Timelines for the Introduction of the Master UDI-DI

Timelines for the Introduction of the Master UDI-DI

MDCG Publishes Timelines for the Introduction of the Master UDI-DI for Eyewear and Contact Lenses

The Medical Device Coordination Group (MDCG) has released its MDCG 2025-7 position paper, setting out the official timelines for the implementation of the Master UDI-DI for highly individualised medical devices, including:

  • Contact lenses

  • Spectacle frames

  • Spectacle lenses

  • Ready-to-wear reading spectacles

Background

The Master UDI-DI is a new identification concept for highly individualised products. It allows similar devices with identical design characteristics to be grouped under a single identifier in EUDAMED.
The aim is to reduce the number of UDI records and simplify management for manufacturers, distributors, and authorities.

Key Deadlines at a Glance

Product Category UDI Labelling Requirement Mandatory Use of EUDAMED UDI/Device Registration Module Mandatory Master UDI-DI Transition Phase
Contact lenses 26 May 2023 (Class IIa/IIb) Q1 2026 9 November 2026 Q1 2026 – Q4 2026
Spectacle frames, spectacle lenses, ready-to-wear reading spectacles 26 May 2025 (Class I) Q1 2026 September 2028 Q1 2026 – Q3 2028

Voluntary Implementation Encouraged

Manufacturers are allowed – and encouraged – to assign Master UDI-DIs before the mandatory deadlines. Early adoption offers benefits such as:

  • Gaining operational experience with the new identifier

  • Facilitating vigilance reporting and post-market surveillance

  • Ensuring internal processes are fully aligned before deadlines

Industry Impact

The introduction of the Master UDI-DI marks a significant step toward harmonisation and reduced administrative burden in UDI management. However, manufacturers should start preparing now to ensure technical readiness and regulatory compliance.

Further resources:

Ugur Müldür

Ugur Müldür leads Sales & Marketing activities at Europe IT Consulting GmbH in Basel, Switzerland. With an industrial engineering background, he bridges regulatory requirements, business needs, and IT implementation for UDI programs. He works with MedTech manufacturers to improve data quality, streamline submissions, and operationalize UDI solutions across global regulations.