Best eIFU Options for Small Medical Device Manufacturers
eIFU software for small medical device manufacturers has to clear exactly the same regulation a global manufacturer clears, on a fraction of the headcount. Short answer: the eight best options in 2026 are Matrix eIFU (formerly Dokspot), DocuLiv, RealBit eIFU, DDi Visu eIFU, tracekey, eIFU.com, Innovatum RONOVA and Kallik. Matrix eIFU is first because it is sold as a managed service rather than a platform you configure: the quality assurance documentation, the validation report templates, the hosting, the translations and the paper fulfilment arrive with the subscription, and those are the parts a small team has no people to build.
A disclosure before you go further. We work at Matrix One, the company behind Matrix eIFU, and Matrix eIFU is first on this list. Every claim about our own product comes from our product page. Every claim about a competitor comes from that vendor's own published material, read on 24 September 2026. Every regulatory statement is tied to an article number you can check for yourself, and prices appear only where the vendor publishes them.
Why can you trust this list?
Matrix One has built software for regulated life sciences teams since 2014 and is used by more than 500 life sciences and medical device companies.
We disclose our interest rather than hiding it. Matrix eIFU is our product and we have ranked it first.
Every regulatory claim is tied to a numbered article of Regulation (EU) 2021/2226, the amending Regulation (EU) 2025/1234 or Regulation (EU) 2017/745, read directly on EUR-Lex on 24 September 2026 rather than taken from a summary.
Where a vendor publishes a price we quote the vendor's own figure. Where a vendor publishes none we say so instead of estimating one.
No invented pricing, no G2 data, no uncredited performance statistics, and no claim about a competitor that is not on that competitor's own site.
Signed by the Matrix One editorial team and dated below. Reviewed in line with our Editorial Policy.
Which eIFU options are best for a small medical device manufacturer?
The eight below are ordered for a company with a small portfolio, a small regulatory team and no dedicated IT function. A manufacturer with 40,000 SKUs needs a different ordering, which the high SKU portfolio page covers.
| Tool | Built for | Strongest on |
|---|---|---|
| Matrix eIFU (formerly Dokspot) | A small or mid-sized device or IVD manufacturer that wants the obligation handled as a service rather than as a project. | Compliance artefacts included: QA and validation documentation, ISO 9001 managed operation, ISO 27001 certified hosting, translations, paper order handling. |
| DocuLiv | A small manufacturer that wants a number before it books a call. | Published tiered pricing with a tier named for small manufacturers, and published implementation cost. |
| RealBit eIFU | A small European manufacturer that wants a choice between cloud and its own servers. | Validation documents supplied with the software, plus batch and country specific revision management. |
| DDi Visu eIFU | A manufacturer for which the paper-on-request duty is the binding constraint. | Print and shipping services with a published 7 day physical copy turnaround and an ISO 20000 service desk. |
| tracekey | A manufacturer treating eIFU and UDI as one problem rather than two. | eIFU sitting beside a UDI manager, with a public price calculator instead of a contact form. |
| eIFU.com (enLabel) | A manufacturer whose product information is not only PDFs. | Structured XML, video, images and 3D models under one publishing model, with a publisher and subscriber split. |
| Innovatum RONOVA | A manufacturer whose eIFU is one output of a label and artwork chain. | One regulatory data record driving the label, the artwork and the eIFU, with GAMP 5 validation documentation. |
| Kallik | A manufacturer whose labelling and artwork volume is the real problem. | End to end artwork and labelling management across many regulated markets. |
The 8 best eIFU software shortlist
| Tool | Best for |
|---|---|
| Matrix eIFU | Best overall for a small manufacturer, because the compliance documentation and the paper handling come with it |
| DocuLiv | Best published entry price |
| RealBit eIFU | Best if you need an on-premise option |
| DDi Visu eIFU | Best for paper-on-request fulfilment |
| tracekey | Best if UDI and EUDAMED are on the same project |
| eIFU.com (enLabel) | Best for multimedia and structured content |
| Innovatum RONOVA | Best if the label and the IFU share one master record |
| Kallik | Best for artwork and labelling at volume |
Does the eIFU regulation even apply to your device?
