Listing Procedures for Class B, C, and D In Vitro Diagnostic Medical Devices in Hong Kong: A Guide to GN-06

Listing In Vitro Diagnostic Medical Devices (IVDMDs) in Hong Kong: Our Guide to GN-06

From our perspective, introducing In Vitro Diagnostic Medical Devices (IVDMDs) to the Hong Kong market requires careful navigation through the Medical Device Administrative Control System (MDACS). This system, run by the Department of Health, offers a clear framework for voluntarily listing medical devices. For those dealing with Class B, C, and D IVDMDs, the specific application procedures are well-explained in the "Guidance Notes for Listing Class B, C and D In Vitro Diagnostic Medical Devices" (GN-06). According to our experience, understanding this guidance is absolutely essential for manufacturers and Local Responsible Persons (LRPs) looking to bring these vital devices to Hong Kong.

Understanding IVDMD Classification: What You Need to Know

Before you even start the listing process, it's super important to classify your IVDMD correctly. So, what exactly is an In Vitro Diagnostic Medical Device (IVDMD)? Simply put, these are medical devices used outside the human body to test samples (like blood or urine) to give you information for diagnosis, monitoring, or to check compatibility. To our understanding, similar to how general medical devices are classified, IVDMDs fall into four risk-based categories:

• Class A: These are very low risk to individuals and public health. (Generally, these aren't listed under MDACS).
• Class B: These have a moderate individual risk or low public health risk.
• Class C: These pose a high individual risk or moderate public health risk.
• Class D: These carry both a high individual risk and a high public health risk.

The classification of an IVDMD depends on factors like what it's intended to be used for, how experienced the person using it needs to be, how important the diagnostic information it gives is, and how the test results might affect an individual's health or public health. Technical Reference TR-006 gives detailed rules and examples for IVDMD classification. How are medical devices classified in Hong Kong generally? In Hong Kong, all medical devices are categorized based on their associated risk. This system helps ensure that devices with higher potential risks undergo more rigorous checks and controls to protect public safety. This classification is a foundational step in Hong Kong medical device registration.

Who Can Apply for Listing? (Eligibility for Application)

Applications for adding Class B, C, or D IVDMDs to the MDACS List of Medical Devices must always be made by a Local Responsible Person (LRP). Who can actually be a Local Responsible Person (LRP)? From our experience, an LRP can be:

• A legal company that is officially registered in Hong Kong.
• An individual or a company with a valid business registration in Hong Kong.
• The manufacturer themselves, but only if they have an officially registered business address right here in Hong Kong.

To our understanding, if you're a foreign manufacturer without a registered business in Hong Kong, you absolutely must appoint an LRP to act on your behalf. This is a critical step for IVDMD listing in Hong Kong.

The Application Procedure: Our Step-by-Step Guide

The process for getting Class B, C, and D IVDMDs listed generally follows these steps, as laid out in GN-06:

1. Prepare Your Application Documents (Dossier):

   • Application Form (MD102): This is the main form for IVDMDs. It needs all the key details about your device, your company (the manufacturer), and your LRP.
   • Essential Principles Conformity Checklist (MD-CCL): Think of this as a tick-box list showing that your device meets the fundamental safety and performance rules for medical devices.
   • Technical Documentation: This is the detailed stuff! It includes how your product is designed, how it's made, test results (like how well it performs and any clinical evidence), risk management plans, and all your labels (like instructions for use and packaging).
   • Quality Management System (QMS) Certification: You'll need proof that your manufacturing process follows a certified quality control system, usually something like ISO 13485.
   • Reference Country Approval (if you have it): If your device is already approved for sale in certain recognized countries (like the US, EU, Canada, Japan, Australia, Korea, or mainland China), according to our experience, this can really help speed up the review process in Hong Kong.
   • Declaration of Conformity: A formal statement from you, the manufacturer, confirming that your device meets all the essential rules.
   • LRP Designation Letter: A formal letter from you, appointing your LRP.

2. Submit Online via MDIS:

   • The Medical Device Division (MDD) really encourages you to use their Medical Device Information System (MDIS) for online submissions. Why is online submission preferred? Because, as we've seen, it significantly streamlines the application process, making it faster and more efficient for everyone involved.
   • To our understanding, while digital copies are generally preferred, you might still need to send a signed original application form (MD102) and Essential Principles Conformity Checklist (MD-CCL) on paper. Plus, you'd send duplicate electronic copies on a CD/DVD or via email for smaller files.

3. MDD Assessment:

   • Once you submit everything, the MDD will review your application to make sure it's complete and meets all the MDACS requirements.
   • According to our experience, the MDD might send you "deficiency letters" asking for more information or clarification during this review period. It's important to respond to these requests quickly to avoid delays in your IVDMD listing Hong Kong.

4. Listing and Certification:

   • If the review goes well and your device meets the MDACS requirements, the MDD will give your IVDMD a unique listing number.
   • Your device will then be added to the publicly available List of Medical Devices. Your LRP will also receive a physical copy of the listing certificate.

Important Things to Remember: Our Practical Advice

• Accuracy and Completeness: According to our experience, providing accurate and complete information is extremely important to avoid delays in the application process. Missing details or errors can set you back significantly.
• Compliance with Standards: Your devices must always follow recognized international and national standards related to their safety and performance. This is non-negotiable for regulatory compliance in Hong Kong.
• Post-Market Surveillance: Getting listed under MDACS also means your LRP has ongoing responsibilities even after the device is on the market. This includes reporting any problems and managing safety actions, as explained in other MDACS guidance notes (like GN-03).
• Timelines: To our understanding, while the exact time for processing applications can vary, the MDD aims for efficiency. Being proactive with your preparation and responding quickly to any questions can definitely help speed things up.

By carefully following the procedures outlined in GN-06 and other relevant MDACS guidelines, manufacturers and LRPs can successfully navigate the IVDMD listing process in Hong Kong, ensuring these important devices are available for public health.