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INFARMED · structured requirements

🇵🇹 Portugal IVD regulatory data

Explore the IVD requirements currently available for Portugal, organized by topic and linked to official sources.

21 facts12 dimensions17 official sourceslatest verification 2026-10-21

Changes after registration in Portugal

Source-linked rules for common changes to a registered IVD. Read the scope and conditions with each rule; unverified details are listed separately.

Does changing a device brand name or logo require an update?

A change to the registered brand name and a change to logo artwork can follow different rules. The legal manufacturer, device design and intended purpose remain the same.

  • Filing route and prior approval

Assess certificate and quality-system impact with the notified body

Fact-level verified

Under the Annex IX route, plans for substantial changes to the quality system or device range must be notified to the notified body for assessment and any required additional audit or approval supplement. Changes to an approved device that could affect safety, performance or conditions of use require the notified body’s assessment of whether a new conformity assessment or certificate supplement is necessary. A logo, office or order-code edit does not by itself prove that every technical-change threshold is met.

Conditions
  • This is a conformity-assessment and certificate-scope rule where a notified body/Annex IX route applies; it is not a national one-form, one-fee or universal prior-approval rule.
  • Filing route and prior approval
  • Labels and identifiers

A commercial REF is distinct from UDI and actor data

Fact-level verified

EU device-registration data distinguish trade name from model/reference/catalogue number. A new UDI-DI is required for listed changes including device name/trade name or version/model where the applicable UDI rules are triggered; a REF edit is not automatically a new UDI. Changes to actor information must be updated within one week under MDR Article 31 or IVDR Article 28, and UDI-database changes not requiring a new UDI-DI within thirty days under Annex VI Part C 5.8.

Conditions
  • These are operator data-maintenance periods, not authority review SLAs. Confirm the applicable device type, UDI implementation and EUDAMED transition stage.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

Update SIDM device records to match EUDAMED

Fact-level verified

INFARMED instructs manufacturers/representatives and distributors using the applicable SIDM pathways to reuse EUDAMED identity by UDI-DI/EUDAMED ID and upload labelling, instructions and the declaration. Existing SIDM records must be updated to align with EUDAMED; the current FAQ describes the CDM-to-UDI-DI association while retaining existing documents. A CDM, UDI-DI and the manufacturer’s commercial REF are different identifiers.

Conditions
  • Use the actual economic-operator role and device record. Data alignment does not itself approve a new legal manufacturer or a bundle of substantive changes.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

IVD distribution records remain a national layer

Fact-level verified

INFARMED’s current registration page expressly retains Decreto-Lei 189/2000 Article 12 for IVD distributors. That provision identifies the distributor and legal address, product list with brand/model/version and the required product/documentation particulars. Apply the current SIDM instructions and keep changed identity and device records aligned with EUDAMED; this retained national duty does not reinstate superseded IVDD conformity-assessment routes.

  • Labels and identifiers

IVD labels and IFU in Portuguese

Fact-level verified

INFARMED requires labels and instructions for use of IVDs to be written in Portuguese, legible and indelible, regardless of whether use is professional, without prejudice to other languages also being included.

Conditions
  • Applies to IVDs placed on the Portuguese market.
  • Supporting documents
  • Labels and identifiers

Align manufacturer identity, labels and the EU declaration

Fact-level verified

For MDR devices and IVDR IVDs, the EU declaration of conformity must be kept current. Its Annex IV identity includes the manufacturer and, where relevant, authorised representative, registered place of business, Basic UDI-DI and traceable product/trade name or product-code information. The label must identify the responsible manufacturer and its registered business address and the authorised representative where required. Update the affected declaration and supplied information when these particulars change.

Conditions
  • Apply MDR Article 19/Annex I 23 to MDs and IVDR Article 17/Annex I 20 to IVDs. A legal office and a manufacturing site are not interchangeable fields.
  • The device route must require an EU declaration of conformity. These are ongoing label/declaration obligations, not a complete national amendment checklist.
  • Existing stock and transition

Legacy sell-through depends on lawful prior placement

Fact-level verified

The amended MDR Article 120(4) and IVDR Article 110(4) allow the specified devices lawfully placed under the former Directives or applicable transition provisions to continue to be made available or put into service. This is conditional on lawful placement of the actual units; it is not permission to place new nonconforming units, to keep an inaccurate post-change manufacturer identity, or to apply a universal old-label grace period.

Conditions
  • Establish unit-level placement dates, Directive/Regulation status, conformity, traceability and the actual change. Other stock routes and nonconforming inventory require a separate assessment.
  • Free sale certificate impact

Portuguese CFS is a separate export certificate snapshot

Fact-level verified

INFARMED’s free-sale certificate service is for national manufacturers or authorised representatives exporting outside the EU. Request it through the current SIDM route using the applicable regulatory category and device data; one certificate covers devices under the same regulatory diploma. The certificate records the market position on its issue date rather than having a fixed expiry. The published charge is EUR 30.69 for up to four sheets and EUR 15.35 per additional set of up to four; payment cannot be reused or transferred.

Conditions
  • A Portuguese-issued export certificate is requested only where needed for the destination. The procedure does not establish automatic reissuance after every name, office or REF change; establish the applicant role, device regime and identity the certificate must attest.

How do I update a manufacturer's name without changing the legal entity?

The same legal manufacturer changes its name, potentially alongside the device brand. A transfer to another legal entity is a separate question; permission to combine filings needs its own evidence.

  • Filing route and prior approval

Assess certificate and quality-system impact with the notified body

Fact-level verified

Under the Annex IX route, plans for substantial changes to the quality system or device range must be notified to the notified body for assessment and any required additional audit or approval supplement. Changes to an approved device that could affect safety, performance or conditions of use require the notified body’s assessment of whether a new conformity assessment or certificate supplement is necessary. A logo, office or order-code edit does not by itself prove that every technical-change threshold is met.

Conditions
  • This is a conformity-assessment and certificate-scope rule where a notified body/Annex IX route applies; it is not a national one-form, one-fee or universal prior-approval rule.
  • Filing route and prior approval
  • Labels and identifiers

A commercial REF is distinct from UDI and actor data

Fact-level verified

EU device-registration data distinguish trade name from model/reference/catalogue number. A new UDI-DI is required for listed changes including device name/trade name or version/model where the applicable UDI rules are triggered; a REF edit is not automatically a new UDI. Changes to actor information must be updated within one week under MDR Article 31 or IVDR Article 28, and UDI-database changes not requiring a new UDI-DI within thirty days under Annex VI Part C 5.8.

Conditions
  • These are operator data-maintenance periods, not authority review SLAs. Confirm the applicable device type, UDI implementation and EUDAMED transition stage.
  • Filing route and prior approval

A legacy IVD identity edit still needs certificate and role assessment

Fact-level verified

MDCG 2022-6 treats administrative changes to manufacturer name, address, legal form or representative as generally not changes to design or intended purpose; agreed notified-body/QMS notification remains applicable. This significance test does not by itself authorise assignment of a certificate or portfolio to a new manufacturer. Establish the continuing legal person, certificate scope and current IVDR transition eligibility.

Conditions
  • The original guidance’s 2025 end-date must not replace the later amended Article 110 dates and conditions.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

Update SIDM device records to match EUDAMED

Fact-level verified

INFARMED instructs manufacturers/representatives and distributors using the applicable SIDM pathways to reuse EUDAMED identity by UDI-DI/EUDAMED ID and upload labelling, instructions and the declaration. Existing SIDM records must be updated to align with EUDAMED; the current FAQ describes the CDM-to-UDI-DI association while retaining existing documents. A CDM, UDI-DI and the manufacturer’s commercial REF are different identifiers.

Conditions
  • Use the actual economic-operator role and device record. Data alignment does not itself approve a new legal manufacturer or a bundle of substantive changes.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

IVD distribution records remain a national layer

Fact-level verified

INFARMED’s current registration page expressly retains Decreto-Lei 189/2000 Article 12 for IVD distributors. That provision identifies the distributor and legal address, product list with brand/model/version and the required product/documentation particulars. Apply the current SIDM instructions and keep changed identity and device records aligned with EUDAMED; this retained national duty does not reinstate superseded IVDD conformity-assessment routes.

