Medical device destruction and equipment recycling

What is medical device destruction?

Medical device destruction is the safe and lawful removal, or recycling, of expired, quality-defective or recalled medical products, products with a broken cold chain, and of end-of-life or technologically obsolete medical equipment. These devices can contain hazardous chemicals, electronics, lead, mercury and patient data units, and improper disposal risks contaminating soil and water. We explain why recycling matters in our article on medical device recycling.

Uncontrolled disposal, however, brings two risks together. First, products or devices can leak into the market; medical product smuggling is a concrete example, and we discuss the link in a news item on an operation. Second, a device that leaves with patient data still on it creates a data protection risk under KVKK.

Which medical products and devices are destroyed?

The groups that fall within scope are:

• Expired products and products with a broken cold chain: medical products past their expiry date or with a broken cold chain.
• Quality-defective and recalled products: medical products with a detected quality problem or withdrawn from the market.
• Sterile supplies: products such as syringes, catheters and dressings that are past their expiry date or have damaged packaging.
• Specialty products: medical products in cardiology, orthopedics, nutrition, eye, ear and brain care.
• Imaging devices: MRI, CT and X-ray devices that have reached the end of their life or lost their technology edge.
• Laboratory and patient monitoring devices: laboratory test devices, patient monitors and ECG/EEG units.
• Life support and dialysis devices: ventilators, defibrillators, dialysis machines and infusion pumps.

Medical device destruction methods

The method depends on the product type and its recovery potential. First, we securely erase patient data; then we dismantle the device into its components at a licensed facility and either destroy or recycle it.

We decide which item goes which way at the inventory and risk analysis stage.

Legal basis of medical device destruction

Medical device destruction touches environmental, product and tax legislation together, so we build the process around all of them.

• Product: the Medical Device Regulation gives the manufacturer, importer and distributor separate duties, and it defines a field safety corrective action (FSCA) as a corrective action the manufacturer carries out. The regulation does not describe destruction step by step; only the authority may seize and destroy a counterfeit device or one that carries an unacceptable risk.
• Environment: the Waste Management Regulation requires waste to be collected separately, recorded and sent to a permitted or environmentally licensed facility. For devices with electronics and batteries, the WEEE Regulation and the Regulation on the Control of Waste Batteries and Accumulators apply as well. For this reason we destroy only at licensed facilities, and transport runs in sealed vehicles.
• Data: uncontrolled disposal creates a risk under KVKK.
• Tax: Article 278 of the Tax Procedure Law provides that the value of goods whose worth has fallen significantly is set by the Valuation Commission; Article 278/A opens a separate route for goods that must be destroyed for reasons such as expiry. Article 30/c of the VAT Law governs VAT on lost goods; for destroyed goods, the tax office and the Council of State hold different views, so decide with your accountant. Details: VAT on destroyed goods.

Destruction minutes and reporting

The destruction minutes are the official record of which product or device we destroyed, in what quantity, on what date and by which method. At Scrap, however, the minutes do not come alone; they are part of a document set:

• official destruction certificates,
• the Valuation Commission’s assessment and a copy of its decision,
• photo and video records of every batch,
• steps you follow throughout on the Online Tracking System,
• the Sustainable Transformation Report: recovery and carbon data that feed directly into your ESG reporting.

This set answers the question “was the product really destroyed?” with a single file, both in a tax audit and in brand compliance reviews. For expert reports, see our article on the expert report protocol.

Medical device destruction or recycling?

They are not alternatives but two outputs chosen by product type. We destroy expired and recalled medical products, and those with a broken cold chain, at a licensed facility. We dismantle end-of-life devices such as MRI, CT and X-ray equipment and route them to recycling. For components that hold patient data, we erase the data first and process the device afterwards.

After a field safety corrective action (FSCA), the product in the field needs a separate decision: repair, return or documented destruction. First, we match the affected model, serial and lot numbers against the manufacturer’s field safety notice; then we do not dispose of any device until the manufacturer’s return or destruction instruction arrives. On the brand side, read our article on protecting brand value.

How medical device destruction works with Scrap

The process starts with the request form; we first list the devices and run an inventory and risk analysis, then present a proposal. Next, we move the devices in sealed, ADR-certified vehicles, securely erase stored patient data, and dismantle each device into its components at a licensed facility before destroying or recycling it. Typical duration is about 21 business days. At the end you receive the official destruction certificates, photo and video records and the Sustainable Transformation Report; for every medical device destruction project a tree is planted and a child joins a nature education programme.