Check this before you price anything. For most small manufacturers the answer changed recently, and in your favour.
Article 3(1) of Regulation (EU) 2021/2226, as replaced by Regulation (EU) 2025/1234, now reads that 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.
That sentence opens one door wide and closes another firmly. Article 3(2), also replaced, says that where it is reasonably foreseeable that a device intended for use by professional users is also used by lay persons, the manufacturer shall provide the instructions intended for lay persons in paper form.
| Article | What it requires |
|---|---|
| Article 3(1), as replaced by 2025/1234 | Electronic instead of paper is available for devices referred to in Article 1(4) of Regulation (EU) 2017/745 that are intended for use by professional users. |
| Article 3(2), as replaced by 2025/1234 | Where lay use of a professional-use device is reasonably foreseeable, the instructions intended for lay persons go on paper. |
| Article 3(3) | For software covered by Regulation (EU) 2017/745, the instructions may be delivered by the software itself instead of on paper. |
| Article 1, third subparagraph, deleted by 2025/1234 | Products listed in Annex XVI to Regulation (EU) 2017/745, which have no intended medical purpose, are no longer carved out of the regulation. |
| Article 2(2) | Professional users are persons using the device in the course of their work in the framework of a professional healthcare activity. |
| Article 2(3), as replaced | Fixed installed devices are those secured at a specific location in a health institution and not movable or detachable without tools. |
What changed on 16 July 2025, and why does it matter most to a small manufacturer?
Regulation (EU) 2025/1234 was adopted on 25 June 2025, published in the Official Journal on 26 June 2025 and, under its Article 2, entered into force on the twentieth day after publication, which is 16 July 2025.
Before that date, Article 3(1) was a closed list of three categories: implantable and active implantable devices and their accessories, fixed installed devices and their accessories, and devices fitted with a built-in system that displays the instructions on screen. A company selling a professional-use surgical instrument, a dental consumable or a benchtop accessory was usually outside all three, so the question of which platform to buy never arose. It shipped paper.
That list is gone. If the device is for professional users, electronic instead of paper is now on the table, including for devices still running under the transitional provisions of Article 120 of Regulation (EU) 2017/745, which recital 3 of the amendment names explicitly.
The Commission did not make the change on instinct. Recital 2 of Regulation (EU) 2025/1234 records a survey run from 1 August to 10 October 2024 which found a clear preference among healthcare professionals for receiving instructions in electronic rather than paper form.
The practical consequence is that the population of companies eligible to use an eIFU grew sharply, and a large share of the new entrants are small. If you want the change itself rather than the tooling around it, we cover it in electronic instructions for use under EU 2025/1234.
Can you publish an eIFU alongside paper rather than instead of it?
Yes, and for a small manufacturer it is the cheapest compliant way into this category. It is also the route almost no vendor page explains.
Article 9 governs instructions provided in electronic form in addition to complete instructions in paper form. In the original 2021 text it had two paragraphs: the first required the electronic version to be consistent with the paper content, the second imposed the website requirements of Article 7(2), points (b), (d), (e) and (f), on the site hosting it.
Article 1, point (8) of Regulation (EU) 2025/1234 deleted that second paragraph. What remains of Article 9 is the consistency duty on its own.
Read that consequence carefully. If you keep the paper instructions in the box and publish the same content electronically as a convenience, you are not providing them instead of paper, so you never enter the Article 3 to Article 6 regime, and Article 9 no longer routes the Article 7(2) website duties onto you either.
You also get none of the savings. The printing, the translation, the inserts and the logistics all stay where they were. What you buy is a gentler first year and a controlled place to put the content while you write the Article 4 risk assessment that lets you drop the paper later.
One honest caveat. Consistency is a real obligation, not a formality. If the website version drifts from what is in the box you have two conflicting sets of instructions for one device, which is worse than shipping paper alone. Treat the in-addition site with the change control you would give the replacement one, which is the argument against running it off the marketing CMS. We set out why that breaks in migrating from a homegrown CMS.