  • Supporting documents
  • Labels and identifiers

Align manufacturer identity, labels and the EU declaration

Fact-level verified

For MDR devices and IVDR IVDs, the EU declaration of conformity must be kept current. Its Annex IV identity includes the manufacturer and, where relevant, authorised representative, registered place of business, Basic UDI-DI and traceable product/trade name or product-code information. The label must identify the responsible manufacturer and its registered business address and the authorised representative where required. Update the affected declaration and supplied information when these particulars change.

Conditions
  • Apply MDR Article 19/Annex I 23 to MDs and IVDR Article 17/Annex I 20 to IVDs. A legal office and a manufacturing site are not interchangeable fields.
  • The device route must require an EU declaration of conformity. These are ongoing label/declaration obligations, not a complete national amendment checklist.
  • Existing stock and transition

Legacy sell-through depends on lawful prior placement

Fact-level verified

The amended MDR Article 120(4) and IVDR Article 110(4) allow the specified devices lawfully placed under the former Directives or applicable transition provisions to continue to be made available or put into service. This is conditional on lawful placement of the actual units; it is not permission to place new nonconforming units, to keep an inaccurate post-change manufacturer identity, or to apply a universal old-label grace period.

Conditions
  • Establish unit-level placement dates, Directive/Regulation status, conformity, traceability and the actual change. Other stock routes and nonconforming inventory require a separate assessment.
  • Free sale certificate impact

Portuguese CFS is a separate export certificate snapshot

Fact-level verified

INFARMED’s free-sale certificate service is for national manufacturers or authorised representatives exporting outside the EU. Request it through the current SIDM route using the applicable regulatory category and device data; one certificate covers devices under the same regulatory diploma. The certificate records the market position on its issue date rather than having a fixed expiry. The published charge is EUR 30.69 for up to four sheets and EUR 15.35 per additional set of up to four; payment cannot be reused or transferred.

Conditions
  • A Portuguese-issued export certificate is requested only where needed for the destination. The procedure does not establish automatic reissuance after every name, office or REF change; establish the applicant role, device regime and identity the certificate must attest.
  • Labels and identifiers

IVD labels and IFU in Portuguese

Fact-level verified

INFARMED requires labels and instructions for use of IVDs to be written in Portuguese, legible and indelible, regardless of whether use is professional, without prejudice to other languages also being included.

Conditions
  • Applies to IVDs placed on the Portuguese market.

What changes when the manufacturer's office address changes?

An office address change for the same legal entity, potentially alongside name and brand changes. This does not cover moving a factory or manufacturing site, and a combined filing cannot be assumed.

  • Filing route and prior approval

Assess certificate and quality-system impact with the notified body

Fact-level verified

Under the Annex IX route, plans for substantial changes to the quality system or device range must be notified to the notified body for assessment and any required additional audit or approval supplement. Changes to an approved device that could affect safety, performance or conditions of use require the notified body’s assessment of whether a new conformity assessment or certificate supplement is necessary. A logo, office or order-code edit does not by itself prove that every technical-change threshold is met.

Conditions
  • This is a conformity-assessment and certificate-scope rule where a notified body/Annex IX route applies; it is not a national one-form, one-fee or universal prior-approval rule.
  • Filing route and prior approval
  • Labels and identifiers

A commercial REF is distinct from UDI and actor data

Fact-level verified

EU device-registration data distinguish trade name from model/reference/catalogue number. A new UDI-DI is required for listed changes including device name/trade name or version/model where the applicable UDI rules are triggered; a REF edit is not automatically a new UDI. Changes to actor information must be updated within one week under MDR Article 31 or IVDR Article 28, and UDI-database changes not requiring a new UDI-DI within thirty days under Annex VI Part C 5.8.

Conditions
  • These are operator data-maintenance periods, not authority review SLAs. Confirm the applicable device type, UDI implementation and EUDAMED transition stage.
  • Filing route and prior approval

A legacy IVD identity edit still needs certificate and role assessment

Fact-level verified

MDCG 2022-6 treats administrative changes to manufacturer name, address, legal form or representative as generally not changes to design or intended purpose; agreed notified-body/QMS notification remains applicable. This significance test does not by itself authorise assignment of a certificate or portfolio to a new manufacturer. Establish the continuing legal person, certificate scope and current IVDR transition eligibility.

Conditions
  • The original guidance’s 2025 end-date must not replace the later amended Article 110 dates and conditions.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

Update SIDM device records to match EUDAMED

Fact-level verified

INFARMED instructs manufacturers/representatives and distributors using the applicable SIDM pathways to reuse EUDAMED identity by UDI-DI/EUDAMED ID and upload labelling, instructions and the declaration. Existing SIDM records must be updated to align with EUDAMED; the current FAQ describes the CDM-to-UDI-DI association while retaining existing documents. A CDM, UDI-DI and the manufacturer’s commercial REF are different identifiers.

Conditions
  • Use the actual economic-operator role and device record. Data alignment does not itself approve a new legal manufacturer or a bundle of substantive changes.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

IVD distribution records remain a national layer

Fact-level verified

INFARMED’s current registration page expressly retains Decreto-Lei 189/2000 Article 12 for IVD distributors. That provision identifies the distributor and legal address, product list with brand/model/version and the required product/documentation particulars. Apply the current SIDM instructions and keep changed identity and device records aligned with EUDAMED; this retained national duty does not reinstate superseded IVDD conformity-assessment routes.

  • Supporting documents
  • Labels and identifiers

Align manufacturer identity, labels and the EU declaration

Fact-level verified

For MDR devices and IVDR IVDs, the EU declaration of conformity must be kept current. Its Annex IV identity includes the manufacturer and, where relevant, authorised representative, registered place of business, Basic UDI-DI and traceable product/trade name or product-code information. The label must identify the responsible manufacturer and its registered business address and the authorised representative where required. Update the affected declaration and supplied information when these particulars change.

Conditions
  • Apply MDR Article 19/Annex I 23 to MDs and IVDR Article 17/Annex I 20 to IVDs. A legal office and a manufacturing site are not interchangeable fields.
  • The device route must require an EU declaration of conformity. These are ongoing label/declaration obligations, not a complete national amendment checklist.
  • Existing stock and transition

Legacy sell-through depends on lawful prior placement

Fact-level verified

The amended MDR Article 120(4) and IVDR Article 110(4) allow the specified devices lawfully placed under the former Directives or applicable transition provisions to continue to be made available or put into service. This is conditional on lawful placement of the actual units; it is not permission to place new nonconforming units, to keep an inaccurate post-change manufacturer identity, or to apply a universal old-label grace period.

Conditions
  • Establish unit-level placement dates, Directive/Regulation status, conformity, traceability and the actual change. Other stock routes and nonconforming inventory require a separate assessment.
  • Free sale certificate impact

Portuguese CFS is a separate export certificate snapshot

Fact-level verified

INFARMED’s free-sale certificate service is for national manufacturers or authorised representatives exporting outside the EU. Request it through the current SIDM route using the applicable regulatory category and device data; one certificate covers devices under the same regulatory diploma. The certificate records the market position on its issue date rather than having a fixed expiry. The published charge is EUR 30.69 for up to four sheets and EUR 15.35 per additional set of up to four; payment cannot be reused or transferred.

Conditions
  • A Portuguese-issued export certificate is requested only where needed for the destination. The procedure does not establish automatic reissuance after every name, office or REF change; establish the applicant role, device regime and identity the certificate must attest.
  • Labels and identifiers

IVD labels and IFU in Portuguese

Fact-level verified

INFARMED requires labels and instructions for use of IVDs to be written in Portuguese, legible and indelible, regardless of whether use is professional, without prejudice to other languages also being included.

