When applying for China NMPA (National Medical Products Administration) certification for a medical device, the required documents can vary depending on the device’s classification (Class I, II, or III) and the type of application (domestic vs. foreign manufacturer). Below is a general list of documents typically required for NMPA medical device registration:
1. Application Form
- Completed application form with detailed information about the medical device, manufacturer, and regulatory status.
2. Power of Attorney
- A letter authorizing a local agent (if the manufacturer is a foreign entity) to act on behalf of the applicant for the NMPA registration process.
3. Business License of Manufacturer
- A copy of the manufacturer’s business license (for domestic companies) or a Certificate of Free Sale (for foreign manufacturers).
4. Company Profile
- Information about the applicant company, including the company’s history, financial status, and manufacturing capabilities.
5. Device Description and Intended Use
- Detailed description of the device, including its intended use, classification, working principle, and function. This document may also need to explain the design and technological characteristics of the product.
6. Product Technical Specifications
- Detailed technical documentation of the medical device, including materials used, technical specifications, manufacturing processes, and design diagrams (e.g., electrical, mechanical, or software components).
7. Device Labeling
- Sample labeling, packaging, and instructions for use (IFU), which should comply with the NMPA requirements for language and format.
8. Clinical Evaluation Report (or Clinical Trial Data)
- A clinical evaluation report or clinical trial data is required for higher-risk devices (Class II and III). This report should demonstrate the device's safety and effectiveness, typically based on existing clinical data or clinical trials conducted in China or internationally.
- For Class I devices, clinical trials may not be required.
9. Risk Management Report
- Documentation showing the manufacturer's risk management process and how risks related to the device are identified, evaluated, and mitigated.
10. Quality Management System (QMS) Documentation
- Evidence of compliance with a recognized quality management system, such as ISO 13485 (Medical Devices—Quality Management Systems), including audit reports and corrective actions. For foreign manufacturers, NMPA may require a GMP (Good Manufacturing Practice) inspection.
11. Pre-clinical Test Reports
- Test reports from laboratory or pre-clinical trials demonstrating the device’s safety, biocompatibility, electrical safety, or electromagnetic compatibility (EMC), depending on the nature of the device.
- Common pre-clinical tests include:
- Biocompatibility testing (for implantable devices).
- Electrical safety testing (for electrically powered devices).
- EMC testing.
- Toxicological tests (for certain devices).
12. Product Stability Data
- Stability testing data (especially for devices with a shelf life or those that are sensitive to environmental factors) demonstrating that the product maintains its effectiveness and safety over time.
13. Clinical Trial Plan and Report (if applicable)
- A clinical trial plan outlining the methodology, objectives, and protocol for clinical trials conducted in China (or any internationally accepted trials). The results of these trials must be included in the application.
14. Manufacturing Site Inspection Report
- An inspection report or audit of the manufacturing facility, verifying that the site complies with local regulations and NMPA’s quality standards (e.g., GMP).
- For foreign manufacturers, the NMPA might require an on-site inspection or provide an alternative approach such as documentation of an existing inspection by another recognized regulatory body.
15. Clinical Trial Approval (if applicable)
- Approval from the relevant ethics committee or regulatory body for clinical trials conducted within China.
16. Post-Market Surveillance Plan
- A plan that describes the procedures for post-market surveillance and vigilance once the device is on the market, including monitoring device performance, adverse events, and reporting mechanisms.
17. Foreign Manufacturer’s Certificate (for Foreign Devices)
- For foreign manufacturers, a Certificate of Free Sale (CFS) from the country of origin indicating that the product is legally sold in that country and meets international standards.
18. Import and Export Authorization (for Foreign Manufacturers)
- Importation authorization documents if the product is being manufactured outside of China.
19. Certificate of Device’s Production Compliance (for domestic manufacturers)
- A statement or certification showing that the product complies with national standards (China’s GB/T standards or other relevant regulations).
20. Market Authorization in Other Countries (if applicable)
- If the device is already authorized in other countries (such as the EU, the US, Japan, or other major markets), this evidence should be included to help support the application.
21. ISO 13485 Certification
- Certification proving that the manufacturer operates under an internationally recognized quality management system (ISO 13485 for medical devices). This is required for Class II and III devices, and foreign manufacturers may need to submit it.
22. Other Supporting Documents
- Additional documentation may be required based on the device type, including:
- Environmental testing reports.
- Certification of device components.
- Manufacturer's history of product recalls or adverse events (if applicable).
NMPA Certification Process and Timeline
- The NMPA review process can take anywhere from 6 months to 2 years, depending on the complexity of the device and the thoroughness of the documentation submitted.
- The registration process for Class I devices is generally faster since they require fewer documents compared to Class II and III devices, which may require more extensive clinical data and testing.
Final Notes
- The NMPA often requires that all documents be translated into Chinese and notarized, particularly for foreign manufacturers.
- The process can be complex, and working with a local agent or regulatory consultant familiar with the NMPA’s requirements can significantly streamline the application and approval process.
This list provides a comprehensive overview, but specific devices may have additional or slightly different documentation requirements based on their risk class and intended use. Always check with the NMPA or a local regulatory expert for the most up-to-date and specific requirements.
Contact Us:
Whatsapp or Wechat:+86 15816864648;email address:hito.lin@grzan.cn