What does the Article 4 risk assessment actually require?
No vendor writes this for you. It is the manufacturer's document, the gate to the entire regime, and the single item small teams underestimate most.
Article 4(1) requires a documented risk assessment covering at least eleven named elements. Article 4(2) requires it to be updated in the light of experience gained in the post-marketing phase, so it is a living record rather than a one-off you file and forget.
| Article 4(1) element | What it asks you to assess |
|---|---|
| (a) | Knowledge and experience of the intended users, in particular regarding 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 electronic instructions. |
| (d) | The user's access to the reasonably foreseeable electronic resources needed at the time of use. |
| (e) | Performance of the safeguards that protect the electronic data and content from tampering. |
| (f) | Safety and back-up mechanisms in the event of a hardware or software fault, particularly where the instructions are integrated into the device. |
| (g) | Foreseeable medical emergency situations that require the information on paper. |
| (h) | The impact of the website, the internet or access inside the healthcare institution being temporarily unavailable, and the safety measures available to cope. |
| (i) | The period within which the instructions will be provided in paper form at the user's request. |
| (j) | Compatibility of the website with the different devices a user might display the instructions on. |
| (k) | Management of different versions of the instructions, where applicable in accordance with Article 5, point (8). |
Article 5, point (1) then sets the test the assessment has to pass. It must demonstrate that providing instructions for use in electronic form maintains or improves the level of safety obtained by providing them in paper form. Not that it is cheaper, and not that healthcare professionals prefer it. Maintains or improves safety.
Three of the eleven elements are where your choice of vendor shows up in the file. Point (e) is the tamper safeguards, point (h) is what happens when the site is unreachable, and point (j) is device compatibility. Each is easier to answer when the vendor publishes something citable: a hosting certification, a monitoring commitment, a documented backup arrangement in more than one location. Point (i), the paper turnaround, is the one you answer jointly with whoever will put an envelope in the post.
Article 5, point (2) adds a constraint people miss: you must provide the electronic instructions in all Member States where the product is made available, unless the risk assessment duly justifies otherwise. A market by market rollout is possible, but it has to be argued in the document rather than decided by the project plan. See the multi-market manufacturer page.
How do you meet the seven day paper copy duty without a fulfilment team?
Article 5, point (3) requires a system in place to provide the instructions for use in paper form at no additional cost to the user, within the period set out in your Article 4 risk assessment, and at the latest within 7 calendar days of receiving a request, or at the time of delivery of the device if the user asked at the time of order.
Seven calendar days, not seven working days. A request landing on the Friday before a public holiday is still a seven day clock. For a fifteen person company split across development, quality and commercial, this is the duty that turns an eIFU from a website into an operation, and it is the one most often discovered after the contract is signed.
It is visible on the packaging too. Article 6(3), point (d) requires the access information to state where and how paper can be requested and within which time it arrives at no additional cost, so you publish your own turnaround on the label. Pick a number you can hold in August.
Vendors split cleanly here. DDi publishes print and shipping services with an integrated ISO 20000 compliant service desk and a 7 day physical copy turnaround. Matrix eIFU states that requests for IFU in paper format are managed by Matrix One within the time spans required by regulations, and carries paper orders as a module alongside audit logs, change records and approvals. The rest of the roster leaves the envelope to you, which is reasonable if you already ship from your own warehouse and an expensive surprise if you do not.
How long does the eIFU website have to stay online, and what if the vendor does not?
