Medical device manufacturers must continually adapt their processes and systems to changing regulatory requirements.
In the United States, the FDA’s Quality Management System Regulation (QMSR) took effect on February 2, 2026. It replaces the former Quality System Regulation (QSR) under 21 CFR Part 820, which governs how devices are designed, manufactured, packaged, labeled, stored, installed, and serviced. Rather than maintaining its own framework, the FDA now incorporates ISO 13485:2016 by reference, while keeping specific requirements like records, labeling, and packaging. The bottom line: procedures, checklists, and documentation built around the old QSR may need an update.
In the European Union, the Medical Device Regulation (EU) 2017/745 (MDR) and the In Vitro Diagnostic Medical Device Regulation (EU) 2017/746 (IVDR) set similar expectations. The technical documentation must describe the variants and configurations of a device that are intended to be made available on the market. The Unique Device Identification (UDI) system also requires a new UDI-DI whenever a change could lead to misidentification of the device or ambiguity in its traceability. In other words, configuration decisions can have direct regulatory consequences.
These requirements reinforce the importance of consistent processes, reliable product information, and traceability. For manufacturers with highly configurable medical devices, the challenge extends beyond maintaining individual product records. They also need to understand which combinations of hardware, software, features, and options are valid for a particular product, market, or customer requirement, and which of those combinations are covered by the relevant marketing authorization, whether that be a 510(k) clearance, a PMA approval, or a CE certificate, in each market.