Class D medical device MDACS registration in Hong Kong refers to the process of voluntarily listing a high-risk medical device with the Medical Device Division (MDD) of the Department of Health (DoH) under the Medical Device Administrative Control System (MDACS).
Although MDACS is not mandatory under Hong Kong law, it is widely recognized and required by many public and private healthcare institutions—especially for hospital tenders, import permissions, and clinical use.
In the MDACS framework, medical devices are classified into four risk-based categories:
| Class | Risk Level | Examples |
|---|---|---|
| Class A | Low risk | Tongue depressors, bandages |
| Class B | Low to moderate risk | Thermometers, surgical gloves |
| Class C | Moderate to high risk | Syringe pumps, anesthesia machines |
| Class D | High risk | Implants, life-support devices, HIV test kits |
Class D represents the highest level of risk, and includes:
Life-sustaining or life-supporting devices
Implantable devices (e.g. heart valves, orthopedic implants)
In vitro diagnostic (IVD) devices for detecting transmissible diseases (e.g. HIV, Hepatitis B, Syphilis)
It means that:
The device has been assessed and accepted by the Medical Device Division (MDD).
It complies with international safety and performance standards (based on GHTF/IMDRF guidance).
It is listed on the MDACS website as an approved medical device for use, marketing, and import in Hong Kong.
It has undergone:
Review of the technical documentation
Verification of foreign regulatory approvals (e.g. CE, FDA)
Validation of quality systems (e.g. ISO 13485)
Assessment of risk, clinical, and performance data
| Feature | Details |
|---|---|
| Voluntary System | Not legally required but widely accepted |
| Regulatory Body | Medical Device Division (MDD), Department of Health |
| Listing Validity | 5 years (renewable) |
| Application via | Medical Device Information System (MDIS) |
| Submission by | Local Responsible Person (LRP) |
| Review Time | 4–9 months depending on completeness |
| Post-Market Compliance | Mandatory (AE reporting, recalls, changes) |
✅ Recognized for public hospital procurement (e.g. Hospital Authority)
✅ Demonstrates compliance with international standards
✅ Enables market access and import clearance
✅ Strengthens trust with local healthcare providers
✅ Supports clinical trials and private sector sales
Cardiac implants (e.g. pacemakers, defibrillators)
Orthopedic implants (e.g. joint replacements)
Dialysis machines
ICU monitors
Blood bag systems
HIV / HBV diagnostic kits
Cancer biomarker detection systems (IVD)
Hong Kong does not have a law mandating pre-market registration of medical devices (as of now), but:
MDACS functions as de facto market approval.
It is frequently required in hospital bids, customs inspections, and professional healthcare settings.
Class D MDACS registration in Hong Kong means a high-risk medical device has been voluntarily registered, reviewed, and listed under the DoH's MDACS framework, signifying it meets recognized international safety and performance standards. While not legally required, it is practically essential for market access, hospital use, and regulatory credibility in Hong Kong.
Would you like a comparison of MDACS vs other Asian regulatory systems (e.g. China NMPA, Singapore HSA) for Class D devices? I can also provide a full checklist of MDACS Class D requirements.
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