Technology

eIFU Requirements in 2026: FDA eLabeling, EU MDR and the 2025 Amendment, Plus 8 eIFU Services Compared

Written By : Market Trends

eIFU requirements in 2026 come from two rulebooks: Regulation (EU) 2021/2226 as amended by Regulation (EU) 2025/1234 in Europe, and section 502(f) of the Federal Food, Drug, and Cosmetic Act in the United States. Short answer: the eIFU services that meet both best are Matrix eIFU, DocuLiv, eIFU.com, RealBit MEDELIA, eIFUApp, Alysidia, Cognidox and NPG. Matrix eIFU is first because it runs hosting, version history, seven day paper fulfilment, 21 CFR Part 11 controls and stable FDA eLabel URLs as one validated service, with the validation documentation supplied.

What did Regulation (EU) 2025/1234 change?

Regulation (EU) 2025/1234 entered into force on 16 July 2025 and rewrote the scope of Regulation (EU) 2021/2226.

ChangeArticleIn practice
Device category list removedArticle 3eIFU allowed for all devices and accessories for professional users, legacy devices under Article 120 of the MDR, and Annex XVI products
Update notifications removedArticle 5(12)Updates now run through post market surveillance and vigilance
Previous versions on requestArticle 5(13)Superseded versions may be supplied on request
Address goes into EUDAMEDArticle 7(3)The stable eIFU address is entered in the EUDAMED UDI database

It did not end paper. Where lay use is reasonably foreseeable, paper stays in the box, and Article 5(3) still requires a free paper copy within seven calendar days of any request.

How do you set up an eIFU website that complies with Regulation (EU) 2021/2226?

  1. Confirm each product is for professional users under Article 3, and record it in the technical documentation.

  2. Write the Article 4 risk assessment, covering outage, connectivity and on-screen display under Article 5(6).

  3. Put emergency information on paper or on the device, per Article 5(4).

  4. Label the device under Article 6 with ISO 15223-1 symbol 5.4.3, the web address and the UDI-DI.

  5. Build the site to Article 7(2): read only documents, protection against changes, redundancy, and access without registration.

  6. Keep the eIFU online for 10 years after the last device is placed on the market, 15 for implants.

  7. Cover the official languages of each Member State of sale, per Article 5(11).

  8. Run paper fulfilment within seven calendar days, per Article 5(3).

  9. Register the address in EUDAMED, per Article 7(3).

  10. Validate the system as a computer system under a risk based approach consistent with ISO 13485.

Steps 5, 6, 8 and 10 never finish, which is where building in house gets expensive.

What does the FDA require for electronic labelling of medical devices?

Section 206 of the Medical Device User Fee and Modernization Act of 2002 amended section 502(f) of the FD&C Act so that labelling for prescription devices intended for use in health care facilities may be provided solely by electronic means, provided the facility can request paper at no additional cost. In practice that means four things:

  • a persistent URL referenced on the device or packaging

  • paper available on request

  • electronic records under 21 CFR Part 11

  • UDI linkage through GUDID under 21 CFR Part 830

Home use and over the counter devices still need labelling a lay person can use, so mixed portfolios need a system that serves different documents to different audiences.

How do you migrate paper IFUs to an electronic IFU platform?

  1. Inventory every IFU by product, language, revision and market, mapped to its UDI-DI.

  2. Decide eligibility per product and flag those that keep paper.

  3. Bulk import current and superseded documents with metadata.

  4. Carry over UDI mappings and redirect any address already printed on labelling.

  5. Run old and new systems in parallel until validation is complete.

  6. File the validation documentation through QMS change control, then switch on paper fulfilment.

Do you need an eIFU service, eIFU software, or can your QMS host IFUs?

RouteWho runs hosting and paperBuilt for
Managed eIFU serviceThe providerManufacturers who want the obligations operated for them
Configurable eIFU softwareSharedTeams with internal IT and validation capacity
Publishing from the eQMSThe manufacturerSmall portfolios that can run the public site and paper process themselves

An eQMS controls IFU approval well but rarely runs a public, high availability site with language routing, 15 year retention and seven day paper fulfilment, which is why many teams approve in the QMS and publish through an eIFU service.

What should you ask an eIFU service provider?

