The Association of Medical Device Reprocessors, AMDR, respectfully submits feedback with regard to Article 17, or the single-use device reprocessing provisions. Consistent with this call for evidences objectives, we strongly urge the Commission to recommend a simplification of Article 17.1 to reduce the needless and disproportionate burden placed on innovative, circular reprocessed or remanufactured devices.
AMD
Association of Medical Device Reprocessors
Industry association · Germany · EU Transparency Register 884250338262-72
4
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #731 by legislative files engaged, a count of participation, not a measure of influence.
0.2
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2020
in the register since
Declares membership of
- AMDR is a member of:
- the standard setting organization, the Association for the Advancement of Medical Instrumentation:https://www.aami.org/
- the Remanufacturing Association Alliance: http://www.remancouncil.org/collaborate/partnerships/remanufacturing-associ…
- and
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Head office
- Washington, United states
- EU office
- Berlin
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Association of Medical Device Reprocessors filed 4 positions between 31 Aug 2020 and 18 Sept 2025, across 4 of the 665 legislative files tracked here, attaching a full position paper 4 times.
2020 · 2 filed2022 · 1 filed2025 · 1 filed
What they argued
The Association of Medical Device Reprocessors (AMDR) appreciates the Commission’s efforts to promote a cleaner and more competitive Europe. We welcome the opportunity to provide feedback to the Inception Impact Assessment on the Sustainable Products Initiative. - AMDR strongly agrees with the Commission’s aim to widen the scope of the existing EcoDesign Directive beyond energy related products.
The Association of Medical Device Reprocessors, representing the regulated, commercial medical device reprocessing and remanufacturing industry, respectfully submits the attached comments promoting reuse and repair for "single-use" medical devices.
The Association of Medical Device Reprocessors (AMDR) appreciates the Commission’s efforts to promote a green transition. We welcome the opportunity to provide feedback to the Inception Impact Assessment on Empowering the Consumer for the Green Transition. AMDR strongly encourages the Commission to amend existing consumer protection legislation OR create a new stand-alone consumer protection instrument.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.