RPlay
A consignment implant carrying its UDI label, ready for traceability

Regulatory brief · EU Medical Device Regulation

EUDAMED is mandatory.Here's what it means for your pharmacy.

A short read for hospital pharmacists, quality officers and pharmacy directors. No legal jargon, no marketing fluff — just the obligations, the deadlines, and a clear answer on what you need to put in place today.

Book a 30-minute compliance review7 minute read · updated May 2026

The short version

If you only read one box, read this one.

  1. 01

    What it is

    EUDAMED is the European Commission's central database for medical devices placed on the EU market.

  2. 02

    Who runs it

    The Commission hosts it. Manufacturers, importers, notified bodies and authorised representatives populate it. Hospitals consume it.

  3. 03

    What is mandatory

    Four EUDAMED modules (Actor, UDI / Device, Notified Bodies & Certificates, Market Surveillance) are now in mandatory use across the EU.

  4. 04

    What hospitals must do

    Maintain a clean, per-implant audit trail and be able to produce traceability data on demand — inspector, supplier dispute, recall.

  5. 05

    Where RPlay fits

    Capture the UDI on intake, track every movement automatically, retain records for seven years, export on demand.

The basics

One database. Every medical device on the EU market.

EUDAMED stands for the European Database on Medical Devices. It is the central register built under the EU Medical Device Regulation (MDR 2017/745) and the In-Vitro Diagnostic Regulation (IVDR 2017/746). Its purpose is straightforward: anyone — regulator, hospital, patient — should be able to look up a medical device on the EU market and find a clean, authoritative record of what it is, who made it, where it was certified, and how it has performed in the field.

The Commission hosts the database; the work of keeping it accurate falls on the people closest to each device. Manufacturers register their devices. Importers and authorised representatives register themselves. Notified bodies upload their certificates. Market surveillance authorities log incidents. Hospitals are the consumers of all this data — and, increasingly, the people who must demonstrate that the implants they used can be traced back to their EUDAMED record.

Modules in mandatory use

Four modules. One that matters most for your pharmacy.

EUDAMED is organised as six modules; four are now in mandatory use across the EU. Here is what each one is for, and which one drives your day-to-day work.

1

Actor registration

Who registers
Manufacturers, authorised representatives, importers, system and procedure pack producers.
What it captures
The legal identity of every economic operator placing devices on the EU market.
Why hospitals care
You can look up the actor behind any device on your shelf. If a supplier dispute escalates, you have an authoritative reference.
2The one that matters most

UDI / Device registration

Who registers
Manufacturers.
What it captures
Every device, with its Unique Device Identifier (UDI), product details, model variants, GMDN code, and certification status.
Why hospitals care
This is the module that operationalises traceability. Every implant in your pharmacy has — or will have — a UDI in EUDAMED. Your job is to be able to link your physical stock to those records, and to demonstrate the link on demand.
3

Notified Bodies & Certificates

Who registers
Notified bodies (the organisations that certify CE marking).
What it captures
Certificates, scopes, validity windows, suspensions and withdrawals.
Why hospitals care
You can verify that the CE mark on an implant is backed by a current certificate. Useful for procurement due-diligence and for recall response.
4

Market Surveillance

Who registers
National competent authorities and manufacturers.
What it captures
Field safety corrective actions (FSCA), serious incidents, post-market surveillance reports.
Why hospitals care
Recalls and field safety notices land here first. The earlier you can match a UDI in the surveillance feed to implants on your shelf, the faster you act.

The bottom line for pharmacy operations. Module 2 (UDI / Device) is the one that touches your daily work. Modules 1, 3 and 4 give you context and look-up power; module 2 is the obligation that shapes how you receive, store, use and report on implants.

Key dates

A short timeline. Long consequences.

EUDAMED's mandatory-use date triggered a chain of obligations. Three dates matter to a hospital pharmacy.

28 May 2026

Mandatory use begins

The four EUDAMED modules become mandatory across the EU. From this date, new devices placed on the EU market must be registered in EUDAMED before they reach a hospital shelf. The grace period for registering legacy devices already on the market starts to run.

28 November 2026

Legacy registration deadline

Devices that were already on the EU market on 28 May 2026 must also be registered in EUDAMED by this date. After 28 November 2026 the grace window closes — every implant on the market is expected to have a EUDAMED record behind it.

Ongoing

Traceability on demand

From the moment EUDAMED's modules went mandatory, the obligation to trace a specific implant on demand is permanent. Inspectors, suppliers in a dispute, and post-market surveillance teams can ask at any time. Pharmacies need an audit trail that answers them in minutes, not weeks.

Manufacturers register devices in EUDAMED, not hospitals. The hospital's obligation is to be able to look up a device by its UDI and demonstrate physical traceability — what arrived, where it went, when it was consumed.

