Guide
From paper to eIFU: an implementation guide
A step-by-step guide to switching from paper instructions to electronic ones, with the article behind every condition.
Last reviewed
- 7
- decisions, in order
- Art. 3 to 7
- Reg (EU) 2021/2226
- 10 or 15 years
- retention to plan for
Since July 2025, Regulation (EU) 2021/2226 allows electronic instructions for almost every device intended for professional use, not only the short list of device types it originally named. The conditions are set out in Articles 4 to 7, and each one can be answered from the text of the regulation.
Meeting them comes down to seven decisions. This guide works through them in the order they depend on each other, with the article behind each one, so regulatory, quality and IT teams can plan the switch from one document.
The seven decisions
In the order they unlock each other. The guide takes each one in full.
- 1 Art. 3 Art. 3 (1) Manufacturers may provide instructions for use in electronic form instead of in paper form where those instructions relate to devices referred to in Article 1(4) of Regulation (EU) 2017/745 intended for use by professional users. (2) Where it is reasonably foreseeable that a device intended for use by professional users is also used by lay persons, manufacturers shall provide the instructions for use intended for lay persons in paper form. (3) For software covered by Regulation (EU) 2017/745, manufacturers may provide instructions for use in electronic form by means of the software itself instead of in paper form. eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect. Art. 4 Art. 4 (1) Manufacturers of devices referred to in Article 3, paragraphs 1 and 3, that provide instructions for use in electronic form to users instead of in paper form shall undertake a documented risk assessment which shall cover at least the following elements: (a) knowledge and experience of the intended users in particular regarding the use of the device and user needs; (b) characteristics of the environment in which the device will be used; (c) knowledge and experience of the intended user of the hardware and software needed to display the instructions for use in electronic form; (d) access of the user to the reasonably foreseeable electronic resources needed at the time of use; (e) performance of safeguards to ensure that the electronic data and content are protected from tampering; (f) safety and back-up mechanisms in the event of a hardware or software fault, particularly if the instructions for use in electronic form are integrated within the device; (g) foreseeable medical emergency situations requiring the provision of information in paper form; (h) impact caused by the temporary unavailability of the specific website or of the internet in general, or of their access in the healthcare institution as well as the safety measures available to cope with such a situation; (i) evaluation of the period within which the instructions for use shall be provided in paper form at the user’s request; (j) assessment of the website’s compatibility displaying the electronic instructions for use with different devices which could be used to display those instructions; (k) management of different versions of the instructions for use, where applicable in accordance with Article 5(8). (2) The risk assessment for the provision of the instructions for use in electronic form shall be updated in view of the experience gained in the post-marketing phase. eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect. Art. 5 Art. 5 Manufacturers of devices referred to in Article 3, paragraphs 1 and 3, may provide instructions for use to users in electronic form instead of in paper form under the following conditions: (1) the risk assessment referred to in Article 4 shall demonstrate that providing instructions for use in electronic form maintains or improves the level of safety obtained by providing the instructions for use in paper form; (2) they shall provide instructions for use in electronic form in all Member States where the product is made available or put into service unless duly justified in the risk assessment referred to in Article 4; (3) they shall have a system in place to provide the instructions for use in paper form at no additional cost for the user, within the time period set out in the risk assessment referred to in Article 4 and at the latest within 7 calendar days of receiving a request from the user or at the time of delivery of the device if so requested at the time of order; (4) they shall provide, on the device or a leaflet, information on foreseeable medical emergency situations and, for devices fitted with a built-in system visually displaying the instructions for use, information on how to start the device; (5) they shall ensure the proper design and functioning of the instructions for use in electronic form and provide verification and validation evidence to this effect; (6) for devices fitted with a built-in system visually displaying the instructions for use, they shall ensure that displaying the instructions for use does not impede the safe use of the device, in particular, life-monitoring or life-supporting functions; (7) they shall provide, in their catalogue or other appropriate device information support, information on software and hardware requirements needed to display the instructions for use; (8) they shall have a system in place to clearly indicate when the instructions for use have been revised and to inform each user of the device thereof if the revision was necessary for safety reasons; (9) for devices with a defined expiry date, except implantable devices, they shall keep the instructions for use available for users in electronic form for 10 years after the last device has been placed on the market and at least 2 years after the end of the expiry date of the last produced device; (10) for devices without a defined expiry date and implantable devices, they shall keep the instructions for use available for the users in electronic form for 15 years after the last device has been placed on the market; (11) the instructions for use shall be available on their website in an official language of the Union determined by the Member State in which the device is made available; (13) during the periods set out in points (9) and (10), all issued electronic versions of the instructions for use and their date of publication shall be available on the website or, as regards versions that are obsolete, be made available upon request. eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect.
Confirm the device qualifies
Whether paper can be replaced at all, and for which part of the instructions.
- 2 Art. 4 Art. 4 (1) Manufacturers of devices referred to in Article 3, paragraphs 1 and 3, that provide instructions for use in electronic form to users instead of in paper form shall undertake a documented risk assessment which shall cover at least the following elements: (a) knowledge and experience of the intended users in particular regarding the use of the device and user needs; (b) characteristics of the environment in which the device will be used; (c) knowledge and experience of the intended user of the hardware and software needed to display the instructions for use in electronic form; (d) access of the user to the reasonably foreseeable electronic resources needed at the time of use; (e) performance of safeguards to ensure that the electronic data and content are protected from tampering; (f) safety and back-up mechanisms in the event of a hardware or software fault, particularly if the instructions for use in electronic form are integrated within the device; (g) foreseeable medical emergency situations requiring the provision of information in paper form; (h) impact caused by the temporary unavailability of the specific website or of the internet in general, or of their access in the healthcare institution as well as the safety measures available to cope with such a situation; (i) evaluation of the period within which the instructions for use shall be provided in paper form at the user’s request; (j) assessment of the website’s compatibility displaying the electronic instructions for use with different devices which could be used to display those instructions; (k) management of different versions of the instructions for use, where applicable in accordance with Article 5(8). (2) The risk assessment for the provision of the instructions for use in electronic form shall be updated in view of the experience gained in the post-marketing phase. eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect. Art. 5(1) Art. 5(1) the risk assessment referred to in Article 4 shall demonstrate that providing instructions for use in electronic form maintains or improves the level of safety obtained by providing the instructions for use in paper form; eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect. Art. 5(2) Art. 5(2) they shall provide instructions for use in electronic form in all Member States where the product is made available or put into service unless duly justified in the risk assessment referred to in Article 4; eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect.
