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    Common Specifications (IVDR)

    Technical or clinical requirements adopted by Commission implementing act that manufacturers must comply with unless a demonstrably equivalent alternative is used.

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

    Definition

    Article 9 of the IVDR empowers the Commission to adopt Common Specifications (CS) covering general safety and performance requirements, technical documentation, clinical evidence, post-market surveillance, or performance studies. Where CS exist, manufacturers must comply with them unless they can duly justify an alternative solution that ensures a level of safety and performance at least equivalent.
    What the regulation says
    Article 9(3) states that manufacturers shall comply with CS unless they can duly justify that they have adopted solutions that ensure a level of safety and performance at least equivalent thereto.

    What this means in practice

    CS are especially important for Annex II (List A/B legacy) high-risk assays such as HIV, HCV, HBV, and blood-group typing. Implementing Regulation (EU) 2022/1107 established the first set of IVDR CS for Class D devices. CS carry legal force stronger than harmonised standards.
    Common pitfalls
    • Treating CS as optional guidance. They are binding secondary law.
    • Missing the CS revision cadence and continuing to rely on withdrawn CTS from the old IVDD regime.
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    Primary references

    3 sources
    Link health: 2 verified 1 unchecked· last checked 2026-06-20
    EUR-Lex·2FDA·1
    1. 1
      Regulation (EU) 2017/746, Article 9
      Verified
      EUR-Lexeur-lex.europa.eu
    2. 2
      Implementing Regulation (EU) 2022/1107
      Unchecked
      EUR-Lexeur-lex.europa.eu
    3. 3
      FDA - Medical Devices
      Verified
      FDAfda.gov

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