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March 10, 2025

Approximately 5 minutes

Standards of Medical Device Good Manufacturing Practice (GMP) in South Korea (MFDS Notice No. 2023-31)

Standards of Medical Device Good Manufacturing Practice (GMP) in South Korea (MFDS Notice No. 2023-31)

1. What this regulation is and why it matters

South Korea regulates medical device manufacturing quality through Medical Device Good Manufacturing Practice (GMP) requirements (often referred to in practice as K-GMP). MFDS Notice No. 2023-31 sets out detailed rules on:

  • the scope of devices and regulated parties,
  • types of GMP audits (e.g., initial, periodic, renewal, additional),
  • how audits are conducted (document review vs. on-site),
  • timelines for review and notification, and
  • governance of GMP audit agencies and quality-manager training organizations.

Source: MFDS—Amendment Notice No. 2023-31 (May 12, 2023) Source: Attached PDF—Standards of Medical Device GMP (No. 2023-31)
(For the MFDS English regulations index page, see: MFDS—Medical Device Regulations (English).)

The Notice implements the GMP audit and standards framework under the Medical Device Act and its Enforcement Rule, prescribing matters necessary for:

  • the manufacturing and quality control standards for medical devices, and
  • the conduct of GMP audits and related administration.

Source: Attached PDF—Article 1 (Purpose)

Who it applies to

The Notice applies to medical devices as defined by law. It also clarifies that:

  • devices intended only for export, and Class I medical devices, must comply with the standard except for the GMP audit requirement.

Source: Attached PDF—Article 3 (Scope)

Effective date

The Notice states it took effect on November 13, 2023.

Source: Attached PDF—Addenda

3. Key concepts and regulated organizations

GMP audit agencies (quality management audit agencies)

MFDS designates and manages quality management audit agencies (i.e., organizations that conduct GMP audits). The Notice provides requirements such as:

  • criteria and procedure for designation, and
  • obligations for independent audits and post-management.

Source: Attached PDF—Articles 7 & 12

Quality-manager training organizations

The Notice also sets out requirements for organizations that provide education and training for medical device quality managers, including conditions for designation and compliance.

Source: Attached PDF—Article 8

4. Classification of GMP audits

The regulation classifies GMP audits into (at least) the following types:

  • Initial audit (for first-time GMP suitability recognition)
  • Periodic audit (performed at least once every three years)
  • Renewal (re-recognition) audit
  • Additional audit
  • Modification audit

The Notice also provides specific cases where a periodic audit may be exempted, including certain export-only or Class I devices, certain investigational medical devices, and certain combination/converged products.

Source: Attached PDF—Article 4 (Classification)

5. How GMP audits are performed

Baseline: follow the audit standards (Annex 2)

GMP audits are conducted in accordance with the audit standards in Annex 2. For investigational medical devices (for clinical trials), the Notice allows partial submission when applying for certain audits.

Source: Attached PDF—Article 5 (Audit Application)

On-site vs. document review

As a general rule, the initial audit includes an on-site audit at least once for each of the applicable manufacturing sites. However, for 64 specified product groups (Annex 4), the initial audit may be conducted as a document-only review (“independent audit”)—and a temporary GMP certificate can be issued in those cases.

Source: Attached PDF—Article 6 (Audit methods) & Annex 4

6. Submission package and review process

What you submit

To apply for GMP suitability recognition, the applicant submits:

  • an application form (Annexed form), and
  • supporting documents such as a quality manual, SOPs, records, and other evidence that the QMS is implemented as required.

The Notice also provides supplementation procedures if the submission is incomplete.

Source: Attached PDF—Article 5 & supplementation

Processing timelines (key operational deadlines)

Operationally important deadlines include:

  • the audit agency notifies the applicant of the result within 30 days after receiving complete application materials; and
  • if an on-site audit is required, the agency decides whether to conduct it within 10 days after completing the document review, and then notifies the final result within 30 days after the on-site audit is completed.

Source: Attached PDF—Article 9 (Processing timelines)

7. Certificates: validity, reissuance, and return

Validity

A GMP certificate is issued with a validity period of 3 years.

Source: Attached PDF—Article 8(9)

Reissuance and return

The Notice describes cases where a GMP certificate may be reissued (e.g., change of name/representative/address) and when a certificate must be returned (e.g., upon expiration, cancellation, or invalidation).

