Malaysia–China reliance, as MDA published it.
MDA and China’s NMPA signed an MoU in November 2023 and have run two short pilots since: IVD reliance in 2025 and joint evaluation in 2026. Here is who could apply, what MDA asked for, how the pilots differ from the HSA route, and which route an NMPA-approved device takes today.
Where things stand on 8 October 2026.
Both Malaysia–China pilots have closed. Phase 1, the Malaysia–China Medical Device Regulatory Reliance Programme, ran from 30 July to 30 September 2025 and covered IVDs only. Phase 2, the Malaysia–China Joint Evaluation Pilot Programme, ran from 1 July to 30 September 2026. MDA has not announced a further phase. NMPA is not one of the recognised regulators for MDA’s ordinary verification route (MDA/GD/0070, Annex 1), so a device whose only approval is Chinese goes through full conformity assessment by a registered conformity assessment body. If the same device also holds a recognised approval, such as an EU notified-body certificate or FDA 510(k), it can use the verification route on that approval instead.
How the programme developed
| Date | What happened |
|---|---|
| November 2023 | MDA and China’s National Medical Products Administration (NMPA) sign a Memorandum of Understanding |
| 16 July 2025 | MDA press release launches the Medical Device Regulatory Reliance Programme between Malaysia and China at HIMSS APAC 2025 in Kuala Lumpur |
| 30 July – 30 September 2025 | Phase 1: mutual reliance on pre-market decisions for IVDs |
| 15 June 2026 (posted 29 June) | MDA notice announcing Phase 2, the Joint Evaluation Pilot Programme |
| 1 July – 30 September 2026 | Phase 2: simultaneous assessment by MDA and NMPA of devices new to both markets |
| 8 October 2026 | No further phase announced |
Phase 1 (2025): reliance for IVDs
MDA described Phase 1 as the first reciprocal regulatory arrangement of its kind, under the Global Harmonization Working Party (GHWP) framework. Both authorities agreed to recognise each other’s regulatory decisions for in vitro diagnostic (IVD) medical devices. The press release said Chinese IVDs could use Malaysia’s verification pathway and Malaysian IVDs qualified for China’s Green Channel, with approval timelines reduced to 30 and 60 working days respectively.
| Requirement | Chinese-made IVDs (into Malaysia) | Malaysian-made IVDs (into China) |
|---|---|---|
| Pathway | Malaysia’s verification pathway | China’s Green Channel |
| Manufacturer | Based in China; owns and operates its facility in China | Based in Malaysia; owns and operates its facility in Malaysia |
| Excluded | Third-party brand owners (rebranders, relabellers, assemblers) | |
| Approval relied on | Class II approved by a provincial MPA, or Class III approved by NMPA | Class B, C or D approved by MDA |
| Priority | Rare diseases and innovative medical devices | Not stated |
| Application limit | 6 applications | |
The Malaysian side of Phase 1 followed MDA’s verification process:
- The Chinese manufacturer appoints a licensed local authorised representative; the AR must hold a valid MDA establishment licence.
- The AR emails the pre-market documentation to MDA (cab.registration@mda.gov.my) for eligibility screening.
- MDA appoints a CAB with the relevant technical code to carry out the verification assessment under MDA/GD/0068.
- The CAB issues its certificate and report.
- The AR applies for registration through MeDC@St, following MDA/GD/0070.
- MDA evaluates the application and issues the registration certificate; the device is listed on the Medical Device Register (MDAR) for 5 years.
Phase 2 (2026): joint evaluation
Phase 2 ran under the GHWP Common Evaluation Reliance Practice (CERP) framework. Instead of relying on an existing approval, MDA and NMPA assess the same device collaboratively and at the same time, so it was aimed at devices not yet registered in either country.
| Requirement | Malaysian-made devices | China-made devices |
|---|---|---|
| Pathway named by MDA | Full conformity assessment | Special Channel Pilot Programme |
| Manufacturer | Based in Malaysia; owns and operates the manufacturing facility | Based in China; owns and operates the manufacturing facility |
| Device classes | Class B, C or D (general device or IVD) | Class II or III (general device or IVD) |
| Prior registration | Must not hold a registration certificate in Malaysia or China | |
| Submission authority | MDA | NMPA |
| Excluded | Third-party brand owners, including rebranders, relabellers and contract assemblers | |
MDA’s Appendix 1 sets out the Malaysian-side process for a local manufacturer: hold a valid MDA establishment licence, send the pre-market documentation to MDA for screening, have the CAB MDA identifies carry out a full conformity assessment under MDA/GD/0031, apply in MeDC@St, and receive a 5-year registration, while submitting to NMPA in parallel. For China-made devices the notice names NMPA as the submission authority and does not set out the Malaysian steps. It publishes no timeline, application limit or priority list for Phase 2.
