For Class B medical device registration under the Medical Device Administrative Control System (MDACS) in Hong Kong, the technical documentation plays a critical role in demonstrating the safety, quality, and performance of the product.
Below is a detailed guide on the technical documentation requirements for MDACS Class B devices:
| Document Type | Description | Notes |
|---|---|---|
| ✅ 1. Device Description & Classification | Detailed product description, intended use, and classification rationale | Align with MDACS classification rules (GHTF-based) |
| ✅ 2. Labeling & Packaging | Actual labels, outer packaging, and Instructions for Use (IFU) | Must be in English and/or Chinese |
| ✅ 3. Regulatory Approval | Certificates from reference markets (at least one): - CE Mark (MDD/MDR) - US FDA 510(k)/PMA - TGA ARTG - Health Canada MDL/MDALL - Japan PMDA | Mandatory unless full technical file is provided |
| ✅ 4. Declaration of Conformity | Manufacturer’s declaration confirming conformity with applicable standards | Referencing ISO, IEC, or relevant GHTF/IMDRF standards |
| ✅ 5. Quality Management System Certificate | Valid ISO 13485:2016 certificate from an accredited body | Scope must cover the device type |
| ✅ 6. Risk Management Report | Risk analysis per ISO 14971 | Especially if no CE/FDA evidence is submitted |
| ✅ 7. Essential Principles Checklist | Mapping of the device to the applicable Essential Principles of Safety and Performance | Required if no prior approval exists |
| ✅ 8. Clinical Evidence (if applicable) | Clinical evaluation report or literature summary | Not always required for Class B, unless novel technology |
| ✅ 9. Device Photos | High-quality color photos of the device and packaging | Must clearly show labels and markings |
| ✅ 10. Manufacturer’s Information | Business registration or profile (if available) | Helps establish credibility |
| ✅ 11. Local Responsible Person Appointment Letter | Authorization from the manufacturer to the LRP | Must be signed and dated |
You must submit a complete technical file, similar to EU MDR Annex II/III, including:
Design drawings & specifications
Performance testing (bench, biocompatibility, EMC, electrical safety)
Clinical evaluation
Manufacturing process details
Vigilance & post-market surveillance plan
| Requirement | Notes |
|---|---|
| 📄 Format | Hard copy (organized binder, tabbed sections recommended) |
| 🈯 Language | English or Chinese only (translated documents must be certified) |
| 📬 Submission | Send to the Medical Device Division, Department of Health, Hong Kong |
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