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Quality Management System Compliance with Japan Ordinance 169

Emergo can assist medical device companies with QMS compliance including Japan Ordinance 169 and the pharmaceuticals and medical devices Act (PMD Act).

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  • What are the QMS requirements in Japan?
  • How do QMS requirements differ for domestic vs. foreign manufacturers?
  • How do we comply with the PMD Act and Ordinance 169?

MHLW Ministerial Ordinance #169

Japan's PMD Act ("Act on Securing Quality Efficacy and Safety of Pharmaceuticals, Medical Devices, Regenerative and Cellular Therapy Products, Gene Therapy Products, and Cosmetics") was issued by the Ministry of Health, Labour, and Welfare (MHLW) in 2014. Under the PMD Act, the MHLW was issued MHLW Ministerial Ordinance #169, which defines quality management system (QMS) requirements for medical device manufacturers selling their devices in Japan. MHLW Ministerial Ordinance #169 consists of specific requirements for domestic and foreign manufacturers, which harmonized QMS requirements with ISO 13485:2016.

Relationship between Ordinance #169 and ISO 13485:2016

Japan has largely embraced ISO 113485:2016 as the basis for its QMS requirements. The PMD Act introduced a more harmonized approach to quality regulations for medical device manufacturers. However, Ministerial Ordinance #169 contains additional QMS requirements you must meet to be in full compliance. Manufacturers with ISO 13485 certification will find compliance with Ordinance #169 is fairly straightforward by adjusting some gaps between ISO 13485 and Ordinance #169.

QMS audits

According to the PMD Act, manufacturing facilities are subject to a QMS conformity investigation as part of the Japanese registration process. QMS conformity assessments are conducted by the Pharmaceuticals and Medical Devices Agency (PMDA) or a Registered Certification Body (RCB). Foreign manufacturers will undergo QMS conformity investigation with involved license holders, including Marketing Authorization Holder (D-MAH), and others. 

QMS conformity investigation certification

Upon successful completion of a QMS conformity investigation, a MAH or manufacturer is issued a Certificate of QMS Conformance (Kijun Tekigoshou) by either the PMDA or RCB. Certificates of conformance are valid for five years and include the registered product name, product group (Seihingun), and manufacturing facility. Under the PMD Act, future conformity assessments focus on devices from the same product group registered with the PMDA or RCB, rather than the manufacturing facility.

Device registration never expires, regardless of the registration routes. Instead, the Manufacturer is required to renew its Certificate of QMS Conformance every five years and maintain it to continue marketing and commercial distribution in the market.

We can assist with Ordinance 169 compliance in Japan

Emergo understands how the QMS requirements in Japan, Europe, Korea, Canada, and the US overlap and differ from one another. Armed with this insight, we can assist you in meeting Japan's quality system requirements so you can begin the process of obtaining certification from a RCB or the PMDA. We will:

  • Review your quality manual and prepare a gap analysis with references to the appropriate clauses of Ordinance #169.
  • Create and propose changes needed to meet the Japan QMS regulation, including preparation of the Device Master File.
  • Prepare supplemental documents as an appendix of the quality manual.
  • Conduct a mock audit of your quality system prior to your PMDA conformity assessment.
  • Prepare the QMS Conformity Assessment application on your behalf.

Emergo can also assist with MDSAP compliance, including in Japan

Emergo has successfully implemented medical device quality management systems (QMS) in all MDSAP participating markets. We can help you adapt your QMS to meet MDSAP audit requirements.

Learn more

Please contact us for more information about QMS consulting for Japan and markets worldwide

Emergo by UL can provide eQMS support in strategic alliance with Greenlight Guru. This helps you leverage an eQMS system designed specifically for the medical device industry. Ask us to schedule a demo so you can explore a software solution that connects with your processes, people, and data.

Looking for Greenlight Guru eQMS information?

Common Questions about Ordinance 169 Compliance

Is our existing ISO 13485 certification accepted as proof of compliance?
An ISO 13485 certificate does not prove compliance with Japan's QMS requirements. Japan Ordinance 169 imposes additional requirements for record retention times, MAH-related requirements, etc. Emergo can assess your current system and address any gaps before completing a conformity assessment audit, if one is required.

We are located outside Japan. Will the PMDA or RCB conduct a desktop or on-site audit?
In most cases, PMDA and RCB conduct a desktop audit on manufacturers with ISO 13485 or MDSAP certification. However, they often conduct an on-site audit on manufacturers of biological devices and Remanufactured devices, regardless of a QMS certification. 

What is a Japanese Medical Device Master File?
The Device Master File is one of the key differences between ISO 13485 and Ordinance #169. This document defines the product specifications and QMS requirements (Seihin Hyojun Sho), as well as information about storage, labeling, packaging, testing, and MAH requirements. It is separate from the application file (Todokede, Ninsho, or Shonin) and similar to a European Technical File. The PMDA and RCB are very particular about the content of the Device Master File. Supporting documents and details must be consistent with the information submitted for the Todokede, Ninsho, or Shonin - even the smallest differences can cause delays.

Within the UL Solutions family of companies, we provide a broad portfolio of offerings to all the Medical Device industries. This includes certification, notified body and consultancy services In order to protect and prevent any conflict of interest, perception of conflict of interest and protection of both our brand and our customers' brands UL Solutions is unable to provide consultancy services to Notified Body or MDSAP customers. UL Solutions has processes in place to identify and manage any potential conflicts of interest and maintain impartiality.


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