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ACT 737 · Mandatory for foreign manufacturers

Your company in Malaysia, without opening a company in Malaysia.

Foreign manufacturers cannot register devices with the MDA directly — Act 737 requires a locally incorporated authorized representative. We already hold our own MDA establishment licence (MDA-6798-K124), so we can be your AR and licence holder from day one: registrations held in trust, licence maintained, vigilance and recalls answered.

01 MDA Registration02 GDPMD + Licensing03 ISO 13485 QMS04 MDSAP05 CE / FDA Export
What an authorized representative is

The licence holder foreign makers must appoint

Under the Medical Device Act 2012 (Act 737), a manufacturer with no legal presence in Malaysia cannot register a device or place it on the market by itself. It must appoint a locally incorporated authorized representative (AR) — the entity that holds the MDA establishment licence, lodges the CSDT dossier through MeDC@St, coordinates the CAB conformity assessment, and stands as MDA’s duty-holder for vigilance and recalls. The AR is not paperwork you file once; it is a standing legal role that lives for as long as your devices are on the Malaysian market.

As your AR, AA Alive Sdn Bhd holds the establishment licence and GDPMD certification the role requires, and carries the duty-holder obligations under Act 737 on your behalf. Because we already hold our own licence (MDA-6798-K124) and run the same GDPMD system we build for clients, you are appointing a licensed establishment that exists today — not one still being assembled.

Verifiable trust signal: AA Alive holds MDA establishment licence MDA-6798-K124. We hold the licence we help you get — you can confirm it before you appoint us as your AR.

Keep regulatory custody separate from sales

The AR decision is strategic, not administrative. Whoever holds your Malaysian registrations controls your market access: if that is a distributor and the relationship sours, your products can be stranded mid-tender while registrations are untangled. An independent AR — a consultancy whose only role is regulatory custody — means you can appoint, add or replace distributors as pure commercial decisions, with a contractual transfer path that keeps the registrations yours.

It also runs the other way. For a Malaysian manufacturer exporting into the EU, an EU authorized representative is the mirror requirement — a European-based representative the CE marking route depends on. We coordinate that appointment too, so one consultant covers both directions of trade.

What the appointment covers

What the AR retainer covers

  • Device registrations held in trust — with a contractual transfer path that protects you
  • Establishment licence and GDPMD maintained continuously under our own licence
  • Vigilance contact: complaint intake, mandatory problem reporting to MDA
  • Field safety corrective action and recall coordination with your distributors
  • Renewal calendar for every registration and certificate we hold
  • MDA correspondence and inspection support

Engagement path

  1. Scope & structure — we map your portfolio, confirm device classes and set the AR structure, including any transfer from a current AR.
  2. Licence & GDPMD — the AR + Importer + Distributor package puts the establishment licence and GDPMD certification in place (or confirms ours already covers you).
  3. Register the portfolio — CSDT dossiers, CAB conformity assessment and MeDC@St submission for each device, held under our AR licence.
  4. Ongoing representation — vigilance, recalls, renewals and MDA correspondence run on an annual retainer for as long as you sell in Malaysia.

Pricing — published package, recurring role

Market entry is priced as our fee, with the CAB and MDA fees you pay direct listed separately; the ongoing AR role is the recurring layer that keeps your registrations alive.

FOREIGN MANUFACTURERS

GDPMD + AR, Importer, Distributor licences

RM5,500 our fee, year 1
  • GDPMD certification + licence submissions for all three roles via MeDC@St
  • Paid direct to the CAB: GDPMD audit RM4,785 per warehouse
  • Paid direct to MDA: each role's licence fee — distributor RM2,250; AR and importer licences carry their own MDA fees
  • Payment plans from RM1,500/month
Start market entry
PER DEVICE

Device registration

RM3,800–12,000/device
  • Class A RM3,800 · Class B RM6,800 · Class C RM9,800 · Class D RM12,000
  • All-in: CSDT dossier, CAB and MDA fees included
  • Held under our AR establishment licence
Register my devices
RECURRING

GDPMD surveillance

RM2,500/year, our fee
  • Years 2 and 3 — CAB surveillance audit RM2,585/year, paid direct
  • Every 3 years: re-certification (our fee RM5,500; CAB RM4,785 paid direct) and licence renewal (MDA fee paid direct)
  • Registrations RM6,000/5yr, CAB and MDA fees included
  • Renewal calendar for the whole portfolio
Keep my portfolio alive

Ongoing AR representation runs as an annual retainer scaled to portfolio size and vigilance workload — quoted in the same written proposal, not a fixed shelf price. Per-device registration fees above are all-in (CAB and MDA fees inside); for GDPMD and the licences, the CAB and MDA fees are paid direct, as listed. See the full schedule on pricing.

Jawapan ringkas · Bahasa Malaysia

Apakah Wakil Sah (Authorized Representative) dan mengapa pengeluar asing memerlukannya?

