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Q&A – Product Registration Questions for Medical Devices, IVD, and CDx

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Frequently Asked Product Registration Questions (FAQ) all about Registration, Renewal, Modification and Innovation Approval:

What are the qualifications for Innovation Approval?

NMPA (CFDA) published “Special Review and Approval Procedure for Innovative Medical Devices” on November 5, 2018. The guideline has been implemented on December 1, 2018. Qualifications for Innovation Approval:
1. Class II / Class III Medical Device with significant clinical application value,
2. Own valid invention patents,
3. Have China PTO coverage,
4. Complete the preliminary study on a prototype with traceable data and an authorized in-country legal entity.

Can renewal be processed if registration certificate is lost?

No. Registration certificate is a necessary file in renewals. The original certificate must be submitted to NMPA once the renewal is approved. Applicants must request reissue if the certificate is lost.

Is change of interior packing allowed in registration renewal?

No. Renewal means no changes to the registered products. Unless mandatory standards are changed, any changes are not allowed in renewal.

What are the steps in the renewal process?

Here are the key steps: (1) prepare renewal dossier (2) Type testing (3) submission and NMPA review (4) NMPA issue supplement notice (5) submit supplement documents (6) final review (7) approval

china product registration questions china medical device

What information is required for renewal application?

Mandatory documents from the manufacturer for no-change renewal:
(1) Copy of original CFDA (NMPA) certificate with annex if there is any, original product standard (with CFDA stamp) (2) Type testing report

Does type testing in China need to be repeated in renewal process?

Type testing is required for renewal when the Chinese standards mandatory for the product has changed/updated since the initial registration.

What types of changes does the NMPA allow to be included in a modification registration?

There are two types of modification registration with NMPA in China: 1. First-level modification (do not need reviewer review or approval)
Registrant name change
Registrant address change
Manufacturing site address change for domestic medical device
Legal agent change
Legal agent address change
2. Second-level modification (need reviewer review and approval)
Product name change
Product technical requirements change
Model/specification change
Components and structure change
Intended use/indication change
Manufacturing site address change for imported medical device
Other changes that may lead to a change of license contents
Other changes

Where can the guidance documents be found?

China Med Device keeps closely in touch with NMPA, CMDE, and other relevant authorities, and will frequently release the updated news, regulations, standards, guidelines, etc. on our website. You can opt-in to our blog and monthly NMPA News Roundup to keep updated Different devices correspond to different standards and guidelines. We can also assess your device, and provide the relevant regulations, standards, and guidelines to help you enter China. China Med Device has just one focus: helping medical device companies succeed in China. We partner with clients at all stages of the product lifecycle to craft optimal regulatory, quality, and clinical solutions for their products. Please contact us if we can ever provide assistance in these or other areas. In addition, we also routinely translate NMPA regulations, standards, and guidelines. Please let us know which guidance documents you are interested in. We can provide translated English versions with a fee.