Informational MDCG 2019-5 Registration of legacy devices in EUDAMED

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SYRANE

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It seems to me there is a contradiction between the MDCG 2019-4 and MDCG 2019-5 document. Indeed, the MDCG-4 document states that the registration of Manufacturers in EUDAMED must take place 18 months on the latest after the application of the MDR (meaning November 26th 2021). However, the assignation of a basic UDI-DI and UDI-DI applies as of May 26th, 2020. For legacy devices (according to MDCG 2019-5), the assignation of the basic UDI-DI and UDI-DIs will be made by EUDAMED (when the devices are registered) as long as these devices are not certified according to the MDR. In this case, ow can legacy devices have a basic UDI-DI and UDI-DIs on May 26th, 2020 if they can register in EUDAMED until November 26th, 2021.
 
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