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MDA · Circular 2/2025 · MDA/GD/0070 · MDA/GD/0068

The MDA verification route, for devices already approved abroad.

If a Class B, C or D device already holds an EU, FDA, Health Canada, TGA, Japanese, UK, Singapore or Thai approval, a Malaysian CAB can verify that approval instead of assessing the device from scratch. Here is who qualifies, exactly which approvals count, what the CAB checks and what goes into MeDC@St.

01 MDA Registration02 GDPMD + Licensing03 ISO 13485 QMS04 MDSAP05 CE / FDA Export
Short answer

What the verification route is.

Section 7 of Act 737 requires every Class B, C and D device to pass conformity assessment by a registered CAB before MDA registers it. For a device already approved by a regulator MDA recognises, that assessment can be done by way of verification: the CAB verifies the evidence behind the existing approval rather than repeating it. The policy is MDA Circular Letter No. 2 of 2025 (30 September 2025, which revoked Circular No. 1 of 2025). The CAB works to MDA/GD/0068 and the applicant to MDA/GD/0070, both Second Editions, with GD/0070 last revised on 13 October 2025. Class A devices skip the CAB altogether under the Exemption Order 2024; see Class A registration.

The route shortens conformity assessment only. A foreign manufacturer still needs a licensed Malaysian authorised representative, and the registration is still made in MeDC@St and lasts 5 years.

Who qualifies (MDA/GD/0070, Table 1)

PathwayThe device must
Verification, initial certification (new registration)
  • hold an approval from at least one recognised regulatory authority or notified body;
  • have the same design and intended purpose as the approved device;
  • have no safety issues globally in the last year when used as intended: no reported deaths, no reported serious deterioration in anyone’s health, and no open field safety corrective action (including recalls) at submission, with all incident reports and CAPAs closed;
  • not have been rejected or withdrawn by any recognised regulator or notified body.
Verification, recertification (re-registration)
  • be registered with MDA after full conformity assessment or verification;
  • hold a valid registration certificate before the CAB’s recertification assessment;
  • have had no changes in design, specifications, features or registration information unless notified to MDA (see change notification);
  • not have had its registration rejected or cancelled by MDA.
Full conformity assessmentNo approval from a recognised regulator or notified body, or an approval that has since been cancelled or invalidated. See full conformity assessment.

The Second Editions dropped an earlier condition that the device had been marketed for at least one year in the approving jurisdiction.

Which approvals count (MDA/GD/0070 Annex 1)

Recognised regulatorApproval that countsWhat the CAB also asks for
EU notified bodiesEC certificate under the MDD, MDR, AIMDD, IVDD or IVDR annexes in the next tableManufacturer’s declaration of conformity with the certificate
US FDA510(k) clearance or premarket approval (PMA)Checked against the FDA database
Health CanadaHealth Canada licenceChecked against the Health Canada database
Australia TGAARTG registration certificateChecked against the ARTG; manufacturer’s declaration of conformity
Japan MHLWShonin (pre-market approval) from MHLW, or Ninsho (pre-market certification) from a registered certification bodyEnglish translation of the certificate
UK MHRAGreat Britain: UKCA, or EC certificates under the listed EU annexes. Northern Ireland: EC certificates, or UKNI with EC certificates, under the listed annexesAuthenticity and validity of the certificate
Singapore HSARegistration on the Singapore Medical Device Register (SMDR)Checked against the SMDR; manufacturer’s declaration of conformity
Thai FDAClass 2–3: Certificate of Notified Medical Device. Class 4: Certificate of Licensed Medical DeviceEnglish translation; manufacturer’s declaration of conformity

HSA and Thai FDA were added in the Second Editions. The HSA arrangement has its own history and published timings; see the Singapore HSA verification route. China’s NMPA is not on the list; its approvals counted only in the 2025 pilot described in Malaysia–China reliance.

