The process for Class A medical device registration under the Hong Kong MDACS (Medical Device Administrative Control System) is designed to ensure that low-risk medical devices meet the necessary safety and quality standards. Below is an outline of the steps involved in registering a Class A medical device under MDACS:
Class A devices are low-risk medical devices. Before starting the registration process, ensure that the device qualifies as a Class A device according to the MDACS classification criteria.
Class A devices typically include devices that are simple, have minimal impact on the patient's health, and are not likely to pose significant risks (e.g., bandages, non-invasive diagnostic devices, etc.).
Technical Documentation: Prepare detailed technical documentation that demonstrates the device’s compliance with safety, performance, and quality standards. The required documentation typically includes:
Product description and intended use.
Design and manufacturing specifications.
Risk management documentation (e.g., risk analysis, risk control measures).
Labeling and Instructions for Use (IFU).
Evidence of compliance with international standards (e.g., ISO 13485, ISO 14971).
Manufacturer Information: If the manufacturer is located outside of Hong Kong, provide details about the manufacturer and the authorized representative (if applicable).
Post-market surveillance plan: Provide an outline for monitoring the device’s performance once it is on the market, including a system for reporting adverse events.
Online Submission: Submit the registration application through the MDACS portal or the Hong Kong Department of Health (DH) online system.
The application form should include information such as the device's name, classification, intended use, and details about the manufacturer or the authorized representative.
Supporting Documents: Submit the technical documentation, including the documents prepared in Step 2. You will likely need to upload the documents in electronic form (PDF or other accepted formats).
Declaration of Conformity: Submit a Declaration of Conformity from the manufacturer or authorized representative that attests that the device complies with applicable safety and performance standards.
Fee Payment: Pay the applicable registration fee based on the device type and other factors. The Hong Kong Department of Health will issue an invoice for the fee.
Fee Processing: Payment is usually made via the online portal using electronic payment methods. Be sure to retain proof of payment for your records.
Evaluation by Authorities: After submission, the Hong Kong Department of Health (DH) will review the application and technical documentation to assess whether the device complies with Hong Kong's regulatory requirements.
Inspection or Additional Information: If necessary, the DH may request additional information or documents for clarification. This could include providing further details on the device’s safety, performance, or manufacturing processes.
If the device meets all the necessary requirements and the review is successful, the Hong Kong Department of Health will issue the registration certificate for the Class A device.
Registration Number: Upon successful registration, a registration number is assigned to the device, which must be used in all marketing and sales documentation.
Registration Validity: The registration is typically valid for a specific period (often 5 years) before re-registration is required.
Post-market Requirements: After the device is registered, the manufacturer (or authorized representative) must comply with post-market surveillance requirements, including monitoring the device’s performance and reporting any adverse events or incidents.
Adverse Event Reporting: If any adverse events related to the device occur, these must be reported to the Hong Kong Department of Health according to the regulatory requirements.
Periodic Updates: The device registration may need periodic updates to ensure continued compliance with any changes in regulations or standards. This could involve submitting new documentation, updating technical files, or providing post-market surveillance data.
Renewal: If the registration expires, renewal is necessary to continue marketing the device in Hong Kong.
Verify Device Classification: Confirm that the device qualifies as Class A.
Prepare Documentation: Gather technical documentation, including device description, risk management, labeling, and compliance with international standards.
Submit the Application: Apply online via the MDACS portal, including necessary documents.
Pay Registration Fee: Pay the required fees and retain payment proof.
Review and Evaluation: The Hong Kong Department of Health will review the application and request any additional information if needed.
Receive Registration Confirmation: If successful, receive the registration certificate and registration number.
Post-market Surveillance: Monitor the device’s safety and performance and report adverse events.
Periodic Updates and Renewal: Ensure the device remains in compliance with periodic updates and re-registration.
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