Updating NMPA-registered medical devices in China involves a detailed procedure and adherence to specific certificate requirements. Here’s an overview of the process:
1. Determine the Need for Update
- Major Changes: If changes affect the safety, efficacy, or performance of the device, or if there's a significant alteration to its design or manufacturing process, a new application or update might be required.
- Minor Changes: Some changes may only require notification rather than a full update.
2. Prepare Documentation
- Technical Documentation: Includes updated technical specifications, risk assessments, and clinical data (if applicable).
- Product Information: Revised product labeling, instructions for use, and any changes to the product's claims or indications.
- Manufacturing Changes: Documentation of changes in manufacturing processes, facilities, or quality control measures.
3. Submit Application for Update
- Online Submission: File an application through the NMPA’s online system or via paper submission if required.
- Application Form: Complete the necessary forms detailing the changes and supporting documents.
4. NMPA Review
- Document Review: The NMPA reviews the submitted documents for completeness and compliance.
- Request for Additional Information: If needed, the NMPA may request further information or clarifications.
5. Inspection or Evaluation (if applicable)
- On-site Inspection: Depending on the nature of the update, an inspection of the manufacturing facility or evaluation of new clinical data might be required.
6. Approval and Issuance of Updated Certificate
- Issuance of Updated Registration Certificate: Once the NMPA approves the update, a revised registration certificate will be issued reflecting the changes.
- Notification: The manufacturer will be notified of the update status and any changes to the registration certificate.
7. Post-Approval Compliance
- Implementation: Ensure that all updates are fully implemented as per the new requirements.
- Ongoing Reporting: Maintain compliance with any new post-market surveillance or reporting obligations.
Key Certificates and Documentation:
- Updated Product Registration Certificate: Reflects the approved changes.
- Updated Technical File: Documentation showing compliance with current standards and regulations.
- Revised Labels and Instructions: Must be updated to reflect any changes in the product.
Adhering to these steps ensures that your medical device remains compliant with Chinese regulations and continues to meet the standards required for market access in China.
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