Applying for NMPA (National Medical Products Administration) registration of Class III medical devices in China involves a detailed and structured process to ensure compliance with regulatory requirements. Here are the key processes involved:

1. Preparation Phase

• Device Classification: Determine the correct classification of your medical device according to the China Medical Device Classification Catalogue. Class III devices are high-risk and require extensive documentation and scrutiny.

• Regulatory Strategy: Develop a regulatory strategy based on the device classification, intended use, and applicable Chinese regulations. Understand the specific requirements and documentation needed for Class III devices.

2. Quality Management System (QMS) Compliance

• ISO 13485 Certification: Obtain ISO 13485 certification or an equivalent QMS certification recognized by the NMPA. This certification demonstrates that your manufacturing processes meet international standards for medical device quality management.

3. Technical Documentation Preparation

• Technical File Compilation: Prepare comprehensive technical documentation that demonstrates compliance with Chinese regulatory requirements. This includes:
  • Device description, specifications, and intended use.
  • Design and manufacturing information, including drawings and diagrams.
  • Risk analysis and mitigation strategies (according to ISO 14971).
  • Clinical evaluation data and performance testing reports.
  • Instructions for Use (IFU) and labeling information compliant with Chinese regulations.

4. Clinical Data (if applicable)

• Clinical Evaluation: Provide clinical evaluation reports or clinical trial data if required by the NMPA. This data should demonstrate the safety and efficacy of your device for its intended use in the Chinese market.

5. Local Representation

• Appoint a Local Agent: Designate a qualified local agent or representative in China who is registered with the NMPA. This agent will facilitate communication with regulatory authorities and handle submissions on your behalf.

6. Document Notarization and Translation

• Document Preparation: Ensure all documentation is notarized and translated into Chinese by qualified translators. Notarization verifies the authenticity of documents, while translation ensures compliance with local language requirements.

7. Submission Process

• Compile Application Package: Organize all required documentation into a comprehensive application package. Ensure that the application is complete, accurate, and aligned with NMPA submission requirements.

• Submit Application: Submit the registration application through the NMPA's designated online portal or physical submission process. Include all necessary forms, technical documentation, clinical data, and proof of QMS compliance.

8. Review Process

• Administrative Review: The NMPA conducts an initial administrative review to ensure that your application is complete and meets basic submission requirements.

• Technical Review: A detailed assessment of your technical documentation, clinical data, and manufacturing processes to verify compliance with Chinese regulatory standards. This review may include requests for additional information or clarification.

• On-Site Inspection (if applicable): Depending on the device classification and risk, the NMPA may conduct an on-site inspection of your manufacturing facilities to verify compliance with Good Manufacturing Practices (GMP).

9. Decision and Approval

• Approval Process: Upon successful completion of the review process, the NMPA will issue a decision regarding your application. This decision may include approval, conditional approval pending further information, or rejection.

10. Post-Approval Responsibilities

• Post-Market Surveillance: Establish procedures for monitoring and reporting adverse events related to your device as required by Chinese regulations.

• Annual Reporting: Submit annual reports to the NMPA detailing device sales, adverse events, and updates on post-market surveillance activities.

Additional Considerations

• Regulatory Updates: Stay informed about changes to Chinese regulatory requirements and standards that may impact your device registration or ongoing compliance.

• Consultation: Consider engaging with regulatory consultants or experts who specialize in Chinese medical device regulations to navigate the application process effectively.

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