Listing Procedures for Local Medical Device Manufacturers in Hong Kong: A Guide to GN-08

Listing as a Local Medical Device Manufacturer in Hong Kong: Our Insights from GN-08

For manufacturers right here in Hong Kong who produce medical devices, the Medical Device Administrative Control System (MDACS) offers a voluntary listing scheme. What does this mean for local medical device manufacturing? It means there's a clear pathway to show your commitment to quality. The specific guidelines for local manufacturers are clearly laid out in the "Guidance Notes for Listing of Local Manufacturers of Medical Devices" (GN-08). This document, to our understanding, outlines the key criteria and steps for local manufacturing businesses to prove their dedication to producing safe and reliable medical devices in Hong Kong.

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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!

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Who is a Local Manufacturer in the MDACS Context?

Under the MDACS, a "Local Manufacturer" refers to a company or entity that actively makes medical devices right here in Hong Kong. What does this manufacturing process typically involve? From our perspective, it includes everything from the initial design and production to the packaging and labeling of medical devices before they are officially put on the market under that manufacturer's own name. This definition helps clarify Hong Kong medical device manufacturing responsibilities.

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Why Should a Local Manufacturer Get Listed? (Eligibility and Benefits)

Any legal company with a valid Business Registration Certificate and a manufacturing facility located in Hong Kong, producing medical devices covered by MDACS, can apply to be added to "The List of Local Manufacturers." While listing is voluntary, according to our experience, it offers some really significant benefits:

• Enhanced Reputation: Being a listed manufacturer clearly signals to hospitals, clinics, regulators, and even the general public that you meet recognized quality and safety standards. It builds trust.
• Facilitated Market Access: From what we've seen, being on this list can genuinely make it easier for your products to be accepted by local hospitals and distributors. This is especially true because public healthcare bodies are increasingly looking for and preferring MDACS-listed products and companies when they buy medical equipment.
• Contribution to Public Health: By participating in the MDACS, local manufacturers play a vital role in a strong system designed to protect public health through careful control of medical devices. This is a key aspect of regulatory compliance in Hong Kong for manufacturers.

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Key Requirements for Local Manufacturers: Our Insights on Quality

To get your Hong Kong medical device manufacturing operation listed under MDACS, you need to show you meet specific requirements, with a very strong focus on how you manage quality. What's the most important requirement?

• Valid Business Registration Certificate: This is straightforward – you need proof that your business is legally registered in Hong Kong.
• Certified Quality Management System (QMS): This, in our opinion, is the absolute paramount requirement. The manufacturer must have a well-established and officially certified QMS. What does that mean in simpler terms? It means you have a robust system in place to control the quality of your products every step of the way, usually following international standards like ISO 13485. This certification covers all stages: from designing and developing the device, through production, and even after it's sold (post-market activities).
• Documented Procedures: You must create, follow, and keep updated a set of written procedures that cover all the critical parts of your manufacturing work. This includes, but isn't limited to:
  • Quality Management: Steps to ensure the overall quality and safety of your devices throughout their entire lifespan.
  • Manufacturing Control: Procedures to keep your manufacturing process consistent and ensure products meet their specifications.
  • Product Realization: How you design, develop, produce, and service your products, plus how you control your testing and measuring equipment.
  • Traceability: A system to track all raw materials, components, and finished medical devices. According to our experience, this is vital for quick recalls if ever needed.
  • Complaints Handling: Steps for receiving, checking, investigating, and responding to any complaints you get.
  • Adverse Event Reporting: Procedures for finding and reporting any unexpected or harmful incidents related to your medical devices to the MDD.
  • Product Recall and Field Safety Corrective Actions: Clear steps for managing and carrying out product recalls and safety corrections efficiently.
• List of Medical Devices Manufactured: You need to provide a complete list of all the medical devices you make and plan to sell.

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The Application Process: What to Expect from Our Experience

The application process for getting your local medical device manufacturing operation listed typically involves these steps:

1. Application Form Submission: You submit the specific application form (e.g., MD-M) to the Medical Device Division (MDD). Is it better to submit online or on paper? While paper submissions are accepted, our advice is generally to use the online Medical Device Information System (MDIS) as it often makes the process smoother.
2. Supporting Documentation: You'll need to provide all the required supporting papers. What kind of documents are these? Copies of your valid Business Registration Certificate, your QMS certification (like the ISO 13485 certificate), copies of all your written procedures, the list of medical devices you manufacture, and any other information or samples the MDD might ask for during their review.
3. MDD Assessment: The MDD will review your application and all the supporting documents. What might this involve? It could include a close look at your QMS documents and potentially even on-site visits or inspections to verify you're meeting MDACS requirements. From what we've seen, the MDD might ask for more details or clarifications during this stage, so being prepared to respond quickly is important.
4. Listing Approval: If everything is assessed successfully, your local manufacturing company will be added to "The List of Local Manufacturers," which anyone can find on the MDD website. You'll also receive an official listing certificate. This is a key step in medical device registration Hong Kong.

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Ongoing Responsibilities: Staying Compliant

From our perspective, getting listed is a significant achievement, but it's not a one-time thing. Once you're on the list, local manufacturers have an ongoing duty to maintain their certified QMS, continuously follow their documented procedures, and promptly tell the MDD about any changes to their business information, manufacturing methods, or the medical devices themselves. Why is this commitment to continuous compliance so fundamental? Because it's what ensures the ongoing safety, quality, and effectiveness of medical devices made in Hong Kong, ultimately benefiting public health.