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Entering Other Markets from Switzerland

Switzerland → EU (MDR)

Swiss manufacturers accessing the EU market are treated as non-EU manufacturers under EU MDR. Requirements:

  • Appoint an EU REP established in an EU member state (EU MDR Art. 11)
  • Complete EU MDR conformity assessment (CE marking)
  • Register in EUDAMED
  • Comply with EU member state labelling language requirements

A CH REP and an EU REP are separate roles. A single organisation can hold both roles only if it is legally established in both Switzerland and an EU member state. Check whether the MRA affects this for Swiss-established manufacturers.

Switzerland → UK (UKCA)

The UK left the EU and has its own UKCA marking system for medical devices. Swiss manufacturers accessing the UK market must:

  • Register with the MHRA (Medicines and Healthcare products Regulatory Agency)
  • Appoint a UK Responsible Person established in the UK
  • Apply the UKCA mark (or CE mark during the transitional period — verify current MHRA position)
  • Comply with UK MDR 2002 (as amended) and UKCA marking requirements under the Medical Devices Regulations 2020/1574

The UK regulatory framework diverges from both MedDO and EU MDR in several areas, including notified body procedures, post-market surveillance reporting, and registration timelines. Always verify the current UK requirements on the MHRA website before finalizing your market access strategy.

Switzerland → Other Major Markets

MarketRegulatorKey Requirement
AustraliaTGAARTG registration; Australian Sponsor required
CanadaHealth CanadaMedical Device Licence; Canadian Importer/Manufacturer
JapanPMDA / MHLWJapan MAH required; FMR; Shonin/Ninsho approval
SingaporeHSAHSA registration; Singapore RSH required
BrazilANVISAANVISA registration; local representative
ChinaNMPANMPA registration; local agent

Multi-Market Submission Strategy

When planning simultaneous market access across CH, EU, and other jurisdictions:

  1. Align technical documentation to EU MDR/IVDR (which satisfies MedDO)
  2. Use a single ISO 13485 QMS scope covering all markets
  3. Plan labelling for the most demanding language requirements (Swiss DE/FR/IT covers EU requirements in those languages)
  4. Sequence NB engagement for EU MDR first — Swiss market access follows as a procedural step