Class A/B updates and fresh-declaration triggers
For Class A/B devices and IVDs, Article28(4) lists name/address updates for the product owner or circulation-number holder and manufacturer name/address information, plus qualifying label/IFU changes. Notify with related documents and update the public dossier within five working days after the change. A new product owner, device kind/type/purpose, added manufacturing site or added product code instead triggers a fresh declaration under 28(3).
- Label/IFU route requires unchanged intended purpose and indications.
- A commercial brand is not automatically a new device type or product owner.