The extension of the validity of the MDD certificates under the MDR is, in our opinion, essential to ensure adequate availability of medical devices on the market. However, we do think that only extending the validity of the certificates without taking any further actions will lead to the same problems as we face today when the new deadlines approach.
DEM
DEMCON
Company · Netherlands
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
2
positions filed
in the 665 files tracked
2
legislative files
of 665 tracked
0
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 (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
DEMCON filed 2 positions between 18 Jan 2023 and 13 Nov 2025, across 2 of the 665 legislative files tracked here.
2023 · 1 filed2025 · 1 filed
What they argued
As part of a large industrial organisation, we see that many SME partners with whom we collaborate in innovative (EU-) funded projects are unable to participate due to the current definition of undertakings in difficulty. This definition is essentially a balance-sheet exercise and does not account for expected incoming funding or available risk capital.
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