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UDI Compliance Dates by Device Class

UDI phase-in timeline

FDA implemented UDI requirements in phases based on device class:

Device classUDI label complianceDirect marking (reusable devices)GUDID submission
Class IIISeptember 24, 2014September 24, 2015September 24, 2014
Class IISeptember 24, 2016September 24, 2018September 24, 2016
Class I and unclassifiedSeptember 24, 2018September 24, 2020September 24, 2018
Implantable, life-supporting, life-sustainingSeptember 24, 2015September 24, 2015September 24, 2015

Full compliance as of 2020

As of September 24, 2020, all device classes are required to comply with UDI labelling requirements. New devices entering the market after this date must comply from the date of commercial distribution.

Official resources

Full compliance as of 2020

Devices already in commercial distribution before their respective compliance date were subject to a transition period; however, any device repackaged or relabelled after the compliance date must comply with UDI requirements regardless of the original clearance/approval date.