To register a Class C medical device under the Medical Device Administrative Control System (MDACS) in Hong Kong, you must prepare and submit a comprehensive set of materials that demonstrate your device’s safety, performance, and regulatory compliance. The materials must follow the structure laid out by the Medical Device Division (MDD) under the Department of Health.
The submission consists of three categories of documents:
Administrative Forms
Technical Documentation (Dossier)
Supplementary Declarations and Certificates
| Form | Purpose | Who Submits |
|---|---|---|
| MD100 | LRP registration | Local Responsible Person (LRP) |
| MD101 | Manufacturer registration | Manufacturer (via LRP) |
| MD102 | Device listing application | LRP |
✅ Download from: https://www.mdd.gov.hk
This should follow the format outlined in GN-02 and demonstrate compliance with the Essential Principles of Safety and Performance (GN-03).
Device name, model(s), variant(s)
Intended use and indications
Device classification rationale (confirm Class C)
Device specifications and materials
Engineering drawings, photos
Manufacturing process overview
Regulatory approval certificate(s) from at least one reference market:
CE Certificate (MDR/IVDR)
FDA 510(k) or PMA approval
TGA ARTG entry
Health Canada MDL
PMDA approval (Japan)
ISO 13485 certificate (valid and issued by an accredited CB)
Description of QMS implementation at manufacturing site
Use the checklist from GN-03
Demonstrate how the device complies with each applicable principle
Risk analysis and risk evaluation (compliant with ISO 14971)
Summary of risk control measures and residual risks
Summary of clinical evaluation report
Clinical investigation data or literature reviews (if applicable)
For well-known devices, equivalence-based evidence may suffice
Outer and inner packaging labels
Instructions for Use (IFU) or user manual
Labels and IFU must be in English or Chinese
Signed by the manufacturer’s authorized representative
Must state compliance with recognized standards and Essential Principles
Optional but helpful in providing a visual understanding of the product
Letter of Authorization from the manufacturer appointing the LRP
Business Registration Certificate of the LRP (Hong Kong-registered entity)
Summary of changes if any variation of a previously approved model is submitted
| Step | Action |
|---|---|
| 1️⃣ | Collect regulatory approvals from reference market(s) |
| 2️⃣ | Obtain valid ISO 13485 certificate for the manufacturer |
| 3️⃣ | Complete and sign Forms MD100, MD101, and MD102 |
| 4️⃣ | Build the technical dossier according to GN-02 structure |
| 5️⃣ | Fill in the Essential Principles Checklist (GN-03) |
| 6️⃣ | Translate IFU and labels to English or Chinese (if not already) |
| 7️⃣ | Prepare Declaration of Conformity signed by the manufacturer |
| 8️⃣ | Compile hardcopy and digital copy (on USB/CD) |
| 9️⃣ | Organize documents with section dividers and a document index |
| 🔟 | Submit full package to: |
Medical Device Division (MDD)
Room 3101, 31/F, Hopewell Centre, 183 Queen’s Road East, Wan Chai, Hong Kong
All files should be clearly labeled and indexed
Use section headers and a table of contents
USB/CD file names must match printed document titles
Ensure consistency across forms, technical specs, and labeling
Include version control and revision dates on documents
| Item | Why It Matters |
|---|---|
| ✅ Reference market approval | Without this, MDACS will not accept the application |
| ✅ Labeling language | Must be in English or Chinese to be valid |
| ✅ Manufacturer authorization | LRP cannot submit without formal appointment |
| ✅ Technical completeness | Missing documents will delay the review or cause rejection |
| ✅ Respond to MDD queries promptly | Delays in response slow down the 4–6 month review window |
| Category | Document | Required |
|---|---|---|
| Forms | MD100, MD101, MD102 | ✅ |
| Authorization | LRP appointment letter | ✅ |
| Certificates | CE/FDA/TGA + ISO 13485 | ✅ |
| Technical | Dossier per GN-02 | ✅ |
| Compliance | Essential Principles Checklist (GN-03) | ✅ |
| Safety | Risk Analysis (ISO 14971) | ✅ |
| Clinical | Evaluation report / summary | ✅ |
| Labeling | IFU + labels in English or Chinese | ✅ |
| Legal | Declaration of Conformity | ✅ |
| Submission Format | Printed + USB/CD | ✅ |

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