EU certificates: which annexes match which Malaysian class

Malaysian classEC certificate issued under
Class B
  • MDD 93/42/EEC Annex II section 3, or Annex V, for Class IIa
  • MDR Annex IX Chapters I and III, or Annex XI Part A, for Class IIa
  • IVDD 98/79/EC Annex IV, or Annex V with Annex VII, for List B and self-testing IVDs
  • IVDR Annex IX Chapters I and III for Class B IVDs
Class C and D
  • MDD Annex II section 3, or Annex III with Annex V, for Class IIb
  • MDR Annex IX Chapters I and III (with technical documentation assessment for implantables), or Annex X with Annex XI Part A, for Class IIb
  • MDD Annex II sections 3 and 4 for Class III
  • MDR Annex IX Chapters I and III, with technical documentation assessment, for Class III
  • AIMDD 90/385/EEC Annex II sections 3 and 4 for active implantables
  • IVDD Annex IV, including sections 4 and 6, for List A IVDs; Annex IV, or Annex V with Annex VII, for List B and self-testing IVDs
  • IVDR Annex IX Chapters I and III, with technical documentation assessment, for Class D IVDs
  • IVDR Annex IX Chapters I and III, with technical documentation assessment, for companion diagnostics, self-testing and near-patient devices, or Annex X with Annex XI (except section 5), for Class C IVDs

Only notified-body certificates are listed. A device that is self-declared in the EU, such as an EU Class I device that is Class B in Malaysia, has no EU approval to verify and needs another recognised approval or full conformity assessment. Classify the device under the Malaysian rules first; our classification guide covers the First Schedule.

Approvals that do not count (MDA/GD/0070, Table 2)

Special authorisations that let an unapproved device into a market for emergency or compassionate use are excluded, including but not limited to:

  • US FDA: Emergency Use Authorization (EUA), Expanded Access (emergency or compassionate use), Humanitarian Device Exemption (HDE)
  • EU national competent authorities and UK MHRA: exceptional use authorisations
  • Health Canada: Special Access Program; Interim Orders (COVID-19)
  • Japan PMDA: Compassionate Use System; emergency regulatory pathway (COVID-19)
  • Australia TGA: Special Access Scheme, Authorised Prescriber Scheme, emergency exemptions (COVID-19)
  • Singapore HSA: Special Access Routes
  • Thai FDA: exemptions for non-commercial manufacture or import under section 27 of Thailand’s Medical Device Act

MDA’s own equivalent, special access, is likewise an exemption from registration, not a route to it.

What the CAB does (MDA/GD/0068)

  • Who can verify. Any CAB registered under Act 737 with at least one Medical Device Technical Area in its scope; that scope lets it verify devices in any technical area. A Malaysian subsidiary of the foreign notified body may verify the same device, provided it keeps separate personnel and impartiality declarations.
  • What it verifies. All four conformity assessment elements: the quality management system, the post-market surveillance system, the technical documentation and the Declaration of Conformity, against the checklist in Appendix 2.
  • The foreign approval. Authenticity and validity, checked against the ARTG, Health Canada, FDA and SMDR databases where they exist.
  • Effort. MDA recommends 4 hours of review per device application.
  • Certificate. One conformity assessment procedure per certificate, issued to one manufacturer or authorised representative, whose name and address must match the establishment licence. It is signed by the technical personnel who did the verification and is valid for 5 years.

CAB turnaround (MDA/GD/0068 Table 3; MDA/GD/0070 Annex 2)

StageTurnaround
Engagement, application submission, contract review3 working days each (contract finalised within 2 weeks)
Preparing and submitting documentsYour own time
Scheduling3 working days
Initial document review4 hours per device application
Final review and certification decisionWithin 2 weeks of the final report
Decision communicated5 working days
Certificate issued2 working days after payment clears
OverallAbout 1.5 months, excluding your response time

CAB fees are commercial; MDA sets none. Our all-in registration fees include the CAB fee and are on the pricing page.

What goes into MeDC@St (MDA/GD/0070 Annex 4)

SectionNew registrationRe-registration
1. Classification and establishment detailsClass, rule, valid licence as local manufacturer or AR—
2. General informationName, brand, description, intended use (consistent with the approved intended use abroad), combination-product status, HS/GMDN/UDI/UMDNS codes—
3. GroupingDevice list with identifiers (MDA/GD/0005 or GD/0054)—
4. CSDTExecutive summary, essential principles checklist, description, design verification and validation, pre-clinical studies, clinical evidence, labelling, ISO 14971 risk analysis, manufacturing informationUpdated CER or CPR, label and risk analysis
5. Manufacturer and QMSISO 13485, MDSAP, FDA QSR or MHLW Ordinance 169 certificate covering the device; manufacturing sitesUpdated QMS certificate
6. Pre-market approