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Eleven Situations Where Real World Data is Used in China, NMPA Guideline Explains


NMPA issued the “Guideline on Real World Data (RWD) Used in Medical Device Clinical Evaluation (Draft)” on December 13, 2019. Feedbacks need to be submitted by January 13, 2020.

Eight overseas manufacturers participated in the Hainan RWD program piloted since June 2019, including one represented by China Med Device, LLC, a regulatory and clinical affairs consulting firm with offices in Boston and Beijing. To determine if your devices & IVDs fall into the RWD catalog, please email us at

Full List of Applicable Scenarios

The document describes eleven situations that RWD can be used in China:

  1. in Clinical Evidence Report (CER) for comparison of same type products;
  2. To be used with existing clinical evidence to support product registration;
  3. The RWD generated from the permitted use of clinically-needed medical devices in China can be used as supplementary data to support product registration;
  4. Used as the external control for single group experiment;
  5. To provide clinical data for the establishment of single-arm objective performance criteria;
  6. To support modification of Scope of Application and Intended Use;
  7. To support modification of clinical claims in package insert
  8. To support post-market studies on products which are granted Conditional Approval;
  9. To be used for the evaluation on long-term safety and efficacy of high-risk implants or similar medical devices;
  10. To be used for clinical evaluation of medical device for treatments of rare disease throughout the full Life Cycle to expedite the product registration;
  11. Used as Post-Market Surveillance.

Another Clinical Pathway

Real World Data will become another clinical pathway for device approval in China. Overseas manufacturers can obtain approval for the RWD pilot program through Hainan provincial NMPA to start using devices in clinical settings prior to national NMPA approval. This is especially significant for manufacturers with high price tags, as RWD program participants can generate clinical data in the actual clinical environment with service fees whereas the traditional clinical trial needs to be complimentary.

Hainan is the first province to pilot Real World Data in China. It offers an additional clinical option to the currently available clinical pathways such as clinical evaluation report and overseas clinical data acceptance. As RWD can be used prior to national NMPA approval, it can significantly shorten the time to begin selling devices in China.

Certain protocols and guidelines need to be followed for the RWD to be admitted as part of the clinical evidence for submission.

For English version of the “Guideline on Real World Data Used in Medical Device Clinical Evaluation (Draft)”, please email We charge nominal fees for the translation.

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About ChinaMed Device, LLC 

ChinaMed Device, LLC ( provides regulatory and commercialization turnkey solutions for medical device, IVD, CDx and combination products in China. As a qualified NMPA (CFDA) legal agent with offices in Boston and Beijing, we can represent manufacturers for the complete product life cycle without their need to create a local entity in China. Our NMPA (CFDA) regulatory services include strategy, registration, local type testing, product technical requirement (PTR), clinical evaluation report (CER), clinical trial, GMP and post-market surveillance (AE, recall, inspection, etc.). Our commercialization services include market research, reimbursement, partnership strategy and distribution qualification.

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