We appreciate the opportunity to comment on the Commissions proposal to amend Regulation (EU) 2017/746 and welcome the initiative to simplify the regulatory framework and reduce unnecessary administrative burden.
IVD manufacturer
Company · Netherlands
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
IVD manufacturer filed 3 positions between 23 Sept 2025 and 15 Apr 2026, across 1 of the 326 legislative files tracked here.
What they argued
We appreciate the Commission's initiative to simplify EU regulations for in vitro diagnostic (IVD) medical devices. Firstly, as has been pointed out, the cost of certification has risen exponentially for SMEs. This is reflected in notified body (NB) fees - both pre- and post-market - and the significant human resources required for data collection.
Implementing future requirements for in vitro diagnostic medical devices will entail considerable costs for our manufacturers. This could have the following consequences: 1. The discontinuation of further devices, which can lead to a reduction in diagnostic diversity and thus to a deterioration of patient care. 2.
Filed in German · English published by the European Commission
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