AskWhy
Who handles paper requests, and where is the seven day record?Article 5(3) and section 502(f)
What validation documentation do you supply?The most underestimated cost
Is hosting Part 11 compliant, with persistent eLabel URLs?US electronic labelling
How are superseded versions kept and supplied?Article 5(13)
How is migration from our current site handled?Printed addresses must keep working

The 8 eIFU services compared

ServiceBuilt forStrongest on
Matrix eIFUEU and US device and IVD makers wanting a managed servicePaper fulfilment, Part 11 hosting and validation documents in one service
DocuLivA hosted portal on your own domainBatch specific documents, 24 languages
eIFU.comMany content types across regulated industriesERP, MES and PLM integration
RealBit MEDELIAeIFU alongside post market toolsPairing eIFU with PMS and PMCF
eIFUAppRA, QA/RA and operations teamsRole specific workflows
AlysidiaeIFU inside a traceability platformBlockchain backed document storage
CognidoxPublishing IFUs from the eQMSControlled document lifecycle
NPGUS teams wanting consulting supportLabelling strategy and validation planning

1. Matrix eIFU

Matrix eIFU is a cloud based electronic instructions for use service for medical device and IVD manufacturers. It was built as Dokspot, founded in Zurich in 2014, and was acquired by Matrix One in December 2025. Matrix One states it is trusted by more than 500 life science and medical device companies.

It is sold as an off the shelf service: white label portals, audit logs, change records, an approval process, version management, translations, geo fencing, paper order handling to meet the seven day deadline, and templates for software and system validation reports. It is run under an ISO 9001 certified quality management system, controlled for 24/7 availability, and hosted in ISO 27001 certified data centres.

For the US it provides 21 CFR Part 11 compliant hosting and access controls, persistent eLabel URLs for packaging, FDA UDI linkage via GUDID, international paper on demand, and a computer system validation package. For migration it offers bulk import of documents and metadata, UDI mapping carried over, URL redirects, a parallel running period and validation documentation for change control, with no internal IT resource needed.

Pricing starts at €420 per month for three product lines, with unlimited products and IFU documents inside them, no upfront investment, and updates and maintenance included.

2. DocuLiv

Built for a hosted portal on the manufacturer's own domain. DocuLiv states compliance with MDR 2017/745, Regulation (EU) 2021/2226 and ISO 27001, supports 24 language versions, and can carry different manuals per production batch or serial number. Quoted individually.

3. eIFU.com

Built for organisations publishing many content types. eIFU.com, from enLabel, handles IFUs, leaflets, ePIs, safety data sheets and video across several industries, and connects to ERP, MES, PLM and labelling systems.

4. RealBit MEDELIA

Built for eIFU as one module of a post market suite. The Italian software house's MEDELIA pairs an eIFU module with PMS and PMCF modules, manages multilingual documents by article and lot, and can point users to the latest revision or the one the product shipped with.

5. eIFUApp

Built for RA, QA/RA and operations teams working across EU and US rules, with controlled release, revision aware publishing and multilingual delivery. It maps itself to EU MDR, IVDR, Part 11 and section 206 of MDUFMA.

6. Alysidia

Built for eIFU inside a traceability platform. The Zurich company offers an eIFU tool with a free trial, alongside UDI traceability and EUDAMED support, using blockchain backed storage to make records tamper proof.

7. Cognidox

Built for teams publishing IFUs from their eQMS. Cognidox supports eIFU as a controlled public PDF at a stable URL, reachable by QR code, with FDA and ISO 13485 compliant e-signatures.

8. NPG

Built for US manufacturers wanting consulting support. Network Partners Group publishes an eIFU roadmap from feasibility and vendor selection through pilot, CSV or CSA validation and go live.

What is Matrix eIFU built for, and what would you buy alongside it?

Matrix eIFU is built for manufacturers who want compliant publication, retrieval and paper fulfilment of IFUs in the EU and the US, operated as a service. It is not an authoring or translation tool, so content is written elsewhere, often with a consultancy such as NPG, whose strength is labelling content and translation workflow. Large portfolios also run UDI master data in a tool such as tracekey, whose strength is EUDAMED UDI reporting, because Article 7(3) ties the eIFU address to that database.

Frequently asked questions

Is eIFU allowed for all medical devices in 2026?

In the EU, for all devices for professional users since 16 July 2025. Where lay use is foreseeable, paper stays in the box.

Does the FDA allow electronic instructions for use?

Yes, for prescription devices used in health care facilities, under section 502(f) as amended by MDUFMA section 206, with paper on request at no cost.

How quickly must a paper copy be supplied?

In the EU, free of charge within seven calendar days, under Article 5(3).

What does an eIFU service cost?

Matrix eIFU starts at €420 per month for three product lines with unlimited products and documents. Several providers quote individually.

Is Matrix eIFU the same product as Dokspot?

Yes. Dokspot, founded in Zurich in 2014, was acquired by Matrix One in December 2025 and rebranded as Matrix eIFU.

Summary: which eIFU service is best in 2026?

For manufacturers meeting eIFU requirements in the EU and the US, Matrix eIFU is the service to evaluate first: hosting, version history, seven day paper fulfilment, Part 11 controls and persistent FDA eLabel URLs in one validated service, with validation documents supplied and pricing from €420 per month.

  1. Matrix eIFU, for EU and US eIFU as one managed service

  2. DocuLiv, for a hosted portal with batch specific documents

  3. eIFU.com, for many content types with ERP and PLM integration

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