To apply for Class C medical device registration under the Medical Device Administrative Control System (MDACS) in Hong Kong, several key conditions must be satisfied. These conditions ensure that the device meets the safety, performance, and regulatory standards acceptable by the Medical Device Division (MDD) of the Department of Health.
Below is a detailed summary of the mandatory conditions you must meet before applying:
Your product must be classified as a Class C device under MDACS based on risk level.
Medium- to high-risk general medical devices
Examples: anesthesia machines, dialysis equipment, infusion pumps, diagnostic X-ray machines
📘 Use MDACS Guidance Document GN-01 to determine the class:
Before applying, your device must have valid regulatory approval or clearance from at least one reference market.
| Country/Region | Regulatory Body | Accepted Approvals |
|---|---|---|
| USA | FDA | 510(k), PMA |
| EU | EU MDR/IVDR | CE Mark |
| Australia | TGA | ARTG Listing |
| Canada | Health Canada | MDL |
| Japan | PMDA | Shonin/GMP Certification |
📌 Attach proof of approval (certificate, license, listing number, etc.) with your application.
If the manufacturer is not located in Hong Kong, a Local Responsible Person (LRP) must be appointed.
A legally registered company in Hong Kong
Officially appointed via a signed letter of authorization
Responsible for:
Submitting and maintaining registration
Communicating with the MDD
Handling adverse event reporting and post-market surveillance
📄 Must register using Form MD100
The manufacturer must be registered in MDACS before listing the device.
Form MD101 (Manufacturer Listing Form)
Valid ISO 13485 certificate
Manufacturer’s contact details and facility address
Declaration of Conformity (DoC)
You must submit a complete technical dossier that demonstrates conformity with the Essential Principles of Safety and Performance.
Device description and design
Risk management file (per ISO 14971)
Clinical evidence or performance data
Essential Principles checklist (GN-03)
Labeling and Instructions for Use (in English or Chinese)
Proof of reference market approval
Declaration of Conformity (DoC)
📄 Technical documentation format must follow GN-02
All packaging labels, product markings, and instructions for use must be in English or Chinese, or both.
🔍 Ensure:
Content is consistent with reference market use
No misleading claims
Proper usage warnings and contraindications included
The applicant (LRP) must be able to handle:
Adverse event reporting (Form MD151)
Change notifications (e.g., manufacturer change, label update)
Recalls or corrective actions if required
Keeping records of sales and distribution for audit
MDACS currently requires:
Hardcopy documents (forms and dossier)
Electronic version (on USB flash drive or CD-ROM)
All materials must be submitted to:
Medical Device Division (MDD)
Room 3101, 31/F, Hopewell Centre
183 Queen’s Road East, Wan Chai, Hong Kong
| Condition | Description |
|---|---|
| ✅ Device Class | Must be Class C under GN-01 |
| ✅ Reference Market Approval | From FDA, CE, TGA, Health Canada, or PMDA |
| ✅ Appointed LRP | Registered company in HK; uses Form MD100 |
| ✅ Manufacturer Listed | Uses Form MD101 + ISO 13485 |
| ✅ Technical File Ready | As per GN-02/GN-03 |
| ✅ Labels & IFU | In English or Chinese |
| ✅ Post-Market Capacity | LRP must handle surveillance, reporting |
| ✅ Submission Format | Physical copy + USB/CD to MDD office |

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