Iceland medical device registration timeline
Source-linked clocksLyfjastofnun (Icelandic Medicines Agency) (Lyfjastofnun) review clocks and end-to-end planning ranges, using the 4-class (I, IIa, IIb, III) — EU MDR as incorporated into the EEA Agreement classification system.
| Class / pathway | Review clock | Planning total | With prior approval | Provenance |
|---|---|---|---|---|
| Class I(Self-declaration (no notified body)) MDR Art. 52(7): a Class I device that is not sterile, has no measuring function and is not a reusable surgical instrument is self-declared by the manufacturer, so no authority and no notified body reviews the file and there is no review clock to publish. The regulation has the force of law in Iceland under 2. gr. laga um lækningatæki nr. 132/2020, which is why an MDR article fixes the Icelandic row. | 0 days | 6-9 months | — | Verified |
Planning steps and estimates; these are not regulator deadlines.
Iceland Medical Device Registration Process
Step-by-step Lyfjastofnun registration process. Total estimated timeline: 6-9 months.
Step 1: Pre-Submission Preparation
1-3 monthsGather technical documentation, quality management system (QMS) records, and clinical data required by Lyfjastofnun. Appoint a EEA authorised representative (viðurkenndur fulltrúi).
Step 2: Application Submission
1-2 weeksSubmit complete registration dossier to Lyfjastofnun including device description, risk analysis, and testing reports.
Step 3: Administrative Review
2-4 weeksLyfjastofnun reviews application for completeness. May request additional documents or clarifications.
Step 4: Technical Evaluation
0 daysIn-depth technical assessment of device safety and performance. Lyfjastofnun may issue questions.
Step 5: Registration Approval
1-2 weeksUpon successful review, Lyfjastofnun issues Iceland market authorization certificate.
- No national device registration and no import licence: Lyfjastofnun keeps no register of individual medical devices, and a device that is lawful on the European market and in Iceland may be imported and distributed without a national permit. Iceland operates no import licence, no establishment permit and no device-by-device customs clearance.
- An authorised representative established in the EEA — 'viðurkenndur fulltrúi' — is required where the manufacturer is not established in the EEA; Act 132/2020 defines the role as a natural or legal person established in the European Economic Area holding a written mandate from the manufacturer.
- Distributors must be registered with Lyfjastofnun under 3. mgr. 28. gr. laga um lækningatæki nr. 132/2020. The registration charge is ISK 53,400 (item 2.1 of gjaldskrá nr. 1529/2025) with a separate ISK 26,700 maintenance charge (item 2.2).
- Manufacturers of devices other than custom-made devices, authorised representatives and importers must register in the electronic operator-registration system under Chapter III of the Regulations; this registers the operator, not the device.
- Icelandic-language labelling and instructions: reglugerð nr. 630/2022 Article 3 requires information and instructions for use intended for the general public to be in Icelandic, while a Class I or IIa device may carry English or a Nordic language other than Finnish; for professional use the instructions may be in English or a Nordic language other than Finnish.
- EUDAMED actor and device registration as given effect in Iceland by reglugerð nr. 907/2022; the agency's EUDAMED page has not been updated since 21 October 2021 and still describes registration as not yet obligatory, which disagrees with the regulation.
- Six months' notice to Lyfjastofnun, and to the distributors concerned, before an interruption or discontinuation of supply that could lead to serious harm or a shortage — 36. gr. b of Act 132/2020, inserted by lög nr. 69/2025.
- Vigilance: a manufacturer that learns a device of its manufacture may have caused or has caused an incident must send an initial report to Lyfjastofnun within the Regulation's time limits — immediately for a serious public-health threat, within 2 days for death or serious deterioration, within 10 days for other serious incidents — and anyone who produces, sells, owns or uses devices must report a deviation, defect or malfunction without delay.
- Devices emitting ionizing radiation additionally need a licence from Geislavarnir ríkisins under 7. gr. laga nr. 44/2002 for their use in Iceland, with periodic inspection paid for under 19. gr.
- Devices that are legal measuring instruments additionally need conformity assessment before first use and löggilding by or under HMS under lög nr. 91/2006, at a löggildingargjald of 15-25% of the service fee.
- Radio equipment, including a radio-capable device, must comply with reglugerð nr. 944/2019 and bear CE marking to be placed on the market or taken into use in Iceland; Fjarskiptastofa is the market-surveillance authority and the information for Icelandic users must be in Icelandic, English or a Nordic language other than Finnish.
- Electrically powered equipment placed on the Icelandic market is subject to the úrvinnslugjald under reglugerð nr. 442/2015, 6. gr. 2. mgr., unless the manufacturer and importer pay it; producer responsibility for the waste stream is administered by Úrvinnslusjóður.
- Administrative decisions under the Medical Devices Act may be appealed to the Minister of Health under the Icelandic Public Administration Act, unless the Act provides otherwise.
Reviewed 2026-09-16. End-to-end totals remain planning estimates.