CE certificate validity (5 years max) and the MDR transition dates as at 2026-09-15
The substantive term of a device's approval is the CE certificate: a notified-body certificate is valid for the period it indicates, which may not exceed five years, and may be extended for further periods of up to five years each on re-assessment. Directive-era certificates are governed by the transitional regime as amended by Regulation (EU) 2023/607: certificates issued under Directive 90/385/EEC or 93/42/EEC from 25 May 2017 that were still valid on 26 May 2021 remain valid until 31 December 2027 for class III devices and class IIb implantable devices, and until 31 December 2028 for other class IIb devices, class IIa devices and class I devices placed on the market sterile or with a measuring function. As at 15 September 2026 the extended dates are still in the future and no further extension has been adopted.
- The transitional validity is conditional, including a quality management system in place by 26 May 2024 and a notified-body agreement, and no significant changes in design or intended purpose (MDR Art. 120(3c)).
- Devices whose Directive-era conformity assessment did not involve a notified body but which require one under the MDR may be placed on the market until 31 December 2028 (MDR Art. 120(3b)).
- Maltese national registrations run alongside and renew annually on their own cycle.
Effective from 2023-03-20
Verbatim from the amending Regulation: '(a) 31 December 2027, for all class III devices, and for class IIb implantable devices except sutures, staples, dental fillings, dental braces, tooth crowns, screws, wedges, plates, wires, pins, clips and connectors; (b) 31 December 2028, for class IIb devices other than those covered by point (a) of this paragraph, for class IIa devices, and for class I devices placed on the market in sterile condition or having a measuring function.' The five-year certificate limit is verbatim from MDR Art. 56(2) (source res-eu-mdr-2017-745): 'The certificates shall be valid for the period they indicate, which shall not exceed five years.'

