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    Class D Batch Verification (IVDR)

    Pre-release testing of every manufactured batch of Class D IVDs by an EU Reference Laboratory, where designated.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed July 25, 2026

    Definition

    Article 48(5) and Article 100 require that, for Class D devices where Common Specifications or, in their absence, harmonised standards exist and an EU Reference Laboratory has been designated for the device type, the manufacturer must have each batch tested by the EU RL before release. The EU RL verifies that the batch meets the applicable CS or the manufacturer's declared performance.
    What the regulation says
    Article 100(2)(a) tasks EU Reference Laboratories with verifying, by laboratory testing, the performance claimed by manufacturers and the conformity of devices with applicable CS or other solutions chosen by manufacturers.

    What this means in practice

    This is one of the strictest controls in EU device regulation and mirrors requirements historically used for blood-typing and infectious-disease screening. Manufacturers must build EU RL turnaround time into release planning and negotiate service-level expectations early.
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    Primary references

    3 sources
    Link health: 2 verified 1 unchecked· last checked 2026-06-20
    EUR-Lex·1European Commission·1IMDRF·1
    1. 1
      Regulation (EU) 2017/746, Articles 48(5) and 100
      Verified
      EUR-Lexeur-lex.europa.eu
    2. 2
      Commission Implementing Regulation designating EU RLs
      Unchecked
      European Commissionhealth.ec.europa.eu
    3. 3
      IMDRF Documents
      Verified
      IMDRFimdrf.org

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