To register and apply for a Class C medical device under the Medical Device Administrative Control System (MDACS) in Hong Kong, you must follow a detailed process administered by the Medical Device Division (MDD) of the Department of Health. Though the system is currently voluntary, it is essential for sales to public hospitals and is often required in local tenders.
| Category | Details |
|---|---|
| Device Type | Medium-to-high risk (e.g., surgical instruments, infusion pumps, patient monitors) |
| Governing Body | Medical Device Division (MDD), Department of Health |
| Registration System | MDACS – Medical Device Administrative Control System |
| Application Party | Manufacturer (with a Hong Kong-based Local Responsible Person, LRP) |
| Requirement Type | Voluntary (but practically necessary for public procurement) |
Use MDACS Guidance GN-01 to determine if the product is Class C
Typical Class C examples include:
Invasive surgical devices (short to long-term)
Diagnostic imaging systems
Infusion systems
Active monitoring devices
📌 Document your classification rationale as part of your technical file.
The LRP must be a Hong Kong-registered company or entity
If the manufacturer is not located in Hong Kong, the LRP acts as the legal contact point for the device
📄 Required Documents:
Form MD100 (LRP Registration)
LRP’s Business Registration Certificate
Authorization Letter from the manufacturer
✅ The LRP is responsible for:
Submitting the application
Handling post-market surveillance
Reporting incidents and maintaining compliance
The product must have valid regulatory approval in at least one recognized reference market, such as:
| Reference Market | Acceptable Proof |
|---|---|
| EU | CE Certificate (MDD or MDR) |
| USA | FDA 510(k) or PMA approval |
| Australia | ARTG Listing |
| Canada | MDL |
| Japan | PMDA/Shonin Approval |
📎 Submit:
CE/FDA/ARTG certificates
Free Sale Certificate (if available)
Declaration of Conformity
If not already registered under MDACS:
📄 Submit Form MD101 with:
Manufacturer’s ISO 13485 certificate
Manufacturer details and location
Device production site info
Declaration of Conformity
Your technical file must comply with GN-02 (submission format) and GN-03 (Essential Principles).
Device description and intended use
Classification rationale
Labeling (IFU, packaging) in English or Chinese
Clinical evaluation data or equivalence justification
Safety & performance testing (ISO 10993, IEC 60601, EMC, etc.)
Software validation (if applicable – IEC 62304)
Essential Principles checklist (GN-03)
📁 Format:
One printed copy
One digital copy (CD-ROM or USB)
📄 Fill and submit Form MD102 (Device Listing Application), along with:
| Submission Includes | Notes |
|---|---|
| MD100 | LRP registration form |
| MD101 | Manufacturer registration form |
| MD102 | Device listing form |
| Technical Dossier | Per GN-02 and GN-03 |
| Reference Market Approvals | CE/FDA certificates, etc. |
📬 Deliver to:
Medical Device Division (MDD)
Department of Health
Room 3101, 31/F, Hopewell Centre
183 Queen’s Road East, Wan Chai, Hong Kong
💰 Fees: Currently, no application fee is required.
Once submitted:
Administrative screening: Check for completeness (2–4 weeks)
Technical review: Evaluate safety, performance, and compliance (2–4 months)
MDD may issue a Request for Further Information (RFI) if needed
📌 Tip: Respond to RFIs within 2–4 weeks to avoid delay.
If approved:
The device receives a Hong Kong Medical Device Number (HKMD No.)
It is published on the MDACS Listed Devices Database
You receive an official listing confirmation letter
🕒 Total Time Estimate: 3–9 months (varies based on submission quality and response time)
| Task | Status |
|---|---|
| Device classification determined (GN-01) | ☐ |
| LRP appointed and registered (Form MD100) | ☐ |
| Manufacturer registered (Form MD101) | ☐ |
| Reference market approval obtained | ☐ |
| Technical file compiled (GN-02, GN-03) | ☐ |
| Listing application submitted (Form MD102) | ☐ |
| Response to RFI (if applicable) | ☐ |
| Listing confirmation received | ☐ |
| Action | Frequency |
|---|---|
| Report serious incidents (Form MD151) | As needed |
| Update MDD on certificate/labeling changes | Within 30 days |
| Maintain technical documents | Minimum 5 years |
| Handle recalls or FSCA reports | Immediately |
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