blog

Navigating the UK Market: A UKRP Perspective on Medical Device and IVD Registration

Written by Melissa Smits & Dennis Sarwin | Mar 10, 2026 8:00:00 AM

As the UK continues to refine its post‑Brexit regulatory landscape for medical devices and in vitro diagnostics, manufacturers placing products on the market face a multilayered set of obligations. Appointing a UK Responsible Person (UKRP) remains one of the cornerstone requirements for non‑UK manufacturers. Acting as a UKRP, we first-hand witness complexities, common pitfalls, and practical realities of supporting manufacturers through MHRA registration and ongoing compliance. In this blog, we share insights into the UKRP appointment and registration process, the importance of proper documentation, the obligations manufacturers should understand from the outset, and real-world observations from daily practice.

1. UKRP Appointment & MHRA Registration: What Manufacturers Should Expect

For any non-UK manufacturer intending to place a device or IVD on the Great Britain market, appointing a single UK Responsible Person is mandatory. Once the appointment is formalized through a UKRP Agreement and Letter of Designation, the first major step is registering the devices with the MHRA. This involves the following key steps:

    • Verification of the manufacturer’s regulatory documentation
      Before any submission, the UKRP must conduct checks to ensure compliance with the UK Medical Devices Regulations (UK MDR 2002, as amended). Under the Medical Devices (Amendment) (Great Britain) Regulations 2023 (SI 2023/627), the acceptance of CE-marked medical devices and IVDs is extended. Allowing non-UK manufacturers also to place their medical devices and IVDs on the Great Britain market when their medical devices and/or IVDs are CE-mark compliant.
    • Creation of the manufacturer profile in the MHRA Database (DORS) system
      Accurate company information, UDI/device identifiers, classification, and conformity assessment details must be provided.
    • Submission of device listings to MHRA
      Registrations must reflect current product status, correct GMDN codes, and the scope of CE marking or UKCA marking.
    • Management of MHRA queries
      The MHRA occasionally requests clarifications or additional evidence. Timely responses keep the process on track.

While the steps seem straightforward, the quality of the underlying documentation and the manufacturer's readiness often define how smooth - or challenging -  the registration process will be.

2. Registration Evidence: PARD and Its Role

Manufacturers frequently assume registration is complete once the MHRA acknowledgement letter is received. However, stakeholders or customers often request additional proof. This is where the Public Access Registration Database (PARD) becomes relevant.

Why PARD matters:

    • PARD is the official public database where MHRA-published registrations are visible.
    • It provides independent verification that a device and its manufacturer are registered correctly under the appointed UKRP.
    • Not all devices appear immediately, and delays between MHRA registration and public posting are common. Updates to PARD usually happen weekly on Mondays.

As a UKRP, we often clarify that MHRA registration confirmation and PARD visibility are separate milestones. Manufacturers should be aware that some customers rely exclusively on PARD for procurement checks, so understanding the timeline and limitations helps avoid unnecessary confusion.

3. UKRP Obligations: Beyond Filing Registrations

The responsibilities of a UKRP extend far beyond registration. Under the UK MDR, the UKRP must perform several ongoing compliance tasks, ensuring that manufacturers maintain conformity throughout the lifecycle of their devices.

Core UKRP obligations include:

    • Verifying conformity documentation
      Ensuring that technical documentation, Declarations of Conformity, certificates, and PMS procedures remain aligned with regulatory requirements.
    • Acting as the primary UK contact for the MHRA
      This includes managing communications related to vigilance, field safety corrective actions, and post-market issues.
    • Supporting the manufacturer in incident reporting
      The UKRP may submit vigilance reports on behalf of the manufacturer when required.
    • Holding available the technical documentation for inspection
      The UKRP must be able to provide documentation to MHRA promptly upon request.
    • Ensuring device information provided to MHRA remains accurate
      Any change, manufacturer address, device status, certificates, must be updated without delay.

These obligations underscore the importance of appointing a UKRP with strong regulatory expertise and the operational capacity to maintain oversight.

4. Real‑World Experiences: Common Challenges and Lessons Learned

Supporting a diverse portfolio of medical device and IVD manufacturers (more than 300) provides valuable insights into trends, recurring issues, and best practices. A few observations from everyday UKRP operations include:

Documentation gaps slow down registrations

Incomplete technical files, expired certificates, missing DoCs, or outdated labelling commonly delay the initial verification process. Manufacturers who maintain well‑organized regulatory documentation experience far smoother onboarding.

Misunderstandings about UK requirements remain common

Many manufacturers assume EU MDR and IVDR compliance automatically satisfies UK requirements. Although the UK currently accepts CE-marked devices, there are UK‑specific obligations, such as MHRA registration and specific vigilance reporting procedures, that must not be overlooked.

Keeping registrations up to date is often underestimated

Changes in device status, company name, address, DoCs, or certificates require updates in DORS. Failing to update registrations in time can result in MHRA scrutiny, particularly during manufacturer audits or when customers request PARD verification.

Clear communication is essential

Manufacturers who communicate early, especially regarding upcoming changes or potential issues, help prevent compliance gaps. Delayed communication often leads to more reactive rather than proactive compliance management.

Partnership mindset leads to the best outcomes

UKRP-manufacturer relationships work best when treated as regulatory partnerships rather than transactional administrative tasks. Regular alignment (calls), transparent planning, and early involvement in product or documentation changes strengthen compliance and reduce risks.

Conclusion

The UK regulatory landscape continues to evolve, and manufacturers navigating the UK market must ensure they meet both initial and ongoing obligations. From the appointment of a UKRP to MHRA registration, the process requires diligence, accurate documentation, and continuous compliance monitoring.

As a UKRP, our role extends beyond administrative submissions. We act as the manufacturer’s regulatory anchor in the UK, ensuring devices remain compliant; documentation stays current, and communication with MHRA is consistent and effective.

We guide you every step of the way toward full compliance across all device classes. Ready to enter or expand in the UK market? Get in touch with our experts today for support with MHRA registration, UKCA compliance, and seamless UK market access.