authority questions, owner and due date. Do not treat a pending or incomplete record as a clearance.
- Install maintenance controls for changed company data, devices, certificates, discontinuations and safety events; keep a designated regulatory owner and review dates.
France-specific branch: ANSM is not a substitute for EUDAMED
ANSM’s guidance dated 7 August 2026 distinguishes EUDAMED registration from declarations required under the French Public Health Code. Certain distributors operating in France must declare their activity to ANSM even though ordinary distributors do not obtain an EUDAMED SRN as distributors. Manufacturers (or their representatives) of custom-made devices and specified persons conducting sterilisation in France have their own national-declaration route. A manufacturer placing a device on the French market, or its representative, must also examine the French requirement to declare a materiovigilance correspondent.
For the ANSM route, use the agency’s published declaration form and supporting documents; ANSM lists communications.dm@ansm.sante.fr for activity declarations and contact.eudamed@ansm.sante.fr for Actor-module questions. Do not send a general device “approval request” in lieu of the proper portal entry. French-specific requirements depend on the operator’s precise activity, not simply on a French customer address.
ANSM specifies that the completed French declaration form and supporting documents should preferably be sent by email to communications.dm@ansm.sante.fr; postal registered delivery is an alternative. This is a separate submission from the EUDAMED portal.
What actually delays an EUDAMED or ANSM filing?
- Actor application conflicts with company identity records, lacks the signed information-security declaration, or a non-EU manufacturer has no validated authorised-representative linkage.
- A Basic UDI-DI is created without the matching UDI-DI, or trade names, model variants and EMDN codes contradict the controlled product register.
- Device certificate references or intended purpose do not align with the notified body’s recorded certificate scope; entry into a database cannot cure absent conformity assessment.
- A French distributor is incorrectly treated as an EUDAMED manufacturer, or a national activity/correspondent declaration is missed because the EU device record exists.
- A pre-28 May 2026 or legacy product is assumed exempt from migration without checking continued placing on the market and the 28 November 2026 registration deadline.
Filing completion and continuing maintenance
A useful registration-service handover is a responsibility matrix, frozen input register, filing screenshots/confirmations, SRN and device-record references where issued, an ANSM declaration receipt where applicable, and an issue-and-change tracker. These are service deliverables, not evidence that ANSM certified the device. The manufacturer retains the MDR conformity obligation and must oversee subsequent corrections, changes, PMS/vigilance and records. EUDAMED vigilance and clinical-investigation modules are not yet part of the four mandatory modules; applicable reporting routes continue separately.
For devices already placed on the market before 28 May 2026 that continue to be placed afterwards, ANSM identifies 28 November 2026 as the relevant UDI/Devices migration deadline for the stated categories. Check applicability rather than assuming every historical device must be entered. Review official guidance again when an EUDAMED module or national filing procedure changes.
Before instructing a filing agent
Ask for a product-by-product scope list, confirmation of who holds the manufacturer role, evidence of valid MDR conformity, actor access authority and an explicit split between EUDAMED entries, any notified-body action and ANSM declarations. No filing consultant can promise SRN approval by an authority, a particular review time or automatic permission to sell. For wider EU registration planning see the EU-wide MDR registration workflow page; for classification or conformity strategy rather than submission handling see MDR regulatory strategy; for broader CE-marking project execution in France see CE-marking execution in France.
Frequently asked filing questions
Can an EUDAMED SRN replace CE marking or an MDR certificate?
No. An SRN identifies an economic operator; device registration is separate from conformity assessment. Check the applicable MDR route, EU declaration of conformity and any required notified-body certificate before market entry.
Does a French distributor register its devices in EUDAMED?
The manufacturer is responsible for UDI/Devices registration. An ordinary distributor does not register as an EUDAMED actor solely in that role, but specified non-retail distribution activities in France must be declared to ANSM.
Can a non-EU manufacturer file without an EU authorised representative?
For the ordinary MDR route, no. The EUDAMED actor application for a non-EU manufacturer requires an active EU authorised representative and mandate summary; verify representative details and linkage before submission.
What if the device was already on the market before 28 May 2026?
Check whether it continues to be placed on the EU market and whether it is a legacy or regulation device. The ANSM/EU transition rules identify 28 November 2026 for relevant existing entries; not all historical devices follow the same record requirement.
Do custom-made devices follow the normal UDI/Devices procedure?
Not generally. French national declaration rules still matter. ANSM separately identifies class III implantable custom-made devices and specified serious-incident cases needing EUDAMED registration; determine the special path before filing.
Can an Actor ID be used as an SRN for a system/procedure-pack producer?
No. EUDAMED assigns an Actor ID, rather than an Article 31 SRN, to the ordinary Article 22(1)–(3) system/procedure-pack producer. Check whether Article 22(4) instead makes the pack a device in its own right; in that case, manufacturer registration responsibilities apply.
Official legal and procedural sources
- ANSM: operator and device filing procedures
- European Commission: Actor registration
- European Commission: UDI/Device registration
- European Commission: EUDAMED roll-out and deadlines
- Regulation (EU) 2017/745 (MDR)
- Regulation (EU) 2024/1860: phased EUDAMED transition
- Commission EUDAMED Help: legacy device identifier rules
- Commission services: phased EUDAMED registration Q&A (guidance)
- MDCG 2021-13 Rev. 1: Actor ID versus SRN (guidance)