Wakil Sah (Authorized Representative) ialah entiti yang diperbadankan di Malaysia yang wajib dilantik oleh pengeluar peranti perubatan asing di bawah Akta 737 — ia memegang pendaftaran peranti dan lesen establishmen MDA, serta menjadi hubungan MDA untuk vigilans dan penarikan balik. AA Alive Sdn Bhd sudah memegang lesen establishmen MDA sendiri (MDA-6798-K124), jadi kami boleh bertindak sebagai Wakil Sah anda dari hari pertama. Yuran kami untuk GDPMD dan lesen Wakil Sah, Pengimport dan Pengedar ialah RM5,500; audit CAB (RM4,785 setiap gudang) dan fi lesen MDA bagi setiap peranan dibayar terus oleh anda. Tahun pengawasan GDPMD: yuran kami RM2,500 setahun, audit CAB RM2,585 dibayar terus. Pelan bayaran dari RM1,500 sebulan. WhatsApp 010-206 2070 untuk sebut harga bertulis.

2026 · What changed for foreign manufacturers

Two rule changes that land on your AR, not on you.

The Singapore reliance route. Since 1 March 2026, Class B–D devices already listed on the Singapore Medical Device Register can clear Malaysian conformity assessment through the Verification Route under MDA/GD/0070. If you sell in Singapore already, your Malaysian entry got cheaper — but the route shortens the dossier review only. It does not waive the AR requirement, because Act 737 still requires a locally incorporated entity to hold the registration. Details on our Verification Route guide.

The import permit. Enforcement moved from 2 January 2026 to 1 July 2027. When it starts, permits are lodged per shipment through ePermit by the licensed importer — which, for most foreign manufacturers, means us. It is one more operational duty that sits with your Malaysian representative rather than with your head office. See the import permit guide.

Who holds your licence

You’ll deal with named people, not a mailbox company.

AA Alive’s medical-device regulatory team
AA Alive’s device regulatory team, on client visits across Malaysia.
Founder & Managing Director · Regulatory authority

Evin Lim

Advises from the operator’s chair — the group registers, imports and supplies devices itself — and speaks on the Malaysian pharmaceutical and device industry on BERNAMA TV and RTM.

LinkedIn profile
Commercial Lead · Your first contact

Lim Yen Thong

Your first point of contact for scope, timelines and quotations. Lim Yen Thong runs the commercial side of the device practice and coordinates every engagement from first enquiry to signed proposal.

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FAQ

Frequently asked questions

Why does a foreign manufacturer need an authorized representative?
Act 737 requires devices from manufacturers with no legal presence in Malaysia to be registered through a locally incorporated authorized representative (AR). The AR holds the device registrations, maintains its own establishment licence, submits the CSDT dossier through MeDC@St, and is MDA’s point of contact for vigilance and recalls. No AR, no market access.
Do you hold your own MDA establishment licence?
Yes — AA Alive Sdn Bhd holds its own MDA establishment licence (MDA-6798-K124) and runs the same GDPMD system we build for clients. That matters for an AR: we already are a licensed establishment, so we can carry your registrations under a licence that exists today rather than one we still have to build after you sign. It is also verifiable — you can confirm the licence before you appoint us.
Should my distributor be my AR?
It is common — and it is the most frequent regret we see. If your distributor holds your registrations, your registrations are hostage to that commercial relationship: change distributors and you may face re-registration. An independent AR separates regulatory custody from sales, so you can add or replace distributors freely.
What does AR service cost?
Market entry: GDPMD certification and the AR, importer and distributor licence submissions at our fee of RM5,500. Paid direct by you, not to us: the CAB’s GDPMD audit (RM4,785 per warehouse) and the MDA licence fee for each role — a distributor licence is RM2,250 (RM250 application + RM2,000 licence); the authorised representative and importer licences carry their own MDA fees. Device registrations are then RM3,800 (Class A), RM6,800 (Class B), RM9,800 (Class C) or RM12,000 (Class D) per device, CAB and MDA fees included. Ongoing AR representation runs as an annual retainer scaled to your portfolio and vigilance workload — quoted in the same written proposal. Maintenance and renewals follow the published schedule: GDPMD surveillance at our fee of RM2,500/yr plus the CAB audit (RM2,585/yr, paid direct); GDPMD re-certification and licence renewal every 3 years; registrations RM6,000 every 5 years. Payment plans from RM1,500/month.
What does the AR role include day to day?
Holding your device registrations and the establishment licence behind them, maintaining GDPMD certification, acting as the vigilance and mandatory-problem-reporting contact, coordinating recalls, tracking renewal deadlines, and representing you in MDA correspondence. It is a continuing legal role, which is why it runs as an annual retainer rather than a one-off fee.
Can you take over from our current AR?
Yes. AR transfers are a defined process — we manage the change notifications and re-issuance so supply is not interrupted. Bring the current registration details to the first call and we will map the transfer path.
Can you arrange an authorized representative for exporting the other way, into Europe?
Yes. An EU authorized representative works the same way in reverse: a manufacturer outside the EU needs an EU-based representative to place devices on the European market. We coordinate that appointment as part of a CE marking (EU MDR) engagement, so a Malaysian manufacturer keeps one consultant across both directions of trade.

Selling into Malaysia from abroad?

Tell us your device portfolio and current setup. We will propose the AR structure, the registration sequence and the annual retainer for your case — under a licence we already hold.

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