A UK MHRA Certificate of Free Sale (CFS) for ophthalmic tonometers supports overseas dossiers for registered intraocular-pressure measurement equipment. Its schedule identifies selected tonometer models alongside the manufacturer’s measurement specifications, component descriptions and conformity documentation.
The issued certificate can then be prepared for overseas use through verification, professional certification, an apostille and any required embassy legalisation.
Product category and MHRA registration: Ophthalmic Tonometers
Ophthalmic tonometers are general medical devices intended to measure intraocular pressure using the method specified by their manufacturer. Product designs can include contact and non-contact arrangements, with documented applanation, rebound or air-puff measurement configurations. The intended purpose defines users, patient population, examination environment and supported measurement functions. Each model retains its own method, operating requirements and component configuration.
The MHRA’s Device Online Registration System, or DORS, holds manufacturer, device and product records. Registration includes the relevant conformity information, such as CE or UKCA documentation, together with the details identifying the products. For manufacturers based outside the UK, a UK Responsible Person represents the manufacturer for the Great Britain registration process.
The MHRA’s medical device registration guidance explains the registration framework. The April 2026 reference guide describes how these records are entered and maintained in the online system.
For Great Britain, the manufacturer’s records sit within the UK medical device framework. A CFS order is submitted by an eligible UK-based manufacturer or UK Responsible Person, using registered products and the relevant CE or UKCA conformity evidence.
Documents and product information
The registration process brings together information about the manufacturer, the product and its conformity documentation. The main records include:
- Manufacturer details: the legal manufacturer’s name, registered address and contact information.
- UK Responsible Person documentation: representative details and the designation agreement, where applicable.
- Product details: tonometer name, model, catalogue reference, legal manufacturer, measurement principle, probe or measuring-head arrangement and relevant software version. Labels, instructions, conformity documents and technical-file records describe measurement performance, calibration or verification arrangements, applicable electrical safety and cleaning. Component documentation identifies patient-contact parts, supplied accessories and any single-use, reusable or sterile presentation where relevant.
- Registration identifiers: the GMDN code and term, with Basic UDI-DI and UDI-DI where applicable.
- Conformity documentation: the Declaration of Conformity and applicable conformity assessment certificates, including their references, validity and product schedules.
- Supporting product records: labels, instructions for use and the technical and performance documentation held by the manufacturer.
The online registration links the relevant conformity documents to the device record and identifies the individual products beneath it. The wider technical documentation supports the manufacturer’s compliance records; it is not a separate standard upload package for each CFS order.
From MHRA registration to an electronic CFS
- Accepted registration establishes the manufacturer, device and individual product records in DORS. Current conformity documents are linked to the relevant entries.
- The applicant selects the products marked CFS Ready and reviews the certificate and schedule preview. Model names and catalogue references come from the registered product data.
- After the order is submitted and paid for, the MHRA issues an electronically signed PDF. The complete certificate and every schedule page form the document set for subsequent verification and legalisation.
The MHRA CFS Reference Guide describes these stages. The published CFS service information gives an issuance aim of ten working days, with longer processing possible during busy periods.
Product coverage in the CFS schedule
A tonometer range may include tabletop, handheld or examination-system-mounted presentations with different operating methods and catalogue references. Registered descriptions connect each selected model to its conformity scope and CFS entry. Disposable probes, reusable measuring prisms and mounting accessories may have separate references and applicable records. A slit lamp supporting a mounted tonometer retains its own product identity unless represented through the relevant selected entries. The complete schedule and compatibility information distinguish the pressure-measurement equipment covered from other instruments used during the same ophthalmic examination.
Direct verification of the CFS with the MHRA
For an overseas submission, the authenticity of the issued certificate is an important part of document preparation. Ginkgo Advisory can arrange for a solicitor to seek direct confirmation of the CFS with the MHRA and review the certificate together with its schedule.
Solicitor certification and express UK FCDO apostille
Where the solicitor-certified route is accepted for the intended submission, Ginkgo Advisory can arrange solicitor certification followed by a UK FCDO paper apostille. The certification format is matched to the receiving authority’s requirements. MHRA’s published guidance describes a notarial route, and notarisation is arranged where that route is required.
Our express UK FCDO apostille service normally takes two working days once verification and the required certification are complete and the document is accepted for submission. The apostille stage has its own timetable, separate from MHRA certificate issuance, verification responses, any embassy processing and delivery. Further FCDO checks can affect completion.
Embassy legalisation for Egypt, the UAE, Kuwait and Qatar
Ginkgo Advisory can arrange embassy legalisation where required, bringing the verification, certification, apostille and relevant embassy submission into one coordinated service. The destination and intended use determine the required document format and any additional stages.
Preparing an issued MHRA CFS for overseas use
For a quotation, the starting documents are the MHRA-issued electronic PDF and all accompanying schedule pages. The issuance email, destination country, receiving authority’s instructions and required completion date help establish the appropriate preparation and delivery arrangements.
Contact Ginkgo Advisory with the issued CFS for a quotation covering direct MHRA verification, solicitor certification where accepted, express FCDO apostille and any required embassy legalisation.
Product questions
Does a tonometer certificate include all replacement probes and measuring prisms?
The manufacturer’s records identify compatible measurement components and their supplied presentations. The selected registered product descriptions and issued schedule establish which references are included. A component’s compatibility with the listed tonometer does not automatically place every replacement product within the same certificate scope.