PMDA Medical Device Registration and Approval in Japan

ANSWERED ON THIS PAGE:

• What is the classification scheme for medical devices?
• What are the registration procedures in Japan?
• How do regulatory requirements differ for domestic vs. foreign manufacturers?

Japan is considered one of the more challenging markets for foreign medical device manufacturers due its complex registration process and language barriers. But once you understand the device registration process, you will see it is actually not complicated and the rewards are worth the effort. Japan's lucrative medical device market is still the second largest in the world, ahead of China and Germany.

The Japanese regulation and approval process

Medical device companies interested in offering their products in Japan must comply with Japan's Pharmaceuticals and Medical Devices Act (PMD Act). Complying with the PMD Act can be challenging for foreign manufacturers, as very few regulatory documents are published in English.

As part of the approval process, medical device manufacturers must:

• Comply with MHLW Ordinance No. 169 related to quality management systems
• Appoint an in-country representative (MAH/D-MAH)
• Register design and manufacturing facilities, among other requirements

Registration procedures for medical devices sold in Japan

The registration pathway for your device is determined by its classification and associated Japan Medical Device Nomenclature (JMDN). For a detailed explanation of the process, download our Japan regulatory process chart (English) or watch this video.

To market medical devices in Japan, your Marketing Authorization Holder (MAH) must register your device through one of the following procedures. Emergo can assist you with any medical device approval in Japan, regardless of classification or JMDN code.

Pre-market submission (Todokede)
Emergo can help register General Medical Devices (Class I) and file a pre-market submission to the PMDA. This is a notification and no review/assessment by the PMDA will be conducted.

Pre-market certification (Ninsho)
Class II (and a limited number of Class III) devices which have an associated certification standard (JIS), are subject to pre-market certification. Many, but not all, Japan Industrial Standards are based on existing ISO/IEC standards. Your MAH will file your application with a Registered Certification Body (RCB). The process is similar to the European CE Marking process where reviews are outsourced to a third party similar to a Notified Body.

Pre-market approval (Shonin)
Class II and III devices without a specific certification standard, are subject to the pre-market approval process. This also applies to all Class IV devices. In this case your MAH will file a pre-market approval application with the PMDA and ultimately obtain approval from the MHLW.

Let Emergo assist you with PMDA medical device registration

With an experienced team in Tokyo, Emergo can assist your company with all aspects of the medical device registration process in Japan. Here's how we can help:

• Device classification: We will assess the classification for your medical device.
• Documentation preparation: Emergo can prepare all necessary documentation for pre-market submission, certification, and approval, and coordinate the submission to the PMDA or the RCB.
• QMS consulting and implementation: Our quality consultants are experts in Ministerial Ordinance #169 and ISO 13485. We can help you comply with QMS regulations in Japan.
• Clinical consulting: Emergo can assist with the PMDA pre-submission consultation process if you need to confirm the necessity of clinical data, additional clinical trials, or the validity of your protocol for clinical trials and/or other testing.

Emergo's team in Tokyo has worked on hundreds of PMDA medical device and IVD submissions so we fully understand the process and how to get your device approved as efficiently as possible. Please contact us for more information on obtaining medical device approval in Japan.