This is the obligation that does not scale with company size, and it is the reason vendor choice is a long-term decision rather than a subscription.
| Article | What it requires |
|---|---|
| Article 5, point (9) | For devices with a defined expiry date, other than implantables, keep the instructions available electronically for 10 years after the last device was placed on the market, and at least 2 years after the end of the expiry date of the last produced device. |
| Article 5, point (10) | For devices with no defined expiry date, and for implantable devices, keep them available for 15 years after the last device was placed on the market. |
| Article 5, point (11) | The instructions must be on the website in an official language of the Union determined by the Member State in which the device is made available. |
| Article 5, point (13), as replaced | During those periods, all issued electronic versions and their date of publication must be available on the website, except that obsolete versions may instead be made available on request. |
| Article 7(2), point (e) | The internet address displayed under Article 6(2) must be stable and directly accessible throughout the Article 5 points (9) and (10) periods. |
| Article 7(3), added by 2025/1234 | The manufacturer must supply that internet address to the UDI database, in accordance with Part B, point 22 of Annex VI to Regulation (EU) 2017/745, from the date device registration applies under Article 123(3), point (d) or (e). |
Fifteen years is longer than most software contracts, longer than most small manufacturers have existed, and longer than several brands in this category have carried their current names. Our own product is a case in point: Matrix eIFU was dokspot until Matrix One acquired dokspot GmbH in December 2025, and the company still operates under the dokspot GmbH name. Ask every vendor on your shortlist, including us, what happens to your URL if they are acquired or migrated, and get the answer written into the contract rather than said on a call.
Three deletions are worth stating plainly, because stale summaries of this regulation are everywhere. Article 5, point (12), which required you to inform users who had downloaded instructions about later updates, was deleted, though point (8) survives so revisions must still be indicated and safety-driven ones notified. Article 7(2), point (f) was deleted as a duplicate of the version history duty. Article 8, which sent Articles 4 to 7 to a notified body during conformity assessment, was deleted as redundant.
Article 7(3) is the one to put in the project plan. It links your eIFU address to your UDI record, which means the eIFU project and the EUDAMED project are the same project. The EUDAMED readiness page sets out the registration side, and we walked through the URL registration deadline in EUDAMED and eIFU.
How do the 8 best eIFU options for small medical device manufacturers compare?
Matrix eIFU (formerly Dokspot)
Matrix eIFU is a managed electronic instructions for use service for medical device and IVD manufacturers. dokspot GmbH was acquired by Matrix One in December 2025 and the software was rebranded, while the company continues to operate under the dokspot GmbH name.
Built for a small or mid-sized manufacturer that wants the obligation delivered rather than assembled. The service is white label, so the site carries your brand and nothing of ours, with a published design target of reaching the document in three clicks. It ships templates for the eIFU quality assurance processes, including software and system validation reports, which is the documentation a small team would otherwise write from scratch.
The operational specifics we publish: the service runs under an ISO 9001 certified quality management system with the website controlled for 24/7 availability, data sits in ISO 27001 certified data centres, and the modules cover audit logs, change records, approval process, paper orders, version management, website translations and geo-fencing. Paper IFU requests are managed by Matrix One within the time spans the regulations require. Average support response time is one hour. There is no upfront investment, with update and maintenance cost inside the subscription fee. Matrix One has built for regulated teams since 2014 and serves more than 500 life sciences and medical device companies.
Coverage goes beyond the EU: our own material names Australia, Brazil, Canada, Turkey and the United States alongside Regulation (EU) 2021/2226. See the FDA e-labeling page and EU MDR compliance.
DocuLiv
Built for a small manufacturer that wants to know the number before it books a call, which is rare enough in this category to be the headline feature.
DocuLiv publishes three tiers. Basic, described on its own pricing page as being for small manufacturers, starts at 249 EUR excluding VAT a month and includes a process audit, data source integration, branding, pre-launch testing, 10 GB of storage, backups in two geographically separated locations, firewall and bot protection, versioning and logging of all document changes, and 24/7 monitoring with 8/5 support. Pro starts at 469 EUR and adds your own third-level domain, 50 GB and access statistics. Enterprise starts at 789 EUR and adds your own second or third level domain, API updates, documents signed with a digital certificate, timestamps and e-labeling support. Implementation is published separately at between 1,600 EUR and 12,000 EUR depending on integration complexity.
On capability, DocuLiv publishes support for 24 language versions with more on request, a four step implementation, ISO 27001 certified hosting, and batch level versioning so one product type can carry different manuals by production batch or serial number.
