What are the requirements for handling Class C medical device MDACS registration in Hong Kong?
Release time:2025-06-25 15:36:11 The author: source:
To handle Class C medical device registration under the Medical Device Administrative Control System (MDACS) in Hong Kong, you must comply with a defined set of regulatory, technical, and administrative requirements established by the Medical Device Division (MDD) of the Department of Health.

To handle Class C medical device registration under the Medical Device Administrative Control System (MDACS) in Hong Kong, you must comply with a defined set of regulatory, technical, and administrative requirements established by the Medical Device Division (MDD) of the Department of Health.

Here is a comprehensive breakdown of all requirements for handling Class C medical device registration under MDACS:


✅ 1. Device Classification Requirement

You must first determine and justify that the product is a Class C medical device, as per MDACS classification rules.

🔹 Class C refers to medium to high-risk general medical devices (e.g., anesthesia machines, infusion pumps, diagnostic X-ray systems).

📘 Reference: GN-01: Guidance Notes on Classification System for General Medical Devices


✅ 2. Reference Market Approval Requirement

The device must already be approved, registered, or licensed in at least one reference market:

Accepted reference markets:

  • United States (e.g., FDA 510(k), PMA)

  • European Union (e.g., CE mark under MDR/IVDR)

  • Canada (e.g., Health Canada MDL)

  • Australia (e.g., TGA ARTG listing)

  • Japan (e.g., PMDA approval)

📌 You must provide supporting certificates and regulatory approvals as part of your application.


✅ 3. Local Responsible Person (LRP) Requirement

If the manufacturer is not based in Hong Kong, you must appoint a Local Responsible Person (LRP).

🔐 The LRP must:

  • Be a legally registered entity in Hong Kong

  • Register with the MDD using Form MD100

  • Be authorized by the manufacturer to act on its behalf (with a formal appointment letter)

  • Be responsible for:

    • Submitting the application

    • Communicating with MDD

    • Performing post-market surveillance and adverse event reporting

📄 Supporting documents:

  • LRP appointment letter

  • Business registration certificate of the LRP


✅ 4. Manufacturer Listing Requirement

The manufacturer must be registered under MDACS using Form MD101, with:

  • Manufacturer’s name, address, contact details

  • Copy of valid ISO 13485 certificate

  • Declaration of Conformity (DoC)

  • Scope of manufacture (relevant to the submitted product)


✅ 5. Technical Documentation Requirements

You must compile a technical dossier to demonstrate that the device complies with the Essential Principles of Safety and Performance (GN-03).

📑 Required documents include:

Document TypeDescription
Device DescriptionIntended use, technical specs, accessories
Regulatory StatusProof of approval in reference markets
Conformity AssessmentCE Certificate, FDA 510(k), etc.
Quality SystemISO 13485 certificate
Essential Principles ChecklistCompleted as per GN-03
Risk Management FileRisk analysis report (ISO 14971-based)
Clinical EvidenceSummaries or reports (if applicable)
Labeling and IFUIn English or Chinese
Declaration of ConformitySigned by the manufacturer
Manufacturing Site InfoFacility address and process summary

✅ 6. Application Form Requirement

You must submit Form MD102 (Application for Listing of a Medical Device) including:

  • LRP and manufacturer information

  • Product name, classification, model numbers

  • Intended use and reference market approval

  • List of supporting technical documents

📎 Attach both printed copies and electronic files (USB or CD).


✅ 7. Language Requirements

All documents must be in English or Chinese.
If originally in another language (e.g., Japanese or German), certified translations are required.


✅ 8. Post-Listing Obligations

Once the device is listed, the LRP is responsible for ensuring ongoing regulatory compliance.

📌 Required actions:

  • Adverse event reporting (Form MD151)

  • Change notifications (e.g., updates to labeling, manufacturer, design)

  • Document retention

  • Market surveillance and recall actions if necessary


✅ 9. Submission Requirement

Send the full application package (Forms + supporting documents) to:

Medical Device Division (MDD)
Room 3101, 31/F, Hopewell Centre
183 Queen’s Road East, Wan Chai, Hong Kong
Tel: +852 3107 8451
Website: https://www.mdd.gov.hk


✅ 10. Fees and Timeframe

  • MDACS listing is currently free of charge.

  • Typical processing time: 4–6 months (varies depending on application quality and completeness).


✅ Summary Checklist of Key Requirements

RequirementDetails
Device ClassClass C (medium-high risk)
Reference Market ApprovalAt least 1 required (FDA, CE, TGA, etc.)
LRPMust be a Hong Kong-registered entity
Manufacturer RegistrationSubmit Form MD101 with ISO 13485 and DoC
Technical DossierComplete and compliant with GN-02/GN-03
Labeling & IFUIn English or Chinese
Application FormForm MD102 (device listing)
SubmissionHard copy + soft copy to MDD
Post-Market DutiesReporting, change notifications, etc.
FeesNo official fees for listing
Review TimeApprox. 4–6 months

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