To register a Class III medical device under the Medical Device Administrative Control System (MDACS) in Hong Kong, you must comply with the requirements set by the Medical Device Division (MDD). Below are the key requirements:
The product must be a Class III medical device, which typically includes:
Life-supporting or sustaining devices,
Devices implanted in the human body,
Devices with significant risk if they fail.
MDACS classification follows GHTF guidelines.
The manufacturer must appoint an LRP based in Hong Kong.
The LRP must:
Be a legal entity registered in Hong Kong,
Hold a Business Registration Certificate,
Be responsible for submission, communication, and post-market actions.
Complete and sign Form MDRR-1:
Download from MDD Website
Provide evidence of approval from at least one reference regulatory authority, such as:
EU (CE under MDR/IVDR),
USA (FDA 510(k) or PMA),
Canada (Health Canada),
Australia (TGA),
Japan (PMDA/MHLW).
Include the following:
Device description
Intended use and indications
Risk classification justification
Labeling and Instructions for Use (IFU)
Design and manufacturing information
Clinical evidence (if applicable)
Summary of safety and performance
Submit a valid ISO 13485 certificate issued by a recognized certification body.
Issued by the competent authority of the reference country,
Confirms the device is legally sold or distributed in that country.
A documented plan covering:
Adverse event reporting,
Complaint handling,
Corrective and preventive actions (CAPA),
Product recall procedures.
Clear photos or renderings of:
The device itself,
Outer and inner packaging,
Labeling.
Test reports or declarations of conformity,
Clinical evaluation reports (CERs),
Certificates from notified bodies or third-party testing labs.
| Document/Requirement | Mandatory for Class III |
|---|---|
| LRP Appointment | ✅ Yes |
| Application Form (MDRR-1) | ✅ Yes |
| Reference Regulatory Approval | ✅ Yes |
| ISO 13485 Certificate | ✅ Yes |
| Free Sale Certificate | ✅ Yes |
| Essential Technical Documentation | ✅ Yes |
| IFU and Labels | ✅ Yes |
| PMS Plan | ✅ Yes |
| Device Images & Packaging | ✅ Yes |

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