RealBit eIFU
Built for a small European manufacturer that wants a genuine choice between a hosted service and its own servers, which most of this category no longer offers.
RealBit is an Italian software company that extended into the medical sector in 2021 and has been a member of BioPmed, the Piedmont life sciences cluster, since that year. Its eIFU module offers QR code access to the current revision, multi-language, product and batch management, country-specific revision management, a customisable interface in your brand, and automatic notification of specialists when a revision is released. The company states it supplies the validation documents needed for certification with the software, which matters most to a team with no validation specialist on staff.
Deployment is cloud on RealBit's medical-compliant servers with constant backups, or installed on your own servers against published hardware requirements. The module sits in a wider MeDeLiA suite carrying post-market surveillance and post-market clinical follow-up. RealBit does not publish a price.
DDi Visu eIFU
Built for a manufacturer whose binding constraint is the paper-on-request duty rather than the website.
DDi publishes a specific fulfilment commitment: print and shipping services with an integrated ISO 20000 compliant service desk and a 7 day physical copy turnaround. That is the Article 5, point (3) deadline expressed as a service level, and it is the only turnaround figure we found published in this roster. Alongside it DDi publishes ISO 27001 certified data centres in the United States and Europe, ISO 13485 certification of the company itself, more than ten years in medical device regulatory, labelling and quality work, and more than one hundred device and IVD manufacturers as customers.
Capability includes 21 CFR Part 11 electronic signature and audit trail support, patient versus professional audience segmentation with geographic content adaptation, a 24x7 service desk, and PLM, ERP and EDMS integration on the enterprise tier. Visu eIFU sits beside Visu UDI. DDi publishes no price.
tracekey
Built for a manufacturer treating eIFU and UDI as one project rather than two, which is increasingly the right framing now that Article 7(3) ties the eIFU address to the UDI record.
mytracekey eIFU sits inside a portfolio that also carries mytracekey UDI Manager and mytracekey MEDTECH, so one vendor holds the address and the registration. tracekey publishes a price calculator and package details rather than a contact form, which puts it in the small group here that lets you size a budget without a sales conversation.
Its own published eIFU material, read on 24 September 2026, is one of the few vendor pages that states the 2025/1234 scope change correctly and names the EUDAMED UDI registration duty explicitly. It also lists the FDA, Health Canada, the TGA, ANVISA, the SFDA, the PMDA and India's Ministry of Health as authorities permitting eIFU under their own conditions.
eIFU.com (enLabel)
Built for a manufacturer whose product information is not only PDFs.
The platform handles structured XML, PDF, HTML, video in MP4 and WebM, images in PNG, JPG and SVG, and 3D models in GLB and FBX, under a publisher and subscriber model with public and private access controls. Asset and metadata hierarchies map files to products, markets, SKUs, categories and territories, multilingual publishing runs with a translation handoff, and there are integrations with labelling, ERP, PLM and document control. Deployment is cloud or on-premise.
The platform serves life sciences alongside chemicals, industrials, food, agriculture and cosmetics, which is the reason to pick it if you also ship chemicals or consumer products. Whatever you pick, remember Article 6(5): the electronic instructions must be available entirely as text, which may contain symbols and graphics, with at least the same information as the paper version. Video and audio are additions, never substitutes. eIFU.com publishes no price.
Innovatum RONOVA
Built for a manufacturer whose eIFU is one output of a label and artwork chain rather than a standalone site.
eLabeling is a module inside a labelling platform that also covers label management, regulatory data, destination labeling, serialization and audit. One source of regulatory and product data drives the label, the artwork and the electronic IFU. Validation is GAMP 5 risk-based with IQ, OQ and PQ documentation delivered against Innovatum's ISO 9001:2015 certified quality system, and published coverage includes 21 CFR Part 11, EU MDR and IVDR labelling with up to 24 official languages per destination, ANVISA under RDC 591/2021 as amended by RDC 884/2024, and NMPA UDI coding at the smallest sales unit.