Conditions
  • Applies to IVDs placed on the Portuguese market.

Does a catalogue or reference code change affect registration or UDI?

Check which identifier actually changes. A commercial catalogue, REF or order code is not automatically a device model, registered identifier, GTIN or UDI-DI. Rules for one identifier do not establish the route for another.

  • Filing route and prior approval

Assess certificate and quality-system impact with the notified body

Fact-level verified

Under the Annex IX route, plans for substantial changes to the quality system or device range must be notified to the notified body for assessment and any required additional audit or approval supplement. Changes to an approved device that could affect safety, performance or conditions of use require the notified body’s assessment of whether a new conformity assessment or certificate supplement is necessary. A logo, office or order-code edit does not by itself prove that every technical-change threshold is met.

Conditions
  • This is a conformity-assessment and certificate-scope rule where a notified body/Annex IX route applies; it is not a national one-form, one-fee or universal prior-approval rule.
  • Filing route and prior approval
  • Labels and identifiers

A commercial REF is distinct from UDI and actor data

Fact-level verified

EU device-registration data distinguish trade name from model/reference/catalogue number. A new UDI-DI is required for listed changes including device name/trade name or version/model where the applicable UDI rules are triggered; a REF edit is not automatically a new UDI. Changes to actor information must be updated within one week under MDR Article 31 or IVDR Article 28, and UDI-database changes not requiring a new UDI-DI within thirty days under Annex VI Part C 5.8.

Conditions
  • These are operator data-maintenance periods, not authority review SLAs. Confirm the applicable device type, UDI implementation and EUDAMED transition stage.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

Update SIDM device records to match EUDAMED

Fact-level verified

INFARMED instructs manufacturers/representatives and distributors using the applicable SIDM pathways to reuse EUDAMED identity by UDI-DI/EUDAMED ID and upload labelling, instructions and the declaration. Existing SIDM records must be updated to align with EUDAMED; the current FAQ describes the CDM-to-UDI-DI association while retaining existing documents. A CDM, UDI-DI and the manufacturer’s commercial REF are different identifiers.

Conditions
  • Use the actual economic-operator role and device record. Data alignment does not itself approve a new legal manufacturer or a bundle of substantive changes.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

IVD distribution records remain a national layer

Fact-level verified

INFARMED’s current registration page expressly retains Decreto-Lei 189/2000 Article 12 for IVD distributors. That provision identifies the distributor and legal address, product list with brand/model/version and the required product/documentation particulars. Apply the current SIDM instructions and keep changed identity and device records aligned with EUDAMED; this retained national duty does not reinstate superseded IVDD conformity-assessment routes.

  • Supporting documents
  • Labels and identifiers

Align manufacturer identity, labels and the EU declaration

Fact-level verified

For MDR devices and IVDR IVDs, the EU declaration of conformity must be kept current. Its Annex IV identity includes the manufacturer and, where relevant, authorised representative, registered place of business, Basic UDI-DI and traceable product/trade name or product-code information. The label must identify the responsible manufacturer and its registered business address and the authorised representative where required. Update the affected declaration and supplied information when these particulars change.

Conditions
  • Apply MDR Article 19/Annex I 23 to MDs and IVDR Article 17/Annex I 20 to IVDs. A legal office and a manufacturing site are not interchangeable fields.
  • The device route must require an EU declaration of conformity. These are ongoing label/declaration obligations, not a complete national amendment checklist.
  • Existing stock and transition

Legacy sell-through depends on lawful prior placement

Fact-level verified

The amended MDR Article 120(4) and IVDR Article 110(4) allow the specified devices lawfully placed under the former Directives or applicable transition provisions to continue to be made available or put into service. This is conditional on lawful placement of the actual units; it is not permission to place new nonconforming units, to keep an inaccurate post-change manufacturer identity, or to apply a universal old-label grace period.

Conditions
  • Establish unit-level placement dates, Directive/Regulation status, conformity, traceability and the actual change. Other stock routes and nonconforming inventory require a separate assessment.
  • Free sale certificate impact

Portuguese CFS is a separate export certificate snapshot

Fact-level verified

INFARMED’s free-sale certificate service is for national manufacturers or authorised representatives exporting outside the EU. Request it through the current SIDM route using the applicable regulatory category and device data; one certificate covers devices under the same regulatory diploma. The certificate records the market position on its issue date rather than having a fixed expiry. The published charge is EUR 30.69 for up to four sheets and EUR 15.35 per additional set of up to four; payment cannot be reused or transferred.

Conditions
  • A Portuguese-issued export certificate is requested only where needed for the destination. The procedure does not establish automatic reissuance after every name, office or REF change; establish the applicant role, device regime and identity the certificate must attest.
  • Labels and identifiers

IVD labels and IFU in Portuguese

Fact-level verified

INFARMED requires labels and instructions for use of IVDs to be written in Portuguese, legible and indelible, regardless of whether use is professional, without prejudice to other languages also being included.

Conditions
  • Applies to IVDs placed on the Portuguese market.

Can several changes be filed together?

Changes to brand, manufacturer name, office address and reference codes may occur together, including with a real transfer to another legal manufacturer, registration holder or owner. Assess transfer with each single change, and transfer with brand plus reference, manufacturer name plus reference, or office address plus reference changes: seven transfer combinations in total. Evidence must establish the exact combination and the order of filings and approvals. These combinations and their sequence are not all verified by the rules below; a rule for one change does not prove that a single application, fee or review period covers the combination.

  • Filing route and prior approval

Assess certificate and quality-system impact with the notified body

Fact-level verified

Under the Annex IX route, plans for substantial changes to the quality system or device range must be notified to the notified body for assessment and any required additional audit or approval supplement. Changes to an approved device that could affect safety, performance or conditions of use require the notified body’s assessment of whether a new conformity assessment or certificate supplement is necessary. A logo, office or order-code edit does not by itself prove that every technical-change threshold is met.

Conditions
  • This is a conformity-assessment and certificate-scope rule where a notified body/Annex IX route applies; it is not a national one-form, one-fee or universal prior-approval rule.
  • Filing route and prior approval
  • Labels and identifiers

A commercial REF is distinct from UDI and actor data

Fact-level verified

EU device-registration data distinguish trade name from model/reference/catalogue number. A new UDI-DI is required for listed changes including device name/trade name or version/model where the applicable UDI rules are triggered; a REF edit is not automatically a new UDI. Changes to actor information must be updated within one week under MDR Article 31 or IVDR Article 28, and UDI-database changes not requiring a new UDI-DI within thirty days under Annex VI Part C 5.8.

Conditions
  • These are operator data-maintenance periods, not authority review SLAs. Confirm the applicable device type, UDI implementation and EUDAMED transition stage.
  • Filing route and prior approval

A new legal manufacturer must meet the manufacturer obligations

Fact-level verified

A distributor, importer or other person that markets a device under its own name or trademark generally assumes the manufacturer obligations, subject to the agreement exception that keeps the original manufacturer identified and responsible on the label. Changing intended purpose or making a modification that may affect conformity has separate manufacturer-role consequences. The conditional translation/repackaging activities in Article 16(2) are exceptions, not automatic legal-manufacturer transfers.

Conditions
  • Identify the legal person responsible for conformity and whether the agreement exception actually applies. A share purchase or same-person rename does not by itself prove a transfer of device responsibility.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

An authorised-representative change needs an express handover

Fact-level verified

Where the authorised representative changes, the agreement must address termination/start dates, the date until which the outgoing representative may appear in manufacturer-supplied information, transfer of documents and property/confidentiality, and forwarding of complaints and incidents by the outgoing representative. This is the Article 12 representative handover rule; it does not assign a foreign manufacturer’s certificate or device portfolio to a new legal manufacturer.