What MDA asked for in both phases
Only complete applications were processed. The screening package was:
- QMS: ISO 13485, MDSAP, FDA QSR (21 CFR Part 820) or Japan MHLW Ordinance 169.
- Device information: name, intended use, classification, rule and grouping (see our classification and grouping guides).
- CSDT documentation: executive summary, essential principles (EPSP), design verification and validation summary, pre-clinical and software validation studies, clinical performance, labelling, IFU and brochures, risk analysis and manufacturing information. Our CSDT page covers the format.
- Post-market surveillance system information.
- Declaration of Conformity.
- Phase 1 only: the Class II registration certificate from the provincial MPA or the Class III certificate from NMPA.
The routes compared
| Route | Which devices | What the CAB does | Status (Oct 2026) |
|---|---|---|---|
| Full conformity assessment | Class B–D with no approval from a recognised regulator, including devices approved only by NMPA | Assesses the full CSDT dossier | Open |
| Verification (MDA/GD/0070) | Class B–D approved by an EU notified body, Japan MHLW, TGA, Health Canada, US FDA, UK MHRA, Singapore HSA or Thai FDA | Verifies the recognised approval | Open |
| Singapore HSA reliance | Class B–D on the Singapore Medical Device Register | Verifies the HSA approval; CAB review 30 working days vs 60 for full assessment (MDA–HSA, 22 Aug 2025) | Permanent since 1 March 2026 |
| China Phase 1 reliance | Chinese-made IVDs approved by a provincial MPA (Class II) or NMPA (Class III) | Verifies the Chinese approval | Closed 30 September 2025 |
| China Phase 2 joint evaluation | New general devices and IVDs, not registered in Malaysia or China | Full conformity assessment, run alongside NMPA’s review | Closed 30 September 2026 |
Every route ends in the same place: a MeDC@St application by a licensed Malaysian establishment and a 5-year registration. Published review times for each route are on our registration timeline page.
What a Chinese manufacturer needs on any route
- A Malaysian authorised representative with a valid MDA establishment licence to hold the registration; see our authorised representative service and the MDA establishment licence guide.
- The Malaysian class and rule for the device. MDA’s notices set Chinese Class II and III beside Malaysian Classes B to D, but the Malaysian class comes from the First Schedule rules, so classify the device under those rules rather than translating the Chinese class.
- A CSDT dossier, a Declaration of Conformity in the Malaysian format and a current QMS certificate.
- Your own facility. Both pilots excluded OEM brand owners, rebranders, relabellers and assemblers, so if a future phase follows the same rules, the legal manufacturer must also be the one making the device.
If you would rather work in Chinese, see our Chinese-language page.
Our reading of the pilots
- The windows were short. Each phase accepted applications for two to three months, and Phase 1 capped applications at six. Plan the Malaysian launch on an open route, and treat a future pilot as a bonus.
- A recognised approval is the practical shortcut today. If the device already holds an EU notified-body certificate, FDA clearance or another approval listed in MDA/GD/0070 Annex 1, the verification route is open now.
- Keep the dossier pilot-ready. The screening package above is the same content a full conformity assessment needs, so the work is not wasted if no further phase opens.
Adakah MDA menerima kelulusan NMPA China untuk pendaftaran peranti perubatan?
Tidak secara sendiri setakat 8 Oktober 2026. NMPA tidak tersenarai sebagai pihak berkuasa yang diiktiraf untuk laluan verifikasi (MDA/GD/0070, Lampiran 1). Kelulusan China hanya diterima dalam Fasa 1 program kebergantungan Malaysia–China (30 Julai hingga 30 September 2025) untuk peranti IVD buatan China. Fasa 2, penilaian bersama MDA dan NMPA, berlangsung dari 1 Julai hingga 30 September 2026 untuk peranti yang belum berdaftar di kedua-dua negara. Pengilang China tetap memerlukan wakil sah tempatan yang memegang lesen establismen MDA. WhatsApp 010-206 2070.
Frequently asked questions
Does MDA accept NMPA approval for medical device registration?
Is the Malaysia–China pilot still open?
What is the difference between Phase 1 and Phase 2?
Could OEM, rebranded or relabelled devices use the programme?
Does a Chinese manufacturer still need a Malaysian authorised representative?
How fast was the China reliance route?
Our device has NMPA approval and a CE certificate. Which route applies?
NMPA-approved and planning Malaysia?
Send us the NMPA or provincial MPA certificate, any CE, FDA or HSA approvals, and the device list. We will tell you which MDA route is open now, act as your licensed authorised representative, and prepare the CSDT and Declaration of Conformity for the CAB.