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April 12, 2025

Approximately 5 minutes

Medical Device Product Registration in Hong Kong: A Focused Approach

Expediting Medical Device Registration in Hong Kong: A Practical Overview

From what we've seen, Hong Kong's medical market is full of great opportunities for companies making medical devices. To successfully bring and sell medical devices here, you absolutely need to follow the rules. While Hong Kong's main system, the Medical Device Administrative Control System (MDACS), is currently a voluntary program for listing devices, we know from experience that it's a super important step for getting your products into the market and preparing for stricter rules that might come later.

Specialized consulting services are available to help medical device companies efficiently navigate the regulatory hurdles in Hong Kong and gain timely access to its medical market.


What is the definition of a medical device in Hong Kong?

When we talk about "medical devices" in Hong Kong, what exactly does the Department of Health's Medical Device Division (MDD) consider to be one? According to their guidelines, a medical device is essentially any instrument, apparatus, machine, appliance, implant, software, material, or similar item. It's important that the manufacturer intends it to be used, either alone or with other things, for specific medical purposes in humans.

These purposes include:

  • Diagnosing, preventing, monitoring, treating, or easing diseases.
  • Diagnosing, monitoring, treating, easing, or compensating for an injury.
  • Investigating, replacing, modifying, or supporting the body's structure or how it works.
  • Supporting or sustaining life.
  • Controlling conception (like contraception).
  • Disinfecting other medical devices.
  • Providing medical information by examining samples from the human body (this is what IVDMs do!).

Crucially, a medical device does not achieve its main effect in or on the body through drugs, immune responses, or metabolism. However, it might be helped in its function by such means. So, it's pretty broad, covering everything from a simple bandage to complex diagnostic software!


Streamlining the Hong Kong Registration Process: Our Approach

From our experience, simplifying the registration process is key. That's why we focus on getting medical devices ready for MDACS listing, making the whole journey smoother and helping products get through complex rules much faster. Key aspects of such services include:

  • Regulatory Compliance Guidance: Offering expert advice on Hong Kong's unique medical device rules and guidelines. To our understanding, this involves explaining those often-technical documents and guidance notes from the Medical Device Division (MDD) in plain language, so you know exactly what's expected.
  • Market Access Strategies: Creating custom plans to make sure your products fit local requirements and can be successfully launched in Hong Kong. According to our experience, this often means finding the quickest and most direct ways to submit your paperwork.
  • Documentation Preparation: Helping you meticulously prepare all the documents needed for MDACS listing. What does this involve? We make sure that technical files, summary documents (like STED), and all other materials are complete, accurate, and organized just the way the MDD expects for a smooth review.
  • Local Responsible Person (LRP) Support: What if you're a foreign company? If you're a manufacturer without a local office in Hong Kong, appointing a Local Responsible Person (LRP) is a must. Based on our knowledge, these consulting services often help clients understand how to appoint an LRP or assist the appointed LRP in doing their many important tasks. The LRP is super important because they're the official link with the MDD for everything from getting approval to managing what happens after the product is sold.
  • Efficient Registration Process: Our goal is to make the registration process as fast as possible. We aim to cut down on potential delays and make sure manufacturers can launch their devices quickly and correctly, following all the rules.

Advantages of the Hong Kong Medical Market: What We've Observed

From what we've observed, Hong Kong is really appealing for medical device companies because of a few key reasons:

  • It has a well-developed healthcare system where people spend a lot on medical care, meaning there's a strong demand for good quality medical technology.
  • It's in a fantastic location, acting as a key entry point to mainland China and other busy healthcare markets across Asia.
  • The MDACS provides a clear way forward, even if it's voluntary for now. To our understanding, it lines up with international standards, which makes entering the market more predictable.

By using specialized expertise, companies can meet Hong Kong's rules efficiently and truly get their medical devices into the market. From our experience, these services help you understand everything from how devices are classified to what documents you need, and even how to keep an eye on your product once it's out there for long-term success in Hong Kong. Are you considering bringing a new medical device to Hong Kong, and wondering which step to tackle first?

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Questions & Answers (3)

A
Guest

Does Stage C apply to Class II medical devices for home-use? Or does this only apply to hospital products that are procured by the DH?

ElendiLabs

Stage C applies to all medical devices procured by the DH, including Class II, III, and IV general medical devices and Class B, C, and D in vitro diagnostic medical devices.

A
Guest

We want to use an independent third-party Local Responsible Person (LRP) to maintain control over our technical files. However, our local distributor claims that if they are not the LRP, they cannot be listed as the 'Authorized Importer' in the Hospital Authority’s procurement system. Is it possible to separate the Regulatory Listing (LRP) from the Commercial Importer status in the MDIS portal?

ElendiLabs

Absolutely. The MDACS explicitly separates these roles. The LRP is the legal representative to the Department of Health (DH) for safety and vigilance. The Listed Importer (of which there can be many) is a commercial role. You can appoint an independent LRP to "own" the listing and then authorize multiple distributors as "Listed Importers" under your listing. This ensures that if you change distributors, you do not lose your HKMD Listing Number or have to re-register from scratch

A
Guest

The Centre for Medical Products Regulation (CMPR) is expected to be fully operational by the end of 2026. If we list our devices under the current 'voluntary' MDACS system now, will our listing be automatically 'grandfathered' into the mandatory statutory registration once the new law is passed, or will we have to pay new fees and undergo a fresh 'Primary Evaluation'?

ElendiLabs

Current policy indicates a seamless transition. Devices with a valid MDACS Listing Number when the new legislation is enacted will be automatically transitioned into the mandatory register. They will retain their existing HKMD numbers but will be subject to the new, stricter Post-Market Surveillance (PMS) and Vigilance reporting requirements of the CMPR. Companies that wait for the mandatory system to launch will likely face higher fees and a more rigorous "Primary Evaluation" instead of the current "Leveraged Approval" pathway.

Need Expert Guidance?

Contact us at contact@elendilabs.com / +852 4416 5550