Conditions
  • Only where the authorised representative actually changes; manufacturer succession and local importer/distributor changes require their separate assessment.
  • Filing route and prior approval

A legacy IVD identity edit still needs certificate and role assessment

Fact-level verified

MDCG 2022-6 treats administrative changes to manufacturer name, address, legal form or representative as generally not changes to design or intended purpose; agreed notified-body/QMS notification remains applicable. This significance test does not by itself authorise assignment of a certificate or portfolio to a new manufacturer. Establish the continuing legal person, certificate scope and current IVDR transition eligibility.

Conditions
  • The original guidance’s 2025 end-date must not replace the later amended Article 110 dates and conditions.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

Update SIDM device records to match EUDAMED

Fact-level verified

INFARMED instructs manufacturers/representatives and distributors using the applicable SIDM pathways to reuse EUDAMED identity by UDI-DI/EUDAMED ID and upload labelling, instructions and the declaration. Existing SIDM records must be updated to align with EUDAMED; the current FAQ describes the CDM-to-UDI-DI association while retaining existing documents. A CDM, UDI-DI and the manufacturer’s commercial REF are different identifiers.

Conditions
  • Use the actual economic-operator role and device record. Data alignment does not itself approve a new legal manufacturer or a bundle of substantive changes.
  • Filing route and prior approval
  • Supporting documents
  • Labels and identifiers

IVD distribution records remain a national layer

Fact-level verified

INFARMED’s current registration page expressly retains Decreto-Lei 189/2000 Article 12 for IVD distributors. That provision identifies the distributor and legal address, product list with brand/model/version and the required product/documentation particulars. Apply the current SIDM instructions and keep changed identity and device records aligned with EUDAMED; this retained national duty does not reinstate superseded IVDD conformity-assessment routes.

  • Supporting documents
  • Labels and identifiers

Align manufacturer identity, labels and the EU declaration

Fact-level verified

For MDR devices and IVDR IVDs, the EU declaration of conformity must be kept current. Its Annex IV identity includes the manufacturer and, where relevant, authorised representative, registered place of business, Basic UDI-DI and traceable product/trade name or product-code information. The label must identify the responsible manufacturer and its registered business address and the authorised representative where required. Update the affected declaration and supplied information when these particulars change.

Conditions
  • Apply MDR Article 19/Annex I 23 to MDs and IVDR Article 17/Annex I 20 to IVDs. A legal office and a manufacturing site are not interchangeable fields.
  • The device route must require an EU declaration of conformity. These are ongoing label/declaration obligations, not a complete national amendment checklist.
  • Existing stock and transition

Legacy sell-through depends on lawful prior placement

Fact-level verified

The amended MDR Article 120(4) and IVDR Article 110(4) allow the specified devices lawfully placed under the former Directives or applicable transition provisions to continue to be made available or put into service. This is conditional on lawful placement of the actual units; it is not permission to place new nonconforming units, to keep an inaccurate post-change manufacturer identity, or to apply a universal old-label grace period.

Conditions
  • Establish unit-level placement dates, Directive/Regulation status, conformity, traceability and the actual change. Other stock routes and nonconforming inventory require a separate assessment.
  • Free sale certificate impact

Portuguese CFS is a separate export certificate snapshot

Fact-level verified

INFARMED’s free-sale certificate service is for national manufacturers or authorised representatives exporting outside the EU. Request it through the current SIDM route using the applicable regulatory category and device data; one certificate covers devices under the same regulatory diploma. The certificate records the market position on its issue date rather than having a fixed expiry. The published charge is EUR 30.69 for up to four sheets and EUR 15.35 per additional set of up to four; payment cannot be reused or transferred.

Conditions
  • A Portuguese-issued export certificate is requested only where needed for the destination. The procedure does not establish automatic reissuance after every name, office or REF change; establish the applicant role, device regime and identity the certificate must attest.
  • Labels and identifiers

IVD labels and IFU in Portuguese

Fact-level verified

INFARMED requires labels and instructions for use of IVDs to be written in Portuguese, legible and indelible, regardless of whether use is professional, without prejudice to other languages also being included.

Conditions
  • Applies to IVDs placed on the Portuguese market.

Authority & regime

Which authority and binding regime govern this product, task, and date?

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National contact point for clinical investigations

authority.national-contact-point-mdr-ivdr
Fact-level verified

INFARMED, IP is the national entity responsible for applying Regulations (EU) 2017/745 and 2017/746 and the national contact point for the purposes of MDR Article 101 and IVDR Article 96.

Conditions
  • Applies to clinical investigations (MDR) and IVD performance studies (IVDR).

Effective from 2026-01-21

Change control

Does the event require internal documentation, notice, prior approval, transfer, or a new application?

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An authorised-representative change needs an express handover

changes.eu-authorised-representative-handover
Fact-level verified

Where the authorised representative changes, the agreement must address termination/start dates, the date until which the outgoing representative may appear in manufacturer-supplied information, transfer of documents and property/confidentiality, and forwarding of complaints and incidents by the outgoing representative. This is the Article 12 representative handover rule; it does not assign a foreign manufacturer’s certificate or device portfolio to a new legal manufacturer.

Conditions
  • Only where the authorised representative actually changes; manufacturer succession and local importer/distributor changes require their separate assessment.

Legacy sell-through depends on lawful prior placement

changes.eu-lawfully-placed-legacy-stock
Fact-level verified

The amended MDR Article 120(4) and IVDR Article 110(4) allow the specified devices lawfully placed under the former Directives or applicable transition provisions to continue to be made available or put into service. This is conditional on lawful placement of the actual units; it is not permission to place new nonconforming units, to keep an inaccurate post-change manufacturer identity, or to apply a universal old-label grace period.

Conditions
  • Establish unit-level placement dates, Directive/Regulation status, conformity, traceability and the actual change. Other stock routes and nonconforming inventory require a separate assessment.

Assess certificate and quality-system impact with the notified body

changes.eu-notified-body-change-assessment
Fact-level verified

Under the Annex IX route, plans for substantial changes to the quality system or device range must be notified to the notified body for assessment and any required additional audit or approval supplement. Changes to an approved device that could affect safety, performance or conditions of use require the notified body’s assessment of whether a new conformity assessment or certificate supplement is necessary. A logo, office or order-code edit does not by itself prove that every technical-change threshold is met.

Conditions
  • This is a conformity-assessment and certificate-scope rule where a notified body/Annex IX route applies; it is not a national one-form, one-fee or universal prior-approval rule.

A new legal manufacturer must meet the manufacturer obligations

changes.eu-own-name-manufacturer-role
Fact-level verified

A distributor, importer or other person that markets a device under its own name or trademark generally assumes the manufacturer obligations, subject to the agreement exception that keeps the original manufacturer identified and responsible on the label. Changing intended purpose or making a modification that may affect conformity has separate manufacturer-role consequences. The conditional translation/repackaging activities in Article 16(2) are exceptions, not automatic legal-manufacturer transfers.

Conditions
  • Identify the legal person responsible for conformity and whether the agreement exception actually applies. A share purchase or same-person rename does not by itself prove a transfer of device responsibility.

Portuguese CFS is a separate export certificate snapshot

changes.export-cfs-current-identity-snapshot
Fact-level verified

INFARMED’s free-sale certificate service is for national manufacturers or authorised representatives exporting outside the EU. Request it through the current SIDM route using the applicable regulatory category and device data; one certificate covers devices under the same regulatory diploma. The certificate records the market position on its issue date rather than having a fixed expiry. The published charge is EUR 30.69 for up to four sheets and EUR 15.35 per additional set of up to four; payment cannot be reused or transferred.

Conditions
  • A Portuguese-issued export certificate is requested only where needed for the destination. The procedure does not establish automatic reissuance after every name, office or REF change; establish the applicant role, device regime and identity the certificate must attest.

IVD distribution records remain a national layer

changes.ivd-distributor-national-particulars
Fact-level verified

INFARMED’s current registration page expressly retains Decreto-Lei 189/2000 Article 12 for IVD distributors. That provision identifies the distributor and legal address, product list with brand/model/version and the required product/documentation particulars. Apply the current SIDM instructions and keep changed identity and device records aligned with EUDAMED; this retained national duty does not reinstate superseded IVDD conformity-assessment routes.

