Japanese Medical Device Regulatory Authorities

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Most devices fall under Class II, with a small number classified as Class III. Certification is issued by Registered Certification Bodies approved by the Ministry of Health, Labour and Welfare. The following are some of the more representative organizations.

Official Website of Japan's PMD Act:https://www.japaneselawtranslation.go.jp/ja/laws/view/3214

Certified Certification Bodies (J-RCBs) in Japan

Most of them are authorized for Class II medical devices under technical standards, while a small number cover Class III devices. Certifications are issued by Registered Certification Bodies (RCBs) approved by the Ministry of Health, Labour and Welfare (MHLW). Below are representative institutions of this type.

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Regulatory Framework

Pharmaceutical and Medical Device Act, abbreviated as the PMD Act.

Risk Level Classification

Medical devices in Japan are classified into four risk classes: I, II, III, and IV, arranged from lowest to highest risk.

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Applicant/Certificate Holder

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Registration Language

Japanese.

Registration Process, Timeline, and Official Fees

1. Class I Medical Device Notification Process

Preparation of product notification application materials

Submission of application to the PMDA

PMDA acceptance and stamping

2. Class II/Class III Medical Device Certification Process

(1) Product Approval

Preparation of Application Materials (Requires preparation of Annexes 1–7 and various supplementary documents, including intended use, design principles, raw materials, performance and safety, instructions for use, and accompanying documents)

Submission of Application Materials

Corrective Actions Based on Instructions from the Certification Authority

Completion of Approval

(2) QMS (Quality Management System) Audit

Submission of Audit Documentation (Including ISO 13485 certification, annual audit reports, and the QMS manual)

Documentary Review (if ISO 13485 certification is held)

QMS Audit of the Chinese Manufacturer and the Importing Company (QMS review is also required for Japanese warehouses)

Revision of the QMS Manual and Records

Documentary Review or On-site Audit

Implementation of corrective actions based on the certification body’s instructions

Completion of Approval (based on PMDA’s comprehensive assessment)

3. Approval Process for Class 2/Class 3 Devices Without Reference Standards and Class 4 Medical Devices

Preliminary Communication: Various meetings with PMDA to determine the application category, the need for clinical trials, and the availability of relevant reports; competitive product comparisons may be conducted; if clinical trials are required, they will be conducted (some steps may be omitted).

Product Approval: Preparation of application materials → Submission of application materials → Correction of issues raised by PMDA → Completion of approval.

QMS Audit: Process as described above for QMS review

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Review Timeline
The following are estimated average completion times under different scenarios (after submission to the reviewing authority):
Class I – Notification Filing: 0 days
Class II – Certification: 4–9 months
Class III – With certification standards, no clinical trials: 9–12 months
Class III – No certification standards, no clinical trials: 12 months (me-too generic) or 15 months (improved)
Class III – No certification standards (improved), with clinical trials: 16 months
Class III – No certification standards (new), with clinical trials: 16 months
Foreign Manufacturer Registration (FMR): 1–2 months
Medical Device Quality Management System (QMS): Approximately 75 days

Official Fees
Fees charged by J-RCB certification bodies: Vary by institution and product; fees for a single product may range from 1 million to 1.5 million yen

Labeling | Packaging Requirements

Article 63 of the PMDA Act stipulates that the immediate container or packaging of a medical device must bear the following information:
① Name and address of the marketing authorization holder
② Product name
③ Lot number or manufacturing code
④ Weight, volume, quantity, etc., of the contents for medical devices designated by the MHLW
⑤ Standard items for medical devices as specified in relevant provisions
⑥ Expiration date for medical devices designated by the MHLW

Determination of Clinical Trial Requirement

Whether a clinical trial is required is determined based on the product’s innovativeness, degree of modification, and differences from existing similar devices. The specific classifications are as follows:
Clinical trial required: New devices, devices with significant differences after modification (Differences C and D), and products requiring clinical evaluation by users.
Clinical trial not required: Devices with no substantial differences after modification (Difference B), follow-on products (substantially equivalent), and non-clinical

七、FAQ

Q: What issues should be paid attention to after the approval of medical devices?

A: Medical device registration does not expire, but registrants are required to renew their QMS certificate every 5 years, and registrants are required to initiate the renewal process six months in advance.

Q: Does it require a QMS certificate for medical device registration in Japan?

A: Class I product is not required; Class II and above level need, the basic requirements are the same as ISO 13485. In addition to directly providing ISO 13485 certificate and annual audit report, but also need to accept the Japanese regulatory authorities QMS system document audit.

Q: How to register medical devices without a company in Japan?

A: It is acceptable to cooperate with Japanese import agents and entrust agents to help complete the procedures of product certification. Wiselink JP Co., Ltd. can serve as the Japanese DMAH of Chinese manufacturers to help Chinese manufacturers complete foreign manufacturer login, product compliance registration and customs clearance import services.

Q: The manufacturer does not have ISO13485 system certificate, is it acceptable to use MDSAP certificate?

A: Agreed. Japan is one of the five MDSAP countries (Australia, the United States, Canada, Brazil, Japan).

Q: How to determine whether a medical device is a specific conservative device in Japan?

A: Medical devices in Japan are divided into general devices, specific conservative devices, benchmarking, non-benchmarking devices and other categories. If you want to confirm the registration approach of devices in Japan, you can contact the business manager of Wiselink for inquiry.

八、Certificate Template

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