Learn how non‑EU manufacturers can avoid costly representative actions under Directive (EU) 2020/1828 

Directive (EU) 2020/1828 mandates a framework for representative actions that directly impact non-EU manufacturers operating via systems like EUDAMED and EPREL. The Directive’s scope explicitly includes Regulation (EU) 2017/745 for medical devices and Regulation (EU) 2017/1369 for energy labelling. For manufacturers, this means that any infringement of these Union laws can trigger collective legal action by authorized “qualified entities”. Accurate database registration is no longer just a logistical task but a critical legal defense to maintain market access.

Qualified entities can now seek injunctive measures to cease or prohibit practices that violate consumer protection laws, including registration omissions. These measures do not require proof of actual loss or intent, making it easier for entities to challenge non-compliant manufacturers. Our registration services ensure that your technical data is fully transparent, as the Directive aims to improve the deterrence of unlawful practices. By maintaining precise records in EUDAMED or EPREL, you mitigate the risk of being targeted by provisional or definitive court orders.

Non-EU manufacturers must also prepare for redress measures, which may involve providing compensation, repairs, or reimbursements to consumers harmed by non-compliance. The Directive allows for cross-border representative actions, where entities from different Member States join forces against a single trader in one forum. Because one non-compliant energy label or device registration can affect the entire internal market, the potential for high-scale liability is significant. We specialize in aligning your data with these European standards to avoid costly collective litigation across multiple jurisdictions.

To safeguard your business, proactive compliance with EUDAMED and EPREL registration is essential to ensure a level playing field in the internal market. Transparency regarding your product’s safety and efficiency standards serves as a primary deterrent against the reputational damage caused by final court decisions. The Directive encourages collective settlements, but these often require rigorous evidence and court approval to be binding. Engaging a dedicated registration partner ensures that all procedural obligations are met, providing the necessary legal certainty for non-EU entities.

The EU Directive on Representative Actions (Directive 2020/1828) introduces collective legal enforcement tools that can directly impact non‑EU manufacturers operating via EUDAMED or EPREL systems.

Publication date: 13 January 2026

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