A legacy IVD identity edit still needs certificate and role assessment

changes.legacy-ivd-administrative-identity-boundary
Fact-level verified

MDCG 2022-6 treats administrative changes to manufacturer name, address, legal form or representative as generally not changes to design or intended purpose; agreed notified-body/QMS notification remains applicable. This significance test does not by itself authorise assignment of a certificate or portfolio to a new manufacturer. Establish the continuing legal person, certificate scope and current IVDR transition eligibility.

Conditions
  • The original guidance’s 2025 end-date must not replace the later amended Article 110 dates and conditions.

Clinical investigation & performance

Which clinical or IVD performance evidence or study is required and accepted?

Compare countries

INFARMED decides; CEIC gives binding ethics opinion

clinical.authority-and-ethics-committee
Fact-level verified

INFARMED is responsible for decisions on clinical investigation applications and notifications; the CEIC (Comissão de Ética para a Investigação Clínica) is the ethics committee competent for the ethics assessment under MDR Chapter VI and IVDR Chapter VI, and its opinion is binding and incorporated in the decision.

Conditions
  • Applies to medical devices in Portugal.

Effective from 2026-01-21

Submissions via EU electronic system or INFARMED national electronic system

clinical.submission-electronic-systems
Fact-level verified

Clinical investigation applications/notifications are submitted through the EU electronic system of MDR Art. 73 or, for the national routes of Lei 71/2025 Art. 5, through INFARMED's national electronic system, with the full Annex XV Chapter II documentation; IVD performance study applications go through the IVDR Art. 69 system.

Conditions
  • Applies to medical devices in Portugal.

Effective from 2026-01-21

Establishment, import & distribution

Which establishment licences, importer permissions, and distribution controls apply?

Compare countries

IVD wholesale distributors: communication of distributed products

distribution.ivd-wholesale-communication
Fact-level verified

IVD wholesale distributors operating in the national market must communicate to INFARMED the IVDs they distribute, under the still-in-force Art. 12 of DL 189/2000 (name/address, list of products with brand/model, calibration documentation).

Conditions
  • Applies to IVD wholesale distributors operating in Portugal.

Fees

What regulator fee applies to this class, route, event, and date?

Compare countries

Fee exemption: non-commercial investigations and investigator-sponsored studies

fees.non-commercial-investigation-exemption
Fact-level verified

Non-commercial clinical investigations and IVD performance studies, and studies where the sponsor is the investigator, are exempt from the INFARMED fees for investigation/performance study applications, notifications and substantial modifications.

Conditions
  • Applies to medical devices in Portugal.

Effective from 2026-01-21

Label, IFU & language

Which label and IFU elements, languages, symbols, and translation controls apply?

Compare countries

Align manufacturer identity, labels and the EU declaration

changes.eu-identity-labels-and-declaration
Fact-level verified

For MDR devices and IVDR IVDs, the EU declaration of conformity must be kept current. Its Annex IV identity includes the manufacturer and, where relevant, authorised representative, registered place of business, Basic UDI-DI and traceable product/trade name or product-code information. The label must identify the responsible manufacturer and its registered business address and the authorised representative where required. Update the affected declaration and supplied information when these particulars change.

Conditions
  • Apply MDR Article 19/Annex I 23 to MDs and IVDR Article 17/Annex I 20 to IVDs. A legal office and a manufacturing site are not interchangeable fields.
  • The device route must require an EU declaration of conformity. These are ongoing label/declaration obligations, not a complete national amendment checklist.

IVD labels and IFU in Portuguese

label.ivd-language-portuguese
Fact-level verified

INFARMED requires labels and instructions for use of IVDs to be written in Portuguese, legible and indelible, regardless of whether use is professional, without prejudice to other languages also being included.

Conditions
  • Applies to IVDs placed on the Portuguese market.

Official forms & portals

Which current form, portal, account, and submission package must be used?

Compare countries

Update SIDM device records to match EUDAMED

changes.sidm-eudamed-identity-alignment
Fact-level verified

INFARMED instructs manufacturers/representatives and distributors using the applicable SIDM pathways to reuse EUDAMED identity by UDI-DI/EUDAMED ID and upload labelling, instructions and the declaration. Existing SIDM records must be updated to align with EUDAMED; the current FAQ describes the CDM-to-UDI-DI association while retaining existing documents. A CDM, UDI-DI and the manufacturer’s commercial REF are different identifiers.

Conditions
  • Use the actual economic-operator role and device record. Data alignment does not itself approve a new legal manufacturer or a bundle of substantive changes.

Reliance & recognition

Which foreign decisions or evidence can be reused, with what effect and conditions?

Compare countries

Existing records include acceptance, restrictions and evidence reuse. The applicable product scope and conditions are preserved below; a reference does not by itself confer market access.

Portugal approvals and evidence in other markets (3 records)

IsraelUS FDA · UK MHRA · Germany · France · Italy · Spain · Netherlands · Belgium · Ireland · Denmark · Sweden · Finland · Norway · Iceland · Greece · Portugal · Austria · Swissmedic · Australia TGA · Health Canada · New Zealand

Regulatory reference

Recognized-state registration route

reliance.recognized-country-route
Fact-level verified

A device registered, or approved for marketing and actually marketed, in a 'recognized state' (מדינה מוכרת) is registered in the Israeli register for a period not exceeding the period it may be marketed in that state, capped at 5 years from Israeli registration. Recognized states are listed in the First Addendum to the law — 21 states including the US, UK, Germany, France, Italy, Spain, the Netherlands, Belgium, Ireland, Denmark, Sweden, Finland, Norway, Iceland, Greece, Portugal, Austria, Switzerland, Australia, Canada and New Zealand (no single 'EU' entry: member states are listed individually).

Conditions
  • Device must be registered or permitted for marketing and actually marketed in the recognized state.

First Addendum list per the official Sefer HaChukim text of the law held from gov.il.

ParaguayBrazil ANVISA · EU conformity assessment · US FDA · Health Canada · Singapore HSA · IMDRF member authorities · Portugal · Spain · South Korea MFDS · Japan MHLW / PMDA · UK MHRA · NMPA · Taiwan TFDA · Australia TGA · WHO

Prior approval / evidence record

IVD simplified registration (PSR) for products authorised by PAHO/WHO, IMDRF or bilateral-partner authorities

reliance.ivd-psr-reference-authorities
Fact-level verified
Statement

Class II, III and IV in-vitro diagnostic products already authorised and commercialised in countries regulated by PAHO/WHO reference regulatory authorities, by authorities of IMDRF Management Committee member countries, or by authorities with bilateral agreements with DINAVISA enter the Proceso Simplificado de Registro Sanitario (PSR). DINAVISA has 15 business days to validate and decide, and approval follows by positive silence if no report is issued.

Source Approval

PAHO/WHO reference regulatory authorities; authorities of IMDRF Management Committee member countries (the IMDRF committee includes US FDA, EU, Japan PMDA/MHLW, Health Canada, TGA, ANVISA, China NMPA, Korea MFDS, Singapore HSA and UK MHRA); authorities with bilateral agreements with DINAVISA

Edge Type

Abridged Or Recognition Route

Market Access Strength

facilitated

Regulatory Layer

Premarket Review

Local Application Required

Yes

Target Decision Retained

Yes

Conditions
  • Applies to class II, III and IV IVDs (Res. 44/2024 Art. 7: 'Clases II, III y IV'); class I IVDs are registered automatically under Res. 266/2022 Art. 14.
  • The IVD must actually be commercialised in one of those countries and the foreign registration must correspond specifically to the same product being registered.
  • 15 business days to validate; approval by positive silence.
  • Objections may be answered only once (Art. 3), with 30 business days to rectify.
  • Not applicable to the cases in Arts. 13 and 16 of Res. DINAVISA N° 266/2022 (Art. 11).

