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How do medical device manufacturers achieve CE marking under the MDR without delays from the notified body?

We guide manufacturers of Class I to III medical devices through the complete conformity assessment procedure under the Medical Device Regulation (EU) 2017/745: from classification under Annex VIII and the technical documentation under Annex II and III to the declaration of conformity and CE marking. CE marking is not a separate step but the result of a completed conformity assessment procedure; what delays projects is almost never affixing the mark, but technical documentation that is not yet ready for the notified body review.

  • MedTech
  • IVD

Overview

What requirements does the MDR place on CE marking?

Support across all classes I–III · MDR (EU 2017/745), ISO 13485:2016, ISO 14971

Last updated: 2026-06-13

CE marking documents that a medical device meets the requirements of the Medical Device Regulation (EU) 2017/745. It comes at the end of a conformity assessment procedure whose depth depends on the device class. The points where manufacturers most often get stuck on the way there:

  • The device class determined under the classification rules in Annex VIII drives the conformity assessment route and thereby whether a notified body must be involved.
  • From Class IIa onward, as well as for sterile and measuring Class I devices, a notified body is required in the procedure; their capacity comes with long lead times.
  • The technical documentation under Annex II and III must substantiate every General Safety and Performance Requirement from Annex I with concrete evidence, including the clinical evaluation under Annex XIV.
  • A quality management system in accordance with ISO 13485:2016 is a prerequisite for most conformity assessment routes, not an afterthought.
  • Only after the conformity assessment is complete may the manufacturer issue the declaration of conformity and affix the CE marking.

Services

How we support you

Classification & conformity assessment route

Device classification under Annex VIII and determination of the conformity assessment route under Annex IX to XI. The result is a documented classification decision with rationale and the determination of whether and to what extent a notified body must be involved.

Technical documentation under Annex II/III

Build-up and review of the technical documentation under Annex II and III: device and process description, GSPR checklist against Annex I, clinical evaluation and post-market plan. The result is a dossier prepared for the notified body review with evidence for each requirement.

QMS preparation under ISO 13485

Build-up or review of the quality management system in accordance with ISO 13485:2016 as a prerequisite of the conformity assessment procedure. The result is a QMS assessed against the standard with documented linkage to risk management under ISO 14971.

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Notified body support

Preparation for the audit procedure: document review, gap analysis and remediation ahead of the audit, support throughout the procedure and structured resolution of queries up to certificate issuance. The result is a tracked findings list with documented responses.

Declaration of conformity & affixing the CE mark

Preparation of the EU declaration of conformity and clarification of the requirements for correctly affixing the CE marking. The result is a complete declaration of conformity referencing the conformity assessment procedure carried out and the standards applied.

Post-market compliance after CE

Ensuring the ongoing obligations after CE marking is granted: post-market surveillance, PMCF and maintenance of the technical documentation. The result is an ongoing surveillance system that holds up in the follow-up audit.

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What it comes down to

CE marking under the Medical Device Regulation (EU) 2017/745 is not a step added at the end, but the visible consequence of a completed conformity assessment procedure. Sequence is what matters: first, classification under Annex VIII establishes the assessment route and thereby whether a notified body must be involved. Only after that is it worth building the technical documentation under Annex II and III, because its scope depends on the route. Within it, every General Safety and Performance Requirement from Annex I needs concrete evidence, and the clinical evaluation under Annex XIV is part of that. Anyone who checks the class too late, or requests notified body capacity only after writing the dossier, loses precisely this sequence as the bottleneck.

This is exactly where we come in: we confirm the class and the assessment route early, secure the QMS under ISO 13485:2016 in parallel as a prerequisite of the procedure, and build the technical documentation so that it passes the notified body review without rounds of additional requests. The declaration of conformity and affixing the CE marking then stand at the end of a straight path rather than at the beginning of a correction loop, and the post-market obligations take effect from day one after market entry.

Our approach

Our approach

01

Classification & strategy

Confirmed device class under Annex VIII and defined conformity assessment route under Annex IX–XI, including selection of the notified body where required.

02

QMS review

Quality management system in accordance with ISO 13485:2016 assessed and linked to risk management under ISO 14971.

03

Technical documentation

Technical documentation under Annex II/III, every GSPR from Annex I substantiated with concrete evidence.

04

Notified body procedure

Submitted dossier, supported audit, structured resolution of findings up to certificate issuance.

05

Declaration of conformity & CE marking

Issued EU declaration of conformity and affixed CE marking.

06

Post-market obligations

Post-market surveillance and PMCF in operation, technical documentation under ongoing maintenance.

Common pitfalls

Where projects commonly fail

Classification under Annex VIII is underestimated.

An up-classification, for example for software or substance-based devices, shifts the conformity assessment route and requires a notified body where self-certification was initially assumed. This changes the entire timeline.

CE marking is misunderstood as a separate final step.

In fact, the mark may only be affixed after the conformity assessment procedure is complete and the declaration of conformity has been issued; anyone who does not complete the full procedure does not have valid marking.

The GSPR checklist against Annex I is incomplete or does not point to concrete evidence.

The notified body requires proof in the technical documentation under Annex II/III for each individual requirement; blanket references lead to additional requests.

Notified body capacity is planned for too late.

Contract conclusion and audit slots come with long lead times; an application submitted with technical documentation that is not yet mature creates correction loops instead of a straight path to certification.

The QMS under ISO 13485:2016 is not treated as a prerequisite of the procedure.

If the linkage to risk management under ISO 14971 is missing, the gap surfaces in the audit and blocks certification, even though the technical documentation is substantively complete.

FAQ

Frequently asked questions

Class IIa, IIb and III medical devices, classified under the rules in Annex VIII of the MDR (EU 2017/745), require a notified body in the conformity assessment procedure. Class I devices without sterility, a measuring function or a reusable surgical instrument can be certified under the manufacturer's own responsibility, but still require a compliant QMS and complete technical documentation.

Sources
  • Regulation (EU) 2017/745 (MDR): primary text, Annex I, II, III, VIII, IX–XI, XIV
  • ISO 13485:2016: Quality management systems for medical devices
  • ISO 14971: Application of risk management to medical devices
  • https://theentourage.de/regulatory-compliance/ce-kennzeichnung-medizinprodukte/ (existing page content, revised)

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Regulations & standards considered

  • EU 2017/745 (MDR)
  • MDR Annex I (General Safety and Performance Requirements, GSPR)
  • MDR Annex II/III (Technical Documentation)
  • MDR Annex VIII (classification rules)
  • MDR Annex IX–XI (conformity assessment procedures)
  • MDR Annex XIV (Clinical Evaluation & PMCF)
  • ISO 13485:2016 (QMS)
  • ISO 14971 (Risk Management)

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