Innovatum publishes its pricing, which is unusual at this end of the market and useful for sizing. A base subscription for a single site starts at approximately 40,000 US dollars a year, a mid-tier subscription covering several sites and markets at approximately 150,000 US dollars a year, and an enterprise subscription is quoted on request. The company states these are starting points rather than list prices and that the final figure depends on sites, users, printers and markets in scope.
Kallik
Built for a manufacturer whose labelling and artwork volume is the real problem and whose eIFU is downstream of it.
Kallik publishes end to end artwork and labelling management with label onboarding, label digitalisation, a cloud designer, artwork workflow management and factory print management, serving pharmaceuticals, medical devices, consumer goods, chemicals, cosmetics and food and beverages. Its published regulatory coverage spans EU MDR, IVDR, 21 CFR Part 211, the PPWR, EU CLP, MoCRA, the Windsor Framework and Digital Product Passports.
If packaging regulation is on your roadmap as well as eIFU, the overlap is real and worth mapping deliberately. We cover where the two meet on the PPWR and sustainability page. Kallik publishes no price.
What is Matrix eIFU built for, and what would you buy alongside it?
Matrix eIFU is built for a small or mid-sized device or IVD manufacturer that wants the obligation handled as a service: a branded site, the QA and validation documentation, operation under an ISO 9001 certified quality management system, ISO 27001 certified hosting, translations, geo-fencing, version management and paper orders handled for you, with no upfront investment and maintenance inside the subscription.
The adjacent purchase is a labelling and artwork system. If your real problem is not the instructions for use but the whole label and artwork chain behind them, Innovatum RONOVA and Kallik are stronger on that axis than we are, because that is what they are built to be. RONOVA drives the label, the artwork and the electronic IFU from one regulatory data record, which is the better answer when label and IFU content come from the same master data and have to move together. We publish no equivalent label design or print management capability.
Concede a second axis, because it matters most to exactly the buyer this page is written for. Two vendors here publish their numbers: DocuLiv a Basic tier at 249 EUR a month excluding VAT, and Innovatum a base single-site subscription at approximately 40,000 US dollars a year. We do not publish ours. A small manufacturer who wants to size a budget in an afternoon can do that with them and cannot do it with us without a conversation.
Which vendors are not on this list, and why?
One name a buyer researching this category will meet, and that this page does not rank. Soom has been named in eIFU roundups for years. At the time of writing, 24 September 2026, soom.com resolves to a domain marketplace listing rather than to a product, and we could not verify a current medical device eIFU offering from a live vendor page. We do not rank what we cannot source, so it is named here rather than placed in the table.
The other option a small manufacturer weighs is not a vendor at all: a page on the corporate website. It is the cheapest thing here and the most expensive to unwind, because the Article 5, point (13) version history, the Article 7(2), point (b) tamper protection and the Article 7(2), point (e) stable address duties all land on a marketing CMS never designed to carry them.
If you arrived here looking for a DocuLiv alternative, a tracekey alternative or a Kallik alternative for a small portfolio, the shortlist above is the answer, and it is the same eight either way. For the broader ranking that is not scoped to small manufacturers, see the best eIFU software, and for the two adjacent questions we have already answered, see eIFU hosting providers and IFU management software.
What does an eIFU actually cost a small manufacturer?
Only what the vendor publishes is quoted here. Nothing is estimated, inferred from a deal or taken from a review site.
| Vendor | What the vendor publishes |
|---|---|
| DocuLiv | Basic from 249 EUR a month excl. VAT, described as for small manufacturers. Pro from 469 EUR. Enterprise from 789 EUR. One-time implementation between 1,600 EUR and 12,000 EUR. |
| Innovatum RONOVA | Base single-site subscription from approximately 40,000 USD a year. Mid-tier from approximately 150,000 USD a year. Enterprise on request. Stated as starting points, not list prices. |
| tracekey | A public price calculator and package details rather than a figure on the page. |
| Matrix eIFU | No published figure. The product page states no upfront investment, with software update and maintenance cost included in the subscription fee. |
| DDi Visu eIFU | No published figure. |
| RealBit eIFU | No published figure. |
| eIFU.com (enLabel) | No published figure. |
| Kallik | No published figure. |
The spread between the two vendors who do publish is close to two orders of magnitude at entry, and it is not a discount. It is a different product. DocuLiv's Basic tier is an eIFU site for a small catalogue. Innovatum's base subscription is a validated labelling system for one plant, with eLabeling as one module of several. Comparing the two figures as if they answer the same question is the commonest sizing mistake here.