Effective from 2024-01-30

Source language: Spanish. Translation of the operative part of Art. 2: 'Applications for sanitary registration of In Vitro Diagnostic Products ... that are authorised and commercialised in countries regulated by: PAHO/WHO Reference Regulatory Authorities; Regulatory Authorities of member countries of the Committee of the International Medical Device Regulators Forum - IMDRF; Regulatory Authorities with which bilateral agreements with DINAVISA exist, shall be subject to the Simplified Sanitary Registration Process (PSR).' and 'DINAVISA shall have a term of 15 (fifteen) business days to validate the required documentation and decide thereon. Once the term has elapsed with no report from DINAVISA, the application shall be approved.' Article numbering confirmed by reading the page image of the official PDF.

PeruUS FDA · UK MHRA · Health Canada · Japan MHLW / PMDA · Australia TGA · Swissmedic · South Korea MFDS · Germany · France · Netherlands · Spain · Italy · Belgium · Portugal · Ireland · Austria · Hungary · Denmark · Norway · Sweden

Prior approval / evidence record

País de Alta Vigilancia Sanitaria (art. 9 D.S. 016-2011-SA): United States, Canada, Japan, Australia, Switzerland, South Korea, United Kingdom, Germany, France, Netherlands, Spain, Italy, Belgium, Portugal, Ireland, Austria, Hungary, Denmark, Norway, Sweden

Authority

País de Alta Vigilancia Sanitaria (art. 9 D.S. 016-2011-SA): United States, Canada, Japan, Australia, Switzerland, South Korea, United Kingdom, Germany, France, Netherlands, Spain, Italy, Belgium, Portugal, Ireland, Austria, Hungary, Denmark, Norway, Sweden

Accepted

Yes

Benefit

The Peruvian route to relying on a foreign approval is documentary, not procedural. A certificate of free sale or a GMP certificate issued by a high-surveillance authority is accepted directly, and if the issuing authority appears on the Resolución Directoral 169-2014-DIGEMID list the document does not need an apostille. Everything else still goes through DIGEMID certification.

Timeline Savings

None published — the TUPA period is set by class, not by origin

Maintained reference · planning ranges remain estimates · reviewed 2026-08-30

Prior approvals and evidence for Portugal (2 records)

PortugalUS FDA

Prior approval / evidence record

FDA 510(k)/PMA

Authority

FDA 510(k)/PMA

Accepted

No

Benefit

No substitute for EU MDR conformity assessment; useful as predicate documentation in the technical file

Maintained reference · planning ranges remain estimates · reviewed 2026-08-29

Regulatory reference

NMPA certificate does not replace EU conformity assessment

reliance.china-nmpa-no-recognition-route
Fact-level verified
Statement

For ordinary market placement under MDR/IVDR, a Chinese approval does not replace conformity assessment under MDR Article 52 or IVDR Article 48. The applicable EU class and procedure must be established independently; lower-risk devices may self-declare, while other devices require notified-body assessment. This is a finding about the ordinary conformity route, not a ban on Chinese devices or their technical evidence.

Source Jurisdiction Id

china

Source Authority Id

nmpa

Source Approval

China NMPA medical device registration certificate (Class II/III) or Class I filing record

Target Jurisdiction Id

portugal

China Classes In Scope

All NMPA classes (I filing, II, III) -> all EU MDR/IVDR classes

Edge Type

No Reliance Route

Market Access Strength

none

Regulatory Layer

Product Marketing

Local Application Required

null

Target Decision Retained

null

Conditions
  • Determine the local class independently; NMPA Class III is not an automatic EU class assignment.
  • A local regulatory application/decision is not universal: MDR Article 52(7) and IVDR Article 48(10) permit specified self-declaration routes.
  • Clinical, performance and technical evidence must meet the applicable EU requirements; the certificate alone does not replace them.
  • Special-purpose, investigational, custom-made and derogation regimes require separate assessment.

Independent review of current EUR-Lex consolidations supports this bounded ordinary-route conclusion. It does not establish the absence of every special route.

Submission communications & appeal

How are deficiencies answered, clocks handled, and decisions escalated or appealed?

Compare countries

Clinical investigation decisions: hierarchical appeal to health minister and courts

appeal.clinical-investigation-decisions
Fact-level verified

Decisions on clinical investigation applications, notifications and substantial modifications may be challenged by administrative impugnation (hierarchical appeal to the member of Government responsible for health) and by judicial review under the general terms of law.

Conditions
  • Applies to medical devices in Portugal.

Effective from 2026-01-21

UDI, listing & traceability

Which UDI, device listing, database, and traceability duties apply?

Compare countries

A commercial REF is distinct from UDI and actor data

changes.eu-ref-udi-and-record-updates
Fact-level verified

EU device-registration data distinguish trade name from model/reference/catalogue number. A new UDI-DI is required for listed changes including device name/trade name or version/model where the applicable UDI rules are triggered; a REF edit is not automatically a new UDI. Changes to actor information must be updated within one week under MDR Article 31 or IVDR Article 28, and UDI-database changes not requiring a new UDI-DI within thirty days under Annex VI Part C 5.8.

Conditions
  • These are operator data-maintenance periods, not authority review SLAs. Confirm the applicable device type, UDI implementation and EUDAMED transition stage.

Vigilance & incident reporting

What is reportable, by whom, where, in what format, and by what deadline?

Compare countries

National reporting channel: EU harmonized forms + dvps@infarmed.pt

vigilance.national-channel-forms-and-email
Fact-level verified

Until the EUDAMED vigilance module is implemented, serious incidents and FSCA are reported to INFARMED using the EU harmonized forms published by the European Commission; all communication is by e-mail to dvps@infarmed.pt.

Conditions
  • Transitional national channel until the EUDAMED vigilance module becomes mandatory.

Related structured datasets

Classification systems · 0 records

No maintained record.

Registration pathways, prior approvals and planning · 1 record

These country-level records can cover multiple product types. Check each item's scope and conditions before applying a fee, pathway or licence to an IVD.

Open Portugal registration →
Country

Portugal

Jurisdiction Id

portugal

Country Code

PT

Flag

🇵🇹

Regulator

National Authority of Medicines and Health Products

Regulator Abbrev

INFARMED

Region

europe

Tier

3

Risk Classification

4-class (I, IIa, IIb, III) — EU MDR

Classes
  • Id

    class-i

    Class Name

    Class I

    Risk Level

    low

    Pathway

    Self-declaration (no notified body)

    Official Timeline
    Min

    0

    Max

    0

    Unit

    days

    Verification Status

    official-verified

    Official Source
    Title

    EUR-Lex Regulation (EU) 2017/745 (MDR)

    Url

    https://eur-lex.europa.eu/eli/reg/2017/745/oj

    Accessed Date

    2026-08-25

    Realistic Timeline
    Min

    6

    Max

    9

    Unit

    months

    Notes
    • MDR Art. 52(7): non-sterile, non-measuring, non-reusable-surgical Class I devices are self-declared, so no authority or notified body reviews the file and there is no review clock
    • Elapsed time is Eudamed actor and device registration, which has no guaranteed processing time, plus any national registration duty
    Clinical Trial Required

    No

    Local Testing Required

    No

    Gmp Required

    Yes

Key Requirements
  • EU Authorized Representative (for non-EU manufacturers)
  • Field safety corrective action: preliminary INFARMED submission within 2 days before informing users (Decree-Law 145/2009 as amended by Lei 27/2022, applied to MDR/IVDR by Lei 71/2025)
  • Lei 71/2025 applies MDR/IVDR assessment clocks directly to national procedures
Prior Approvals
  • Authority

    FDA 510(k)/PMA

    Accepted

    No

    Benefit

    No substitute for EU MDR conformity assessment; useful as predicate documentation in the technical file

Local Rep Required

Yes

Local Rep Name

EU Authorized Representative

Mdsap Accepted

No

Mdsap Benefit

ISO 13485 accepted as QMS evidence

Registration Validity

5 years (CE certificate)

Last Updated

2026-08-29

Verification Status

partially-verified

Official Sources
  • Title

    Commission Implementing Regulation (EU) 2026/977, Art. 2 — maximum notified-body conformity assessment timelines (30 + 120/90 parallel + 20 days)

    Url

    https://eur-lex.europa.eu/eli/reg_impl/2026/977/oj

    Effective Date

    2027-02-25

    Accessed Date

    2026-08-29

  • Title

    EUR-Lex Regulation (EU) 2017/745 (MDR)

    Url

    https://eur-lex.europa.eu/eli/reg/2017/745/oj

    Accessed Date

    2026-08-25

  • Title

    EUR-Lex MDR consolidated text — Annex IX §5.1 (expert-panel clinical evaluation consultation: 21/60 days) and §5.2(d) (ancillary medicinal-substance opinion: 210 days)

    Url

    https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02017R0745-20250110

    Accessed Date

    2026-08-29

Reviewed On

2026-08-29

Process
Template Id

default

Status

planning-template

Usage Rule

Maintained planning steps and estimates, not verified regulator deadlines.

