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A UDI-DI is to be assigned to a specific model of device and manufacturer. Contact lenses are available in many variants due to the high number of clinical parameters that characterise them. In accordance with Regulation (EU) 2017/745, an UDI-DI is to be assigned to each of such variants of contact lenses. This individualisation at UDI-DI level, that results in a proliferation of UDI-DIs to be assigned to similar contact lenses, overwhelms Eudamed and is disproportionate compared to the safety risk associated with contact lenses.
Taking into account progress at international level and collaboration with issuing entities, concerned industry stakeholders and Union competent authorities for medical devices, the technical development in this field is such that contact lenses that have the same clinical and design parameter combinations are more appropriately grouped under the same UDI-DI (Master UDI-DI). In order to avoid assignment of different device identifiers to very similar contact lenses, a solution is therefore needed for UDI-DI assignment to contact lenses.