After obtaining approval (i.e., the Medical Device Listing Number) for a Class B medical device with the Vietnam Ministry of Health (MOH), there are several important post-approval responsibilities and precautions to ensure ongoing compliance.
Class B devices are exempt from expiration under Decree 98/2021/ND-CP.
However, the listing number remains valid only if product details remain unchanged.
Re-notification is required if:
Manufacturer changes
Product name/model changes
Labeling or intended use changes
Distributor/Authorized Representative (AR) changes
Product must be labeled in Vietnamese per MOH requirements.
Label must match exactly the information in the registered dossier (Listing Number, manufacturer, model, etc.).
Include:
Device name
Listing number (from MOH)
Manufacturer
AR in Vietnam with contact info
Production date, lot/batch number, expiration (if applicable)
When importing, the customs broker must present:
MOH Listing Number
Valid contract with AR
Vietnamese label and IFU
Manufacturer’s invoice
Customs may request additional documents or testing if there’s suspicion of product inconsistency.
Your Authorized Representative (AR) is responsible for:
| Task | Notes |
|---|---|
| Adverse event reporting | Report serious incidents to MOH within 10 days |
| Corrective action tracking | Must document and notify MOH if product recall or CAPA is required |
| Customer complaints | AR must record and resolve complaints |
| Annual reporting | Not mandatory for Class B, but recommended to maintain traceability |
Keep a full copy of the technical dossier, translated IFU, and legal certificates available in case of inspection.
AR and importer must maintain distribution records for traceability.
You may face fines, product seizure, or listing cancellation if:
Products differ from those registered
Vietnamese label or IFU are incorrect
You fail to report incidents or changes
You use misleading advertising or make unapproved claims
If any of the following change, notify the MOH and re-register or update the listing:
Manufacturer name/address
Brand or model name
Risk classification
Indications for use
| Task | Recommendation |
|---|---|
| Monitor regulatory updates | Decree 98/2021 is evolving — stay updated |
| Work closely with your AR | They're responsible for compliance on your behalf |
| Keep digital copies organized | Especially certificates, testing, labeling, and MOH responses |
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