The practical changes

Four things you need on the shelf, on the screen, and in the archive.

Hospitals are not asked to become EUDAMED data entry teams. You are asked to keep clean records and produce them on demand. In practice that means four things.

1

Capture the UDI of every implant on intake

The UDI is the bridge between your physical stock and the EUDAMED record. If the UDI is not captured cleanly at intake — typed wrong, stuck to the wrong label, or simply lost — every downstream obligation becomes harder.

2

Maintain a per-implant audit trail

Arrival date and time, lot number, expiry date, every storage location, every transfer between rooms, the consumption event, the procedure or case reference. An immutable history, not a snapshot.

3

Produce traceability data on demand

An inspector arrives. A supplier disputes a usage report. A field safety notice lands. You need to filter by UDI, by lot, by manufacturer, by date range — and produce a clean export within minutes.

4

Retain records for at least seven years

Medical device traceability rules already require seven-year retention for consumption events. With EUDAMED in force, the retention bar is higher in practice — recall windows can reach decades for some implant classes.

The honest answer about Excel.

Spreadsheets can capture UDIs, in theory. In practice, they break on three things:

  • Transcription errors. A UDI typed by hand is a UDI in the wrong cell ten times out of a hundred.
  • No event history. A spreadsheet snapshots the present. The moment an implant moves rooms, the previous-location information is overwritten unless someone manually keeps a log.
  • No structured queries. Filtering 12,000 rows by UDI is fine. Filtering by “implants from supplier X used between January and March” is fine. Doing both at once, on a copy that's seven years old, with a colleague who no longer works at the hospital — that is where Excel-based traceability falls over.

The mapping

Every EUDAMED obligation, mapped to a feature.

Capture the UDI on intake
The RPlay document scanner reads the UDI from the GS1 barcode on the manufacturer's label and links it to a reusable RPlay Smart Sticker in a single capture. No typing.
Maintain a per-implant audit trail
Every arrival, transfer, consumption and waste event is recorded automatically as the implant moves between rooms. Immutable event history.
Produce traceability data on demand
Export by date range, by UDI, by lot, by location, by product category. CSV and Excel. Filterable on screen, exportable in two clicks.
Recall response — find every affected implant fast
Filter by UDI or lot. The platform returns current location for every unit still on the shelf, and consumption details for every unit already used.
Retain records for 7+ years
Seven-year retention default on consumption and movement events. Configurable longer for implant classes with extended liability windows.
Connect to manufacturer reporting flows
REST API and webhooks so your hospital quality system can push to a manufacturer's EUDAMED reporting flow, or pull a clean record into your own archive.

Smart Inventory is not a EUDAMED submission system — that obligation sits with manufacturers. It is the hospital-side audit trail that proves what arrived, where it went, and when it was used.

Questions we get

Six questions a pharmacist actually asks.

  1. 01

    As a hospital, do I have to register devices in EUDAMED myself?

    No. Device registration is the manufacturer's obligation. The hospital's job is to be able to look up a device by its UDI and demonstrate physical traceability through your facility.

  2. 02

    What is the difference between MDR and EUDAMED?

    MDR (Medical Device Regulation 2017/745) is the regulation — the law. EUDAMED is the operational database that holds the actor, device, certificate and surveillance records the regulation requires. MDR sets the obligations; EUDAMED is where most of those obligations are evidenced.

  3. 03

    Does this apply to legacy stock I already have on the shelf?

    Yes. Devices already on the EU market on 28 May 2026 must be registered in EUDAMED by 28 November 2026 — a six-month grace window. Your traceability obligation for those implants starts the day they arrive at your pharmacy.

  4. 04

    What about exempted implants — sutures, screws, dental fillings?

    MDR Article 18 (the patient implant card) carries an exemption list: sutures, staples, dental fillings, dental braces, tooth crowns, screws, wedges, plates, wires, pins, clips and connectors. The patient-card obligation is lighter for these items. Traceability through EUDAMED still applies. RPlay Smart Inventory tracks them the same way as any other tagged implant.

  5. 05

    How quickly can RPlay Smart Inventory be operational?

    Most hospitals are live within ten working days of the kit arriving on site. There is no IT project — the Edge Gateway is pre-configured and connects over 4G/LTE out of the box.

  6. 06

    What happens if I get audited tomorrow?

    Smart Inventory has a built-in audit export. PDF or CSV, by date range, by product, by location, by UDI. You produce the artefact the inspector asks for, on the spot, from any browser.

Ready?

Book a 30-minute compliance review.

We'll look at your pharmacy's current traceability set-up, identify the gaps EUDAMED will expose, and tell you honestly whether Smart Inventory is the right answer for you. No commitment, no slide deck, no follow-up sales sequence — just a working session.

We answer within one working day. The person on the call will have read your note before they pick up.