a) Reclassification of Medical Devices
The NMPA implements a classification catalogue system for medical devices under the guidance of the medical device classification rules. The classification of specific products is primarily based on the Medical Device Classification Catalogue. The Medical Device Classification Rules are used to guide the principles for classification determination as well as the formulation and adjustment of the Medical Device Classification Catalogue.
The NMPA has recently issued a draft to revise the existing medical device classification rules to better align with current technological advancements and international standards.
b) Clinical Evaluation Exemptions (CEE) Expansion
The NMPA continues to expand its CEE list, exempting more devices from local clinical trials if sufficient overseas data or predicate device comparison is available. However, exemption is not guaranteed and requires careful justification.
c) Unique Device Identification (UDI) Rollout
China’s UDI system is based on global principles (similar to EU and FDA), but requires separate submissions in the NMPA’s platform.
d) Electronic Submission & e-RPS
The shift toward a fully electronic registration system (e-RPS) is gaining speed. This system streamlines submission of dossiers, but introduces formatting and platform-specific requirements unfamiliar to some foreign firms.
e) More Emphasis on Post-Market Surveillance
China is tightening expectations around post-market vigilance, traceability, and adverse event reporting. NMPA has published several new guidance documents on supplier control, adverse event response, and field safety corrective actions (FSCAs).
e) Equal participation in government procurement
In 2025, China announced that products produced by enterprises of different ownerships within China participate equally in government procurement activities.