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:
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
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.
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
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)
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 Type | Description |
|---|---|
| Device Description | Intended use, technical specs, accessories |
| Regulatory Status | Proof of approval in reference markets |
| Conformity Assessment | CE Certificate, FDA 510(k), etc. |
| Quality System | ISO 13485 certificate |
| Essential Principles Checklist | Completed as per GN-03 |
| Risk Management File | Risk analysis report (ISO 14971-based) |
| Clinical Evidence | Summaries or reports (if applicable) |
| Labeling and IFU | In English or Chinese |
| Declaration of Conformity | Signed by the manufacturer |
| Manufacturing Site Info | Facility address and process summary |
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).
All documents must be in English or Chinese.
If originally in another language (e.g., Japanese or German), certified translations are required.
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
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
MDACS listing is currently free of charge.
Typical processing time: 4–6 months (varies depending on application quality and completeness).
| Requirement | Details |
|---|---|
| Device Class | Class C (medium-high risk) |
| Reference Market Approval | At least 1 required (FDA, CE, TGA, etc.) |
| LRP | Must be a Hong Kong-registered entity |
| Manufacturer Registration | Submit Form MD101 with ISO 13485 and DoC |
| Technical Dossier | Complete and compliant with GN-02/GN-03 |
| Labeling & IFU | In English or Chinese |
| Application Form | Form MD102 (device listing) |
| Submission | Hard copy + soft copy to MDD |
| Post-Market Duties | Reporting, change notifications, etc. |
| Fees | No official fees for listing |
| Review Time | Approx. 4–6 months |

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