Steps
  • Step

    1

    Title

    Pre-Submission Preparation

    Description

    Gather technical documentation, quality management system (QMS) records, and clinical data required by INFARMED. Appoint a EU Authorized Representative.

    Duration

    1-3 months

    Icon

    📋

  • Step

    2

    Title

    Application Submission

    Description

    Submit complete registration dossier to INFARMED including device description, risk analysis, and testing reports.

    Duration

    1-2 weeks

    Icon

    📤

  • Step

    3

    Title

    Administrative Review

    Description

    INFARMED reviews application for completeness. May request additional documents or clarifications.

    Duration

    2-4 weeks

    Icon

    🔍

  • Step

    4

    Title

    Technical Evaluation

    Description

    In-depth technical assessment of device safety and performance. INFARMED may issue questions.

    Duration

    0 days

    Icon

    ⚙️

  • Step

    5

    Title

    Registration Approval

    Description

    Upon successful review, INFARMED issues Portugal market authorization certificate.

    Duration

    1-2 weeks

    Icon

    ✅

Government fee schedules · 1 record

These country-level records can cover multiple product types. Check each item's scope and conditions before applying a fee, pathway or licence to an IVD.

Open Portugal fees →
Jurisdiction Id

portugal

Country

Portugal

Country Code

PT

Authority

INFARMED

Low Risk Local
Min

200

Max

200

Currency

EUR

Per Product

No

High Risk Local
Min

1000

Max

1000

Currency

EUR

Per Product

No

Details
  • Id

    clinical-study-application-non-ce

    Item

    Clinical-study application - non-CE device or CE outside intended purpose

    Currency

    EUR

    Amount Local

    1000

    Amount Local Formatted

    EUR 1,000

    Frequency

    Per application

    Amount Status

    exact-current

    Verification Status

    official-verified

    Source Url

    https://www.infarmed.pt/documents/15786/17838/portaria_n_63_2015.pdf

    Source Title

    Portugal Portaria 63/2015: clinical-study fees in force until 5 November 2026

    Source Effective Date

    2015-03-01

    Verified On

    2026-08-25

  • Id

    clinical-study-application-ce

    Item

    Clinical-study application - CE-marked device

    Currency

    EUR

    Amount Local

    600

    Amount Local Formatted

    EUR 600

    Frequency

    Per application

    Amount Status

    exact-current

    Verification Status

    official-verified

    Source Url

    https://www.infarmed.pt/documents/15786/17838/portaria_n_63_2015.pdf

    Source Title

    Portugal Portaria 63/2015: clinical-study fees in force until 5 November 2026

    Source Effective Date

    2015-03-01

    Verified On

    2026-08-25

  • Id

    study-notification-non-ce

    Item

    Study notification - non-CE device

    Currency

    EUR

    Amount Local

    600

    Amount Local Formatted

    EUR 600

    Frequency

    Per notification

    Amount Status

    exact-current

    Verification Status

    official-verified

    Source Url

    https://www.infarmed.pt/documents/15786/17838/portaria_n_63_2015.pdf

    Source Title

    Portugal Portaria 63/2015: clinical-study fees in force until 5 November 2026

    Source Effective Date

    2015-03-01

    Verified On

    2026-08-25

  • Id

    study-notification-ce

    Item

    Study notification - CE-marked device

    Currency

    EUR

    Amount Local

    400

    Amount Local Formatted

    EUR 400

    Frequency

    Per notification

    Amount Status

    exact-current

    Verification Status

    official-verified

    Source Url

    https://www.infarmed.pt/documents/15786/17838/portaria_n_63_2015.pdf

    Source Title

    Portugal Portaria 63/2015: clinical-study fees in force until 5 November 2026

    Source Effective Date

    2015-03-01

    Verified On

    2026-08-25

  • Id

    protocol-amendment

    Item

    Study protocol amendment

    Currency

    EUR

    Amount Local

    200

    Amount Local Formatted

    EUR 200

    Frequency

    Per amendment

    Amount Status

    exact-current

    Verification Status

    official-verified

    Source Url

    https://www.infarmed.pt/documents/15786/17838/portaria_n_63_2015.pdf

    Source Title

    Portugal Portaria 63/2015: clinical-study fees in force until 5 November 2026

    Source Effective Date

    2015-03-01

    Verified On

    2026-08-25

Notes
  • Amounts remain in force until 5 November 2026 plus indexation: Portaria 63/2015 as kept applicable by Lei 71/2025 art. 40(3), subject to annual CPI indexation.
  • Portaria 327/2026/1 (published 6 August 2026, in force 6 November 2026) replaces these with EUR 1,250 (clinical-investigation application), EUR 1,250 (IVD performance-study application), EUR 750 (PMCF/PMPF notification), and EUR 250 (substantial modification); 90% is refunded if the submission is not validated, and payment must precede submission.
Last Updated

2026-08-25

Verification Status

official-verified

Official Sources
  • Title

    Portugal Portaria 63/2015: clinical-study fees in force until 5 November 2026

    Url

    https://www.infarmed.pt/documents/15786/17838/portaria_n_63_2015.pdf

    Effective Date

    2015-03-01

    Accessed Date

    2026-08-25

  • Title

    Portugal Portaria 327/2026/1: device clinical-investigation fees

    Url

    https://files.diariodarepublica.pt/1s/2026/08/15100/0004100043.pdf

    Effective Date

    2026-11-06

    Accessed Date

    2026-08-25

Reviewed On

2026-08-25

Amount Status

exact-current

Range Available

Yes

Additional certifications and licences · 1 record

These country-level records can cover multiple product types. Check each item's scope and conditions before applying a fee, pathway or licence to an IVD.

Open Portugal certifications →
Slug

portugal

Market

Portugal

Confidence

high

Schemes
  • Id

    lvd-medical-exclusion-mdr-electrical-safety

    Name

    MDR electrical safety in place of the Low Voltage Directive

    Category

    Medical Electrical Safety

    Status

    Included In Medical Registration

    Object

    Finished Device

    Note

    Annex II of Directive 2014/35/EU places electrical equipment for radiology and medical purposes outside the Low Voltage Directive, so there is no separate national electrical-safety certificate for a medical device. Electrical safety is assessed inside the MDR conformity assessment against MDR Annex I, with the harmonised IEC/EN 60601 series carrying the presumption of conformity.

    Source Urls
    • https://eur-lex.europa.eu/eli/dir/2014/35/oj
    Source Binding

    candidate

  • Id

    emc-directive-disapplied-by-mdr

    Name

    MDR electromagnetic compatibility in place of the EMC Directive

    Category

    emc

    Status

    Included In Medical Registration

    Object

    Finished Device

    Note

    Article 2(3) of Directive 2014/30/EU switches the EMC Directive off where other Union legislation lays the same essential requirements down more specifically, which MDR Annex I sections 18.5 and 18.6 do for medical devices. EMC is therefore dossier evidence inside the CE route and not a separate national EMC conformity step.

