Changeflow GovPing Healthcare EU Design Act strengthens medical device design...
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EU Design Act strengthens medical device design protection

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Summary

Hogan Lovells analyzes the EU Design Act (effective May 1, 2025 with further reforms July 1, 2026) and its implications for medical device manufacturers. The reform extends design protection to digital and dynamic elements, strengthens enforcement against unauthorized digital replication and 3D printing, and addresses the repair clause for spare parts.

What changed

The EU Design Act introduces new design protection opportunities for medical devices. Key developments include: protection of digital and dynamic designs such as GUIs, animations, and screen-based visuals for connected medical devices and digital health platforms; strengthened enforcement against unauthorized reproduction including CAD models and 3D-printed copies of customized components, implants, and surgical guides; and the repair clause limiting protection for spare parts used to restore complex products.

Medical device manufacturers can now protect software interfaces and user experience elements previously unprotected. The 3D printing provisions enable manufacturers to maintain control over digital design files and decentralized manufacturing. However, the repair clause may allow third-party production of compatible modular device components, subject to intersecting medical regulations and liability requirements.

What to do next

  1. Monitor EU Design Act implementation timelines
  2. Review medical device design portfolios for expanded protection opportunities

Source document (simplified)

April 7, 2026

EU Design Act: Designing the future - why the EU Design Act matters for medical devices

Alessandra Pannozzo Hogan Lovells + Follow Contact LinkedIn Facebook X Send Embed

The EU Design Act (effective 1 May 2025 with further reforms effective 1 July 2026) has been introduced to strengthen, simplify, and modernize the EU design system and align it with EU trademark rules. This new reform will offer design protection that is fit for the era of digital designs and evolving technologies.

But what changes does the reform bring to your business? We address this question in a series of sector-specific articles featured in our "Designing the Future" series. The series started with the video games sector followed by fashion and furniture and automotive and mobility. In this article, we examine the implications of the reform for medical devices.

The changes in EU design law go far beyond administrative tweaks – the reform clearly opens the door to protect the very features that shape user experience and define new generation, software-driven medical devices, offering stronger tools against unauthorized imitations and 3D-printed copies of regulated products.

For the medical industry, the real breakthrough lies in the following developments: the protection of digital & dynamic designs, the protection against replication & 3D printing, and the repair clause allowing the production of “must match” spare parts.

The EU Design Act introduces new opportunities for design protection:

  • Digital & Dynamic Designs The EU Design Act extends design protection to digital and dynamic elements, including GUIs, animations and screen-based visuals.

The protection applies to the visual appearance of medical software interfaces, dashboards and interactive displays, even without a physical embodiment. This is particularly relevant for connected medical devices, digital health platforms and human-machine interfaces, where user experience becomes a key competitive asset.

  • Protection Against Replication & 3D Printing The new framework strengthens enforcement against unauthorized reproduction, including the use and distribution of digital design files (e.g. CAD models).

This has a key impact on customized components, implants, surgical guides and device accessories. It enables manufacturers to maintain control over digital replication and decentralized manufacturing, including hospital-based or third-party 3D printing.

  • Repair Clause & Spare Parts The repair clause limits design protection for component parts of complex products when used solely to restore the original appearance of the product.

This may allow third parties to produce compatible components for certain modular medical devices. However, in the medical sector this interacts with specific medical regulations and liability rules, meaning practical applicability remains highly regulated.

MedTech industry can now protect far more than static product appearances. With a well-structured design portfolio, competitors can no longer easily replicate the visual and interactive features of innovative medical interfaces and systems. This significantly strengthens the ability to act against unauthorized imitations and unregulated copies of medical products.

The technical standards for representing dynamic and animated designs will be finalized by 1 July 2026.

Article 26 of the EU Design Directive already allows design representations in static, dynamic , or animated formats, using commonly available technologies (drawings, images, videos, computer-generated models). In the medical device sector, this enables the protection of software interfaces, dynamic dashboards, and interactive system behaviours, with interactive 3D models or simulations emerging as key tools for design registration.

The reform provides an opportunity to refine your design protection strategy and fully utilize the new options to legally secure the features that shape user experience and brand identity and shield them from unauthorized use and copycats.

We recommend that you

  • Educate teams: Brief creative and product development teams on the new scope of design protection in the EU.
  • Audit assets: Identify key interfaces, dashboards, interactive visualizations, animations, and 3D simulations that may be eligible for design protection (keeping in mind the novelty requirement).
  • Strategize: Develop filing strategies for protecting your key assets.
  • Monitor developments: Track the July 2026 technical rules and further category expansions.
  • File early: Begin submitting design applications for key visual features that define your medical devices.
  • Signal protected design status: Consider using the new registration symbol Ⓓ to raise awareness and deter infringers. [View source.]

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Hogan Lovells
Published
April 7th, 2026
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Medical device makers
Industry sector
3345 Medical Device Manufacturing
Activity scope
Medical device design IP portfolio management 3D printing of medical components
Geographic scope
European Union EU

Taxonomy

Primary area
Intellectual Property
Operational domain
Legal
Topics
Medical Devices Product Safety

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