Complete the risk assessment
What stays on paper, the period set for paper on request, and whether any market needs an exception.
- 3 Art. 7 Art. 7 (1) Where manufacturers provide the instructions for use in electronic form on an electronic storage medium together with the device, or where the device itself is fitted with a built-in system visually displaying the instructions for use, the instructions for use in electronic form shall also be made accessible to the users through a website. (2) Any website containing instructions for use of a device which are provided in electronic form instead of in paper form shall comply with the following requirements: (a) the instructions for use shall be provided in a commonly used format that can be read with freely available software; (b) it shall be protected against unauthorised access and tampering of content in accordance with Article 4(1), point (e); (c) it shall be provided in such a way that the server downtime and display errors are reduced as far as possible; (d) it shall fulfil the requirements of Regulation (EU) 2016/679; (e) the internet address as displayed in accordance with Article 6(2) shall be stable and directly accessible during the periods set out in Article 5, points (9) and (10). (3) At the latest at the date from which the registration of devices in the UDI database referred to in Article 28 of Regulation (EU) 2017/745 applies in accordance with Article 123(3), point (d) or point (e), of that Regulation, as applicable, the manufacturer shall provide the internet address referred to in paragraph (2), point (e), of this Article to the UDI database in accordance with Part B, point 22, of Annex VI to Regulation (EU) 2017/745. eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect.
Choose where the instructions will live
The address that has to stay stable and accessible for 10 or 15 years.
- 4 Art. 6 Art. 6 (1) Manufacturers shall clearly indicate on the label that the instructions for use of the device are supplied in electronic form instead of in paper form. That information shall be provided on the packaging for each unit or, where appropriate, on the sales packaging. In the case of fixed installed devices, that information shall also be provided on the device itself. In the case of software, the information shall be provided at the location from where access to the software is granted. (2) Manufacturers shall provide information on how to access the instructions for use in electronic form. That information shall be provided as set out in the second subparagraph of paragraph 1 or, if not practicable, in a paper document supplied with each device. (3) The information on how to access the instructions for use in electronic form shall also contain the following: (a) any information needed to view the instructions for use; (b) the Basic UDI-DI and/or the UDI-DI of the device, as respectively referred to in Article 27(6) and Article 27(1), point (a)(i), of Regulation (EU) 2017/745, and any additional information allowing the identification of the device, including its name and if applicable the model; (c) relevant manufacturer contact details e.g. manufacturer’s name, address, email address or other means of online communication and website; (d) where and how instructions for use in paper form can be requested and within which time they shall be obtained at no additional cost in conformity with Article 5, point (3). (5) The instructions for use in electronic form shall be available entirely as text, which may contain symbols and graphics, with at least the same information as the instructions for use in paper form. Video or audio files may be provided in addition to the text. eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect.
Update labelling and packaging
How the label tells the user the instructions are electronic and how to reach them.
- 5 Art. 5(3) Art. 5(3) they shall have a system in place to provide the instructions for use in paper form at no additional cost for the user, within the time period set out in the risk assessment referred to in Article 4 and at the latest within 7 calendar days of receiving a request from the user or at the time of delivery of the device if so requested at the time of order; eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect.
Build the paper-on-request process
A no-cost route to paper within the assessed period, seven calendar days at the latest.
- 6 Art. 7(3) Art. 7(3) At the latest at the date from which the registration of devices in the UDI database referred to in Article 28 of Regulation (EU) 2017/745 applies in accordance with Article 123(3), point (d) or point (e), of that Regulation, as applicable, the manufacturer shall provide the internet address referred to in paragraph (2), point (e), of this Article to the UDI database in accordance with Part B, point 22, of Annex VI to Regulation (EU) 2017/745. eIFU Regulation · consolidated 2025-07-16. This text is meant purely as a documentation tool and has no legal effect.
Register the address in EUDAMED
A UDI database entry, mandatory for MDR devices with electronic instructions.
- 7 Recital 7, 2025/1234
Route the change through your quality system
Conformity assessment, not a standalone eIFU submission.
Sources
Every statement on this page is traceable to one of these texts, read in the Official Journal rather than in secondary commentary. The guide lists every provision it relies on.
Show 3 sources
- Commission Implementing Regulation (EU) 2021/2226 Cited as amended. Articles 3 to 5 on eligibility. Article 4 and Article 5, points (1) and (2), on the risk assessment. Article 5, point (3), on paper on request. Article 6 on the label. Article 7 on the website, and Article 7(3) on the UDI database.
- Commission Implementing Regulation (EU) 2025/1234 The replacement of Article 3(1) and 3(2), which turned a list of device categories into a test based on who uses the device. Recital 7 on requirements clarified or deleted to remove uncertainties and overlaps, among them Article 8. In force 16 July 2025.
- Regulation (EU) 2017/745 (MDR) Annex VI, Part B, point 22, on the UDI database. Article 52 and Annexes IX to XI on conformity assessment.