    Source Urls
    • https://eur-lex.europa.eu/eli/dir/2014/30/oj
    Source Binding

    candidate

  • Id

    dl-57-2017-radio-market-access

    Name

    Decreto-Lei 57/2017 radio equipment market access

    Category

    Radio Spectrum

    Status

    Mandatory If Feature

    Object

    Radio Equipment

    Note

    Article 7 of Decreto-Lei 57/2017 of 9 June, in its consolidated version, allows only radio equipment complying with the decree to be made available on the market, article 10 guarantees free circulation of compliant equipment, and article 39 gives surveillance to ANACOM and ASAE. A full read of the consolidated text found no Portuguese type approval, homologation or pre-market authorisation. Article 8(2) lets ANACOM add requirements for entry into service or use on spectrum-efficiency, interference and public-health grounds, which is the verbatim RED article 7(2) power and a use condition rather than a product approval.

    Source Urls
    • https://diariodarepublica.pt/dr/detalhe/decreto-lei/152-d-2017-114337042
    Source Binding

    candidate

  • Id

    dl-79-2013-rohs-substance-restriction

    Name

    Decreto-Lei 79/2013 substance restriction (RoHS)

    Category

    Environmental And Batteries

    Status

    Evidence Only No Separate Certificate

    Object

    Electrical Electronic Medical Device

    Note

    Portugal transposed Directive 2011/65/EU by Decreto-Lei 79/2013 of 11 June, published in Diário da República 111/2013 Series I, with a subsequent declaração de retificação, as recorded on the EUR-Lex national implementing measures page. The Portuguese text itself was not opened, so no article number is given and the designated competent authority is not confirmed from the decree. Directive 2011/65/EU Annex I category 8 covers medical devices, Article 4(3) has bound medical devices since 22 July 2014 and in vitro diagnostic medical devices since 22 July 2016, and Article 2(4)(h) excludes active implantable medical devices.

    Source Urls
    • https://diariodarepublica.pt/dr/legislacao-consolidada/decreto-lei/2017-156850835
    • https://diariodarepublica.pt/dr/detalhe/decreto-lei/152-d-2017-114337042
    Source Binding

    candidate

  • Id

    dl-152-d-2017-unilex-market-precondition

    Name

    UNILEX producer-responsibility system as a precondition for market placement

    Category

    Environmental And Batteries

    Status

    Mandatory Pre Market

    Object

    Producer Or Authorised Representative

    Note

    Article 7(2) of Decreto-Lei 152-D/2017, the unified regime for specific waste streams, permits placing and making available on the national market only products whose producers have adopted one of the producer-responsibility systems set out in article 7(1), and article 19(1) requires producers to report to APA through the integrated electronic waste registration system. That system is SIRER, operated by APA as national waste authority under articles 95 to 97 of Decreto-Lei 102-D/2020 and regulated by Portaria 20/2022, and is reached through the SILiAmb platform. Directive 2012/19/EU Article 2(4)(g) excludes devices expected to be infective before end of life and active implantable devices; other medical devices are in scope, and Article 16 requires each Member State to keep a producer register.

    Source Urls
    • https://diariodarepublica.pt/dr/detalhe/decreto-lei/152-d-2017-114337042
    Source Binding

    candidate

  • Id

    sirer-battery-producer-registration

    Name

    Battery producer registration in SIRER under Article 55

    Category

    Environmental And Batteries

    Status

    Mandatory Pre Market

    Object

    Battery Producer Or Authorised Representative

    Note

    APA's own January 2026 producer-registration briefing states that a producer that is not registered, or whose authorised representative for extended producer responsibility is not, may not place batteries on the market, and that Article 55(1) of Regulation (EU) 2023/1542 is discharged through the existing SIRER producer register in SILiAmb. The same document carries an important negative: the batteries-specific sanctions regime is still being drafted, so for the producer register the prohibitions and penalties of UNILEX and the RGGR continue to apply and there is no batteries-specific Portuguese implementing decree. Article 11(2)(b) of Regulation (EU) 2023/1542 lets professional medical imaging and radiotherapy devices and in vitro diagnostic medical devices restrict portable-battery replacement to independent professionals, and Article 11(3) lifts the removability duty where continuity of supply is needed for safety or data integrity.

    Source Binding

    unresolved

  • Id

    apa-radiation-practice-licence-or-registration

    Name

    APA radiation practice licence or registration

    Category

    Ionizing Radiation

    Status

    Mandatory If Feature

    Object

    Radiation Source Import Or Practice

    Note

    Decreto-Lei n.º 108/2018 art. 22(2) subjects the operation of intraoral dental equipment and bone densitometry equipment to registration, and art. 22(4) subjects to licensing the operation of ionising radiation generators, accelerators (other than electron microscopes) and radioactive sources both for medical and non-medical imaging exposures and for other purposes, and — in art. 22(4)(i) — the import, export and introduction of radiation sources into national territory. The Agência Portuguesa do Ambiente is the competent authority for licensing and registration, holders of sealed sources or equipment incorporating them file the Annex IV standardised registration sheet in advance and report receipt within 10 days, and the art. 188 fee is fixed by Portaria n.º 293/2019.

    Source Urls
    • https://diariodarepublica.pt/dr/detalhe/decreto-lei/152-d-2017-114337042
    • https://apambiente.pt/prevencao-e-gestao-de-riscos/legislacao-2
    Source Binding

    candidate

Official Sources
  • Authority

    EUR-Lex

    Topic

    Low Voltage Directive 2014/35/EU Annex II — electrical equipment for radiology and medical purposes outside scope

    Url

    https://eur-lex.europa.eu/eli/dir/2014/35/oj

  • Authority

    EUR-Lex

    Topic

    EMC Directive 2014/30/EU Article 2(3) — more specific Union legislation displaces the directive

    Url

    https://eur-lex.europa.eu/eli/dir/2014/30/oj

  • Authority

    EUR-Lex

    Topic

    RoHS Directive 2011/65/EU Annex I category 8 and Article 4(3) medical-device application dates

    Url

    https://eur-lex.europa.eu/eli/dir/2011/65/oj

  • Authority

    EUR-Lex

    Topic

    WEEE Directive 2012/19/EU Article 2(4)(g) medical-device exclusions and Article 16 national producer register

    Url

    https://eur-lex.europa.eu/eli/dir/2012/19/oj

  • Authority

    EUR-Lex

    Topic

    Batteries Regulation (EU) 2023/1542 Articles 11 and 55 — medical-device removability derogation and producer register

    Url

    https://eur-lex.europa.eu/eli/reg/2023/1542/oj

  • Authority

    Diário da República Eletrónico

    Topic

    Decreto-Lei 57/2017 arts. 7, 8, 10 and 39 — consolidated RED regime

    Url

    https://diariodarepublica.pt/dr/legislacao-consolidada/decreto-lei/2017-156850835

  • Authority

    Diário da República Eletrónico

    Topic

    Decreto-Lei 152-D/2017 arts. 7 and 19 — UNILEX market precondition and APA electronic registration

    Url

    https://diariodarepublica.pt/dr/detalhe/decreto-lei/152-d-2017-114337042

  • Authority

    APA (Agência Portuguesa do Ambiente)

    Topic

    Registo de Produtores — Baterias, 30 January 2026: Article 55 discharged through SIRER and the pending sanctions regime

    Url

    https://apambiente.pt/sites/default/files/_Residuos/FluxosEspecificosResiduos/Produtores/Apresentacoes/registo-de-produtores_bat30.01.2026.pdf

  • Authority

    Diário da República

    Topic

    Decreto-Lei n.º 108/2018 — prior administrative control of radiation practices

    Url

    https://diariodarepublica.pt/dr/detalhe/decreto-lei/108-2018-117202785

  • Authority

    Agência Portuguesa do Ambiente

    Topic

    consolidated radiation protection legislation and APA licensing instruments

    Url

    https://apambiente.pt/prevencao-e-gestao-de-riscos/legislacao-2

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