EU MDR · IFU · Intended purpose

Is your IFU compliant with EU MDR?

Your Instructions for Use are now a regulatory document. Under EU MDR, every claim of intended purpose, benefit and indication must be traceable to clinical evidence, or removed. Here is how to make yours defensible.

EU MDR 2017/745Article 61 & Annex XIVMDCG 2020-5 / 2020-6Intended purpose & indications
IFU compliance under EU MDR, Eclevar MedTech

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Reviewed by the people who assess claims.

IFU claims are where clinical evidence meets the reviewer. Ours are pressure-tested by clinicians and former Notified Body reviewers before a Notified Body ever sees them.

Pierre-Marie Boutanquoi

Pierre-Marie Boutanquoi

CMO & Head of Medical Writing · 15+ yrs

CERs under MEDDEV 2.7/1 Rev 4 and EU MDR; aligning intended purpose, claims and clinical evidence.

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Dr Mark Da Costa

Dr Mark Da Costa

COO & CMO · 25+ yrs

Former lead Notified Body reviewer at TÜV SÜD. 400+ devices CE-certified.

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Former Notified Body reviewersArticle 61 & Annex XIVMDCG 2020-5 / 2020-6State of the art

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Platinum Award 2026

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The requirements

From a marketing document to a clinical one.

The European regulatory landscape has shifted profoundly. The IFU is no longer a leaflet, it is the bridge between the clinical evidence and what you tell users the device does, and every word of it can be challenged.

01 / 06

Why the IFU is now a regulatory document

Manufacturers must ensure their Instructions for Use clearly communicate the device’s intended purpose, clinical benefits, indications, conditions of use and contraindications — all supported by robust clinical evidence. The IFU is where the clinical evaluation becomes visible to the user, and to the reviewer.

02 / 06

Intended purpose: from MDD to MDR

The definition of intended purpose has been refined, and the change matters.

MDD 93/42/EEC

The old definition

“The use for which the device is intended according to the data supplied by the manufacturer on the labeling, in the instructions and/or in promotional materials.”

MDR 2017/745 · Article 2

The expanded definition

The use for which a device is intended according to the label, IFU, promotional or sales materials or statements, and as specified by the manufacturer in the clinical evaluation.

The expansion is the point: intended purpose must be communicated consistently across every material and must be substantiated by clinical evaluation.

03 / 06

What Article 61 and Annex XIV require

Article 61 and Annex XIV, with clarifications from MDCG 2020-5 and 2020-6, set what the clinical evaluation must do to back the IFU.

The clinical evaluation must

  • Clearly identify the intended purpose, clinical benefits, conditions of use and specific contraindications
  • Ensure the available clinical evidence justifiably supports all claims made in the IFU
  • Establish outcomes achievable with other state-of-the-art (SOTA) therapies for the same population and indication
  • Determine benchmarks for safety, performance and benefit-risk
  • Define measurable parameters, endpoints and acceptable outcomes

04 / 06

Intended purpose vs indications

Article 2(12) keeps the definition of intended purpose from the Directives, and Annex I Section 23.4 confirms the intended purpose includes indications, where they exist. But per MDCG 2020-6, an indication is the clinical condition being diagnosed, prevented, treated or controlled — while intended purpose describes the device’s effect. All devices have an intended purpose; not all have an indication (for example, a device for disinfection or sterilisation).

05 / 06

What your IFU must contain

A compliant IFU starts from a clear, comprehensible description of the intended purpose and the standard of care, then flows into everything else.

Intended purpose defines

  • The target patient population and clinical condition
  • The clinical benefits and therapeutic outcomes
  • Conditions of use: setting, operator qualifications, patient characteristics
  • Contraindications and warnings
  • Performance expectations, safety parameters and the clinical evidence required

06 / 06

How to make every claim defensible

The test is simple and unforgiving: can the clinical evidence justify each IFU claim against the state of the art, with a defined endpoint and an acceptable outcome? Where it can, we document the link explicitly. Where it cannot, the claim is a Notified Body deficiency waiting to happen and must be substantiated or removed. Our medical writers align the clinical evaluation report and the IFU so a reviewer can trace every claim end to end.

The IFU test

Every claim, traced to evidence.

Art. 61
clinical evaluation must support IFU claims
Annex XIV
defines the clinical evaluation process
MDCG 2020-6
intended purpose vs indications
SOTA
the benchmark every claim is judged against

Talk to a reviewer

Would your IFU survive a Notified Body review today?

Book a free IFU review with a former Notified Body reviewer and a medical writer. We map every claim to its evidence and flag the ones a reviewer would challenge.

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An IFU claim you can’t defend is a deficiency you haven’t found yet.

An expert read maps every intended-purpose and benefit claim to its clinical evidence, checks it against the state of the art, and tells you exactly what to substantiate or remove before submission.

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Questions we hear first

IFU compliance under EU MDR, answered.

What must an IFU contain under EU MDR?
The IFU must clearly communicate the device's intended purpose, clinical benefits, indications, conditions of use and contraindications, and every claim must be supported by the clinical evaluation. The IFU is now a regulatory document that bridges the clinical evidence and what users are told the device does.
How did the definition of intended purpose change from MDD to MDR?
Under the MDD, intended purpose was the use for which the device is intended according to the labeling, instructions and promotional materials. EU MDR Article 2 expands this to include sales materials and statements and, crucially, requires that the intended purpose be as specified by the manufacturer in the clinical evaluation, so it must be consistent everywhere and substantiated by evidence.
What is the difference between intended purpose and indication?
Per MDCG 2020-6, an indication is the clinical condition to be diagnosed, prevented, monitored, treated, alleviated, compensated for, replaced, modified or controlled by the device, while intended purpose describes the effect of the device. All devices have an intended purpose, but not all have an indication, for example a device intended for disinfection or sterilisation.
What happens if IFU claims are not supported by clinical evidence?
Article 61 and Annex XIV require the clinical evaluation to justify every claim made in the IFU against the state of the art, with defined endpoints and acceptable outcomes. Claims the clinical evidence cannot support are a common source of Notified Body deficiencies and must be either substantiated or removed.

Reforming Clinical Evaluation of Medical Devices in Europe