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EUDAMED and swissdamed: what device makers must register in 2026

Two databases, two sets of numbers, no data link between them — and deadlines at the end of November and the end of December 2026. A practical guide for manufacturers selling in the EU and Switzerland.

10 min read By Alexander Baranov, Founder Updated October 2026
In one paragraph

Four EUDAMED modules — actors, UDI/devices, notified bodies & certificates, market surveillance — became mandatory on 28 May 2026. New devices must be registered before the first unit is sold; devices already on the market must be registered by late November 2026 (treat 27 November as the safe date). Switzerland runs its own database, swissdamed: device registration has been mandatory since 1 July 2026, with existing devices due by 31 December 2026 and a fee of CHF 200 for the first UDI-DI per year plus CHF 20 for each additional one. Data does not flow between the two systems.

EUDAMED: what became mandatory

Under Regulation (EU) 2024/1860, each EUDAMED module becomes mandatory six months after the Commission publishes a notice that it is functional. The notice for the first four modules was published on 27 November 2025 (Commission Decision (EU) 2025/2371).

ObligationDeadline
Actors, UDI/devices, NB & certificates, market surveillanceMandatory from 28 May 2026
New devices (first unit placed on the market on or after 28 May 2026)Register before the first unit — no grace period
Devices already on the market before 28 May 2026 (MDR/IVDR and legacy)By 28 November 2026 per the Commission timeline; several advisers read 27 November — use 27 November as the safe date
Certificates issued before 28 May 2026Notified bodies enter them by 28 May 2027

In Germany the national DMIDS registration stayed mandatory until 28 May 2026, and its data does not transfer to EUDAMED automatically.

Device registration (UDI)

One registration per device identifier covers all units: the UDI-DI under its Basic UDI-DI, or a EUDAMED DI/ID for legacy devices. A legacy device need not be registered if the same device is already registered under the MDR/IVDR, unless a vigilance event concerns only the legacy version. Devices no longer placed on the market need registering only if a vigilance or post-market action arises.

MethodBest for
Web interfaceUp to about 100 devices
XML bulk uploadAbout 100–1,000 devices, validated against the published schemas
Machine-to-machine (M2M)Large portfolios; needs an eDelivery access point

Prepare the data first: issuing-entity identifiers (GS1, HIBCC, ICCBBA or IFA), Basic UDI-DIs and UDI-DIs, EMDN nomenclature codes and, where relevant, the eIFU address.

swissdamed: Switzerland’s own database

Because the EU–Switzerland mutual recognition agreement was not updated for the MDR, Switzerland runs its own registration. An EU SRN does not count there, and EUDAMED data does not flow across.

  • Actors module: Swiss manufacturers, Swiss representatives (CH-REP), importers and system/procedure pack producers get a CHRN (CHF 200, up to 30 days). Foreign manufacturers do not register as actors but must appoint a CH-REP.
  • Devices module: mandatory since 1 July 2026; devices already on the market must be registered by 31 December 2026; devices with a vigilance event immediately.
  • Who uploads: Swiss manufacturers and CH-REPs for the devices they hold mandates for; a CH-REP can give the foreign manufacturer’s staff an editor role.
  • Importers link their CHRN to already registered UDI-DIs (free, available since 1 October 2026; enforced from 1 April 2027).
  • Upload: online editor, XML in EUDAMED format (max 300 pairs per file) or a REST/JSON API.

The updated EU–CH device agreement signed in 2026 is not in force yet; plan as if the separate system stays for now. See Swiss pharma and medtech into Germany.

Checklist for a non-EU maker selling in the EU and Switzerland

  1. Representatives first: an EU authorised representative (and its SRN) and, separately, a CH-REP registered in swissdamed.
  2. EUDAMED access: EU Login, actor request with mandate summary and security declaration, user access.
  3. UDI data: issuing entity, Basic UDI-DIs, UDI-DIs, EMDN codes, eIFU.
  4. Register in EUDAMED: new devices before first sale; existing devices by 27 November 2026.
  5. Re-use the data for swissdamed via XML by 31 December 2026.
  6. Brief Swiss importers to link their CHRN by 1 April 2027.
Common questions

EUDAMED and swissdamed, answered

When did EUDAMED become mandatory?

The actor, UDI/device, notified body and certificate, and market surveillance modules became mandatory on 28 May 2026, six months after the Commission notice of 27 November 2025.

What is the deadline for devices already on the EU market?

Devices placed on the market before 28 May 2026 that continue to be sold must be registered within 12 months of the notice: 28 November 2026 per the Commission timeline. Treat 27 November 2026 as the safe date.

Does an EU SRN work in Switzerland?

No. Switzerland uses swissdamed with its own CHRN numbers. Foreign manufacturers need a Swiss representative (CH-REP), and data must be uploaded separately; there is no interface between the systems.

When must devices be registered in swissdamed?

Device registration has been mandatory since 1 July 2026. Devices already on the Swiss market must be registered by 31 December 2026, and devices with a vigilance event immediately.

How much does swissdamed registration cost?

CHF 200 for the first UDI-DI per manufacturer per year and CHF 20 for each additional one, capped at CHF 10,000 a year. Updates are free; foreign manufacturers are invoiced via their CH-REP.

AB
By Alexander Baranov
Founder, BCA Unternehmensberatung · market entry and market access in Germany since 2011
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