Source: Attached PDF—Article 10 (Reissuance) & Article 11 (Return)

8. Practical compliance checklist (for manufacturers/importers)

  • Map your product group: confirm whether your product falls into the Annex 4 group eligible for document-only review; if not, plan for an on-site audit.
  • Align your QMS evidence: ensure your quality manual, SOPs, and records demonstrate consistent control of production, process validation (as applicable), and CAPA.
  • Plan for timelines: treat the 10-day/30-day decision and notification windows as baseline operational expectations when planning market entry.
  • Maintain readiness for periodic audits: periodic audits occur at least every three years (unless exempted).

Primary legal text reference: Korean Law Information Center—Medical Devices Manufacturing and Quality Control Standards

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Questions & Answers (5)

A
Guest

我们目前已经获得了 MDSAP(医疗器械单一审核程序)证书。在向韩国食品医药品安全部(MFDS)申请 KGMP 认证时,这份 MDSAP 报告是否可以用来替代实地检查(On-site Audit)?如果可以,我们是否仍需要提交某些特定的韩国补充文件?

ElendiLabs

虽然韩国目前是 MDSAP 的观察员而非正式成员,但 MFDS 确实接受 MDSAP 审计报告作为简易审核的依据。对于符合条件的制造商,这通常可以将“实地检查”转为“书面审核”(Document-based Audit)。但是,您仍需提交针对韩国特定法规(如《医疗器械法》)的差异性自查报告,并确保所有申请资料(如质量手册和程序文件)符合韩国 KGMP 的特定模板要求。

A
Guest

As a foreign manufacturer, we understand we must pass the KGMP audit. However, does our local Korean distributor (the License Holder) also need to obtain their own KGMP certification for their warehouse, and if so, how does their audit intersect with our manufacturing audit?

ElendiLabs

Yes, the Korean Importer (K-Holder) must obtain their own KGMP for Importers (sometimes referred to as GIP - Good Import Practice). Their certification focuses on storage conditions, distribution records, and post-market surveillance handling. During your manufacturing KGMP audit, the auditors might verify that there is a clear Quality Agreement between you (the manufacturer) and the importer, ensuring that technical files and complaint handling protocols are synchronized between both parties.

C
Guest

我们的产品由一家位于美国的合同制造商(CMO)生产,但灭菌工序在另一个独立场地的第三方灭菌站完成。在申请 KGMP 时,这两个场地是会被视为一个整体进行一次审核,还是需要分别申请两个 KGMP 证书?

ElendiLabs

韩国 KGMP 认证是针对“制造场地”发放的。通常情况下,主工厂(实际组装和包装的地方)是审核的核心。如果灭菌是外包的,该灭菌站必须作为制造工序的一部分被包含在内。通常只需一份证书,但证书上会注明所有受审的工序及场地地址。如果灭菌站位于不同国家,审核难度和资料要求会相应增加。

A
Guest

We are planning to register a Class II diagnostic device. Under the current KGMP policy, is it guaranteed that a Class II device will undergo a document-based (remote) audit rather than an onsite inspection? Are there specific "red flags" that would cause the MFDS or a Third-Party Auditor (TPA) to demand an onsite visit to our overseas facility?

ElendiLabs

While Class II devices are generally prioritized for document-based reviews, an onsite audit can be triggered if: 1) It is the first time the manufacturer is exporting to Korea; 2) The manufacturing site has been flagged for significant safety issues or recalls internationally; or 3) The manufacturer produces high-risk components that are integrated into Class III or IV devices. The final decision rests with the TPA and MFDS after reviewing your Site Master File (SMF)

E
Guest

我们的 KGMP 证书有效期为三年。如果我们在证书到期前 63个月提交续展申请,但在原证书过期时 MFDS 尚未完成实地检查,这是否会导致我们的产品在韩国市场被迫停售或清关受阻?

ElendiLabs

为避免贸易中断,建议至少提前 6 到 9 个月启动续展程序。如果申请已在有效期内提交但因行政原因延迟审核,MFDS 通常允许在审核期间继续进口。然而,如果是因为企业资料提交不全导致无法在过期前完成评估,海关可能会扣留货物。因此,获得“受理通知书”并在到期前完成必要的现场或文审是确保供应连续性的关键。

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