Your legacy device, its real sunset date, and the gap

Which Regulation (EU) 2023/607 date your legacy device actually falls under, and how many days are left.

Sunset date that binds this device
Days left before that datedays
Last safe day to hand over the dossier
Slack against that day, negative means already latedays
Days with no valid certificatedays
EU revenue those days carryEUR
Basis in law

Answer above is free and unlimited. The full version exports your whole legacy-device portfolio as a CSV you keep and sets a browser alarm before each device’s last safe submission date.

Portfolio CSV export and submission alarms — $60

$60 once · one licence key per person or team seat · 7-day full refund. Today this question is answered by a regulatory affairs consultant, per device, at around EUR 150 per hour.

Applicable sunset date
Maps your device to the Article 120 date that actually binds it: 2026-05-26, 2027-12-31, 2028-12-31 or 2029-12-31.
The suture and dental carve-out
Class IIb implantables that are sutures, staples, dental fillings, braces, crowns, screws, wedges, plates, wires, pins, clips or connectors drop to 2028-12-31, not 2027-12-31.
Last safe submission date
Back-calculates from the sunset date by your notified body review length, so you see the day the dossier has to be in their hands.
Days off the EU market
Turns a late dossier into days with no valid certificate and the EU revenue those days carry.
Portfolio CSV export
Paid layer: one row per legacy device so the whole portfolio review leaves the browser as a file you own.
Submission date alarm
Paid layer: a browser alarm before each device's last safe submission date, repeated until you clear it.

Get the complete version $60

This page is the working piece. The full pack has everything below.

Which Regulation (EU) 2023/607 date your legacy device actually falls under, and how many days are left.

Today this question is answered by a regulatory affairs consultant, per device. At a EUR 150 per hour EU RA consulting rate, one device's Article 120 date and submission-gap check is about half a day of billed time.

Buy the full version — $60

Questions people ask

What does the MDR Legacy Sunset Clock actually do?

You pick your device's old-directive class and the extension returns the Regulation (EU) 2023/607 date that binds it: 2026-05-26, 2027-12-31, 2028-12-31 or 2029-12-31. It then subtracts your notified body review length to give the last day the dossier can be handed over, and the EU revenue any overrun costs.

Who is this for?

Regulatory affairs and quality managers at EU medical device and in vitro diagnostic manufacturers who still have products on the market under MDD, AIMDD or IVDD certificates. It is built for the person who has to say, in a management review, which quarter each legacy device stops being sellable in the EU.

Why will a free chatbot not answer this?

General chatbots still reply that the MDR transition ended on 2024-05-26, because that was the original deadline. Regulation (EU) 2023/607 replaced one date with four, split by risk class, carved sutures and dental devices out of the 2027 group, and deleted the sell-off provision entirely. A wrong date here is a product off the market.

What is free and what needs the key?

Every calculation is free and unlimited: the sunset date, the days left, the last safe submission day, the slack, and the revenue at risk, for any of the twelve device classes. The 60 dollar key adds two things on a different axis: a CSV of your whole portfolio that you keep, and browser alarms before each submission date.

What does this cost if a person does it?

This is normally answered by a regulatory affairs consultant, device by device. At a EUR 150 per hour EU consulting rate, roughly half a billed day goes into confirming the Article 120 class, the carve-out and the submission gap for a single device. A legacy portfolio is quoted per device, so the bill scales with your catalogue.

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