Circular medtech: what's changing, and what does it mean for medical device design?

UK circular medtech is still early. Neither regulation nor procurement yet match the scale of the ambition for change, so single use often remains the norm in practice. 

However when it comes to setting out the vision, the Design for Life roadmap is the headline. It’s an extensive policy paper setting out a clear target and route to change, anchored by a single goal: “By 2045 the UK will have transitioned away from all avoidable single-use medtech products towards a functioning circular system, safely transforming the sector to deliver enhanced resilience, increased economic growth, better value for patients and the NHS, and minimised environmental impacts.”

Crucially, this is framed as more than an environmental project. Our reliance on single use and virgin materials is also a resilience risk — we currently have a heavy dependence on a permanent flow of predominantly imported products and materials, exposed to every global supply shock that comes along.

Mostly because neither regulation nor commercial incentives are yet properly aligned towards circularity. The pieces are moving, but they haven’t clicked into place. And even though there is a clear wish from government, clinicians and industry to move in the right direction, systemic change on this level will require extensive lead-in times to allow manufacturers to adjust in this highly regulated and slow moving industry.

However we have already seen some movement. The NHS Evergreen Sustainable Supplier Assessment already requires companies bidding on NHS Supply Chain tenders to register their sustainability maturity. But in practice, how much improved sustainability credentials actually shift the odds of winning a tender today is still murky and mixed. Cost is still king. For now.

The deeper problem is that NHS procurement is structurally short-termist. Budgets are set annually, and the cost of a reusable product is routinely compared head-to-head against a single-use one — even when the reusable option is dramatically cheaper per use over its life. So it’s not as simple as implementing new design standards and finding more money. 

Then there are other practical barriers for manufacturers, too:

Materials are limited. The regulatory burden on medical-grade materials means more sustainable alternatives are hard to come by.

Liability is unresolved. Manufacturers have legitimate concerns about where responsibility sits if a device is improperly reused or remanufactured.

The infrastructure isn’t there. We lack the waste streams to reliably capture devices, divert them to the right processing facilities, and return them to use. And as preventative and home-based care picks up pace, this challenge moves out of the hospital and into people’s homes — making it harder, not easier.

None of these are reasons to do nothing. But they are all significant challenges which require dedicated and focussed resources to solve.

Three major factors are driving change: the Design for Life roadmap, proposed changes to Article 17 of the EU MDR, and the move to value-based procurement. Each one changes what “good” looks like for a device.

The Design for Life roadmap will mature in stages. Most circular medtech systems haven’t yet fully matured anywhere in the world. We’re currently still in the roadmapping and communication phases. By 2027 – 2029 the intent is to have some support frameworks and KPIs in place. It’s not until 2029 – 2031 until the report anticipates circularity becoming embedded in the commercial ecosystem, and the alignment of the regulatory environment for circular medtech.

Proposed changes to article 17 of the EU MDR could flip the default.  Under the proposed changes, manufacturers would have to actively justify why a device needs to be single use. Today, single use is often the default and reuse is the thing you have to argue for. The proposed changes move the burden of proof the other way.

Value-based procurement changes the maths.  The NHS defines this as a shift in emphasis “from a reduction in product costs to working with industry to consider technologies that can influence a reduction in total costs within the patient pathway.” In other words, they intend to judge a product on the total value it delivers across the pathway, not just on its sticker price. This should, in theory, make reusable options more attractive in tenders. 

Commercial incentivisation is also highlighted as one of the six core problem statements in the Design for Life report. At the end of the day, procurement has to put their money where their mouth is to make the switch worth a manufacturer’s while. And remanufacture is increasingly being recognised as a commercial opportunity in its own right: selling remanufactured rather than new can cut costs and improve supply chain resilience — provided tenders stop specifying “new” as a requirement.

Build sustainability in as a win-win, not a trade-off. We find the interventions that stick are the ones that are win-wins for the environment and the bottom line. A few principles we keep coming back to:

Reduce material use. Make what’s there work harder — value engineer for efficiency, combine components, and question whether every part earns its place. Does that tube need to be that long?

Keep one eye on cost per use, not just unit cost. Nobody knows exactly how procurement plans are going to pan out in the long term. But where you can, target cost per use, not just the bill of materials. A device that costs a bit more to make but delivers ten safe uses stacks up very differently once value, not sticker price, is being judged.

Avoid multi-material components, material blends and permanent assembly methods like heat staking.  They’re the enemy of disassembly, repair and recovery.

Maximise reusable components and minimise disposable ones. Be deliberate about which parts genuinely have to be thrown away, and shrink that list.

Design for reuse and remanufacture from the start. Where the risk profile allows, borrow from the consumer “right to repair” playbook: avoid permanent bonding, favour standard fasteners over adhesives, make high-wear parts modular and accessible, and design so a device can be opened, cleaned and reassembled without specialist tooling. And even better – talk to the teams responsible for the remanufacture directly.

Choose lower-impact materials, and don’t ignore packaging. Primary packaging is hard to change, but there’s a lot to learn from consumer industry on secondary and non-safety-critical packaging — Google’s plastic-free design guidelines are a good reference point.

Invest in a Life Cycle Assessment. Whether to compare two concepts head-to-head, or to benchmark an existing product and quantify the improvements you’ve made, an LCA generates data you can actually put in front of a procurement team. As product-level carbon footprinting requirements move closer, that evidence will come in handy more and more often.

Of the six Design for Life problem statements, we actively work on two. Behaviour change — pushing our clients to think differently and actively hunting for the option that’s better for sustainability rather than defaulting to what’s familiar. And transformative innovation — working directly with founders and startups on products and services that improve sustainability while making hard commercial sense, and constantly chasing better materials.

In practice, that comes down to a few things:

We lean on creativity to find sharper solutions. A more effective, more efficient answer to the underlying problem often saves the NHS money and cuts the environmental footprint at the same time.

We try not to take single use as a given.  We ask which parts can be reused and how small the disposable element can be. Our work on the FXI respirator mask and the Releaf portable urinal — both award-winning — came directly out of questioning that default.

We educate clients on sustainable practice when it’s useful to them.

We’re always on the hunt for better materials. Meaning we’re actively engaging with suppliers to find more sustainable alternatives. If that’s you, get in touch.

Teams that treat circularity as a compliance problem to be deferred will spend the next few years reacting to it. Teams that build it into their thinking now will be better placed as the system shifts. And the whole sector is hunting for proof that this works — for case studies it can point to and shout about. Right now there’s an open opportunity to be one of them.