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。
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March 10, 2025
Approximately 5 minutes
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:
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:
Source: Attached PDF—Article 1 (Purpose)
The Notice applies to medical devices as defined by law. It also clarifies that:
Source: Attached PDF—Article 3 (Scope)
The Notice states it took effect on November 13, 2023.
Source: Attached PDF—Addenda
MFDS designates and manages quality management audit agencies (i.e., organizations that conduct GMP audits). The Notice provides requirements such as:
Source: Attached PDF—Articles 7 & 12
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
The regulation classifies GMP audits into (at least) the following types:
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)
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)
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
To apply for GMP suitability recognition, the applicant submits:
The Notice also provides supplementation procedures if the submission is incomplete.
Source: Attached PDF—Article 5 & supplementation
Operationally important deadlines include:
Source: Attached PDF—Article 9 (Processing timelines)
A GMP certificate is issued with a validity period of 3 years.
Source: Attached PDF—Article 8(9)
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)
Primary legal text reference: Korean Law Information Center—Medical Devices Manufacturing and Quality Control Standards
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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。
Anonymous
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.
cindyhsu
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。
Anonymous
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)
edisonchen
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。
Approximately 5 minutes
An MFDS overview of South Korea’s premarket pathways (notification, certification, approval), the required technical documentation (including SER when clinical trial reports are needed), review timelines, business licensing for manufacturers/importers, and tracking-control obligations for high-risk devices.
Approximately 5 minutes
MFDS (Korea) and HSA (Singapore) jointly issued guiding principles (first released Dec 11, 2024) to address MLMD-specific clinical study challenges, covering trial design, dataset representativeness and independence, reference standards and adjudication, and endpoint analysis with justified acceptance criteria.
Approximately 5 minutes
A practical summary of South Korea’s MFDS UDI Management Regulations: what manufacturers/importers must register in the UDI system (UDI-DI, barcode standard, product and company data), optional fields, exemptions, how and when to register updates, confidentiality, and the phased enforcement timeline by device class.
Approximately 5 minutes
This guidance explains how South Korea expects in vitro companion diagnostics (IVD-CDx) to be developed, labelled, and supported with analytical and clinical performance evidence for conformity assessment—including scenarios such as follow-on tests, new specimen types, and class/group labelling.
Anonymous
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?