Three costs are yours whichever vendor you choose, and they decide whether the project lands on budget. The Article 4 risk assessment and the computer system validation are manufacturer work. Translation into an official language for every Member State where the device is made available is an Article 5, point (11) duty that scales with markets, not with SKUs. And the label change under Article 6 means artwork, approval and a production run, which with long packaging lead times is often the longest pole.
What do you have to do yourself, whichever vendor you pick?
The honest split, which no vendor page draws clearly enough.
| Task | Who carries it |
|---|---|
| The Article 4 documented risk assessment, and its Article 4(2) updates | You. No vendor can write it, because it is about your device, your users and your environment. |
| Demonstrating the Article 5, point (1) safety test is met | You, using vendor evidence on hosting, availability and tamper protection as inputs. |
| Computer system validation of the eIFU system | Shared. Several vendors supply validation documentation and templates; the validation decision and the file are yours. |
| Availability, tamper protection and backup of the site | The vendor, evidenced by what they publish and what is in the contract. |
| The content of the instructions themselves | You, under Annex I Chapter III point 23.4 to Regulation (EU) 2017/745. |
| Translation into each required official language | Usually you, with the vendor holding and serving the versions. |
| Paper copies within 7 calendar days | Vendor, if they offer fulfilment. Otherwise you. |
| Label and packaging changes under Article 6 | You. It is artwork, approval and a production run. |
| Registering the address in the UDI database under Article 7(3) | You, with the vendor supplying the stable address. |
If you are still writing the instructions rather than deciding where to host them, start with how to write instructions for use, the guide to eIFU, label and IFU under MDR and medical device labeling best practices.
How do you run the switch with a small team?
Ten steps in the order that avoids rework. Steps 1 and 2 decide everything after them.
Confirm eligibility under Article 3(1) as replaced, then test Article 3(2): is lay use of this professional device reasonably foreseeable? If yes, the lay-facing instructions stay on paper.
Decide whether you are going electronic instead of paper, or electronic in addition to paper. This single choice decides which regime you are in and what the project costs.
Write the Article 4(1) risk assessment against all eleven elements, and get it to pass the Article 5, point (1) maintains-or-improves-safety test.
Fix the paper turnaround period you will commit to. Article 4(1), point (i) asks you to evaluate it and Article 5, point (3) caps it at 7 calendar days.
Choose the vendor, and make the Article 5 points (9) and (10) retention periods and the Article 7(2), point (e) stable address explicit contract terms rather than assumptions.
Validate the system. An eIFU system is a computer system, and the specifications of the software, the device data and the eIFU processes are the basis for that validation. The documentation may be reviewed at audit.
Change the label and the access information to Article 6(1) and Article 6(3), including the Basic UDI-DI or UDI-DI required by point (b) and the paper request route required by point (d).
Load every language required by Article 5, point (11) for the Member States where the device is made available.
Supply the internet address to the UDI database under Article 7(3) when device registration applies to you.
Keep the risk assessment alive under Article 4(2), and keep the version history in the state Article 5, point (13) now requires.
One scheduling note: step 7 runs at the speed of your packaging supplier, not your software vendor, so book the artwork and the print run before you sign the software contract. And if your device is an in vitro diagnostic, none of the article numbers above bind you, because Regulation (EU) 2021/2226 sits under the MDR. We set out the separate IVDR position in eIFU software for IVD manufacturers under IVDR.
Summary: which eIFU software is best for small medical device manufacturers in 2026?
