1. Registration Testing Process
Key Requirements:
Conduct full performance testing in compliance with product technical requirements.
Must be performed by CMA/CNAS accredited institutions (mandatory for official reports).
Timeline: 30–60 working days.
Testing Category Key Contents Reference Standards
Physical/Chemical Properties Material strength, dimensional stability, chemical residues GB/T 14233.1 (2021)
Biocompatibility Cytotoxicity, sensitization, irritation GB/T 16886.10 (2022 Revised Edition)
Sterilization Validation Dose, residual toxicity, sterility assurance GB 15980 (2023 Updated)
Electrical Safety Insulation, leakage current, withstand voltage YY 0505 (2021 Implementation)
2. Clinical Evaluation Pathways
Regulatory Updates (2021):
Simplified clinical requirements for certain products (e.g., low-risk devices).
Options:
Same-product comparison: Demonstrate equivalence to existing approved devices.
Clinical trial: Required for high-risk or novel technologies (e.g., AI diagnostic software).
Guidance: Follow the 2021 Clinical Evaluation Technical Guidance.
Timeline: 3–12 months (varies by product complexity).
Risk Note:
For AI-based devices, consult NMPA’s 2021 Technical Guidance for specific requirements.
Clinical trial design must align with GCP (Good Clinical Practice) standards.
3. Quality Management System (QMS) Audit
Key Requirements:Verify compliance with the 2022 Revised Medical Device Production Quality Management Norms.
Focus on production processes, documentation, and risk control.
Timeline: 45–90 working days.
4. Policy Dynamics and Risk Management
2023 NMPA Classification Adjustment:
The Medical Device Classification Catalogue is under dynamic review.
Action Required: Regularly check NMPA announcements for potential reclassification of your product.
Testing Institution Selection:
Only accept reports from CMA/CNAS accredited labs.
5. Key Risks and Mitigation Strategies
Risk AreaMitigation Measures
Regulatory Changes Subscribe to NMPA updates; engage professional consultants for compliance checks.
Clinical Trial Delays Plan buffer time (e.g., 12 months) and validate trial design early.
QMS Non-Compliance Conduct internal audits against 2022 norms before official inspection.
Final Recommendations:
Prioritize CMA/CNAS testing and 2022 QMS compliance to avoid delays.
For clinical evaluation, clarify product classification with NMPA if unsure.
Monitor policy updates via NMPA’s official website (www.nmpa.gov.cn).
Disclaimer: This guide summarizes general requirements. Specific product pathways may vary; consult NMPA or third-party experts for tailored advice.