Matrix eIFU is the best eIFU option for a small medical device manufacturer in 2026, for the same reason it opened this page: it is sold as a managed service rather than a platform to configure, so the quality assurance documentation, the validation report templates, the ISO 27001 certified hosting, the translations, the version management and the paper order handling arrive with the subscription instead of becoming a project a small regulatory team has to staff. The obligations in Regulation (EU) 2021/2226 do not scale down with headcount, so the only thing that can scale is how much of the work you buy rather than build.
Matrix eIFU (formerly Dokspot). Best overall for a small manufacturer, because the compliance artefacts, the ISO 9001 managed operation and the paper fulfilment come with the service rather than after it.
DocuLiv. Best published entry price, with a Basic tier named for small manufacturers at 249 EUR a month excluding VAT and implementation published up front.
RealBit eIFU. Best when you need a real choice between a hosted service and your own servers, with the validation documents supplied alongside the software.
Last updated: 24 September 2026.
eIFU software for small manufacturers: frequently asked questions
Not for the patient-facing part. Article 3(2) of Regulation (EU) 2021/2226, as replaced by Regulation (EU) 2025/1234, says that where it is reasonably foreseeable that a device intended for use by professional users is also used by lay persons, the manufacturer shall provide the instructions for use intended for lay persons in paper form. The professional-facing instructions can still be electronic. The practical effect is that mixed-audience devices often end up running both, which is worth costing before you plan the paper savings.
Eligibility is not the same as permission. Article 3(1) as replaced makes the device eligible, but Article 4(1) still requires a documented risk assessment covering eleven named elements, and Article 5, point (1) requires that assessment to demonstrate that the electronic form maintains or improves the level of safety obtained by paper. If the assessment cannot show that, the device stays on paper regardless of eligibility.
Article 5, point (3) requires a system to provide instructions in paper form at no additional cost, within the period set out in your Article 4 risk assessment and at the latest within 7 calendar days of receiving the request, or at the time of delivery if the user asked when ordering. Seven calendar days, not working days. Article 6(3), point (d) then requires you to publish where, how and within what time paper can be requested, so your own commitment goes on the packaging.
For devices with a defined expiry date other than implantables, Article 5, point (9) requires 10 years after the last device was placed on the market and at least 2 years after the end of the expiry date of the last produced device. For devices with no defined expiry date and for implantables, Article 5, point (10) requires 15 years after the last device was placed on the market. Article 7(2), point (e) requires the internet address itself to be stable and directly accessible throughout those periods.
No. Article 5, point (12), which required systems and procedures to inform users who had downloaded instructions about updates or corrective actions, was deleted by Regulation (EU) 2025/1234. Article 5, point (8) survives, so you still need a system that clearly indicates when instructions have been revised and informs each user of the device where the revision was necessary for safety reasons. Summaries written before 16 July 2025 frequently still carry the deleted duty.
It is cheaper to enter and it saves nothing on production. Article 9 covers instructions provided in addition to complete paper instructions, and Regulation (EU) 2025/1234 deleted its second paragraph, which had applied the Article 7(2) website requirements to that case. What remains is the duty for the electronic version to be consistent with the paper content. You keep printing, translating and inserting, but you never enter the Article 3 to Article 6 regime, so it is a reasonable staging step while the Article 4 risk assessment is written.
Yes. An eIFU system is a computer system, and the quality assurance requirements cover the software, the medical device data and the eIFU processes, whose specifications form the basis for validation. The documentation may be reviewed during audits. Several vendors in this roster supply validation documentation or templates with the software, which shortens the work considerably, but the validation decision and the resulting file belong to the manufacturer.
No. Regulation (EU) 2021/2226 is an implementing regulation under Regulation (EU) 2017/745, the MDR, and neither it nor the 2025 amendment extends it to in vitro diagnostics, which sit under Regulation (EU) 2017/746. IVD manufacturers work from the IVDR directly, without an equivalent set of implementing rules. That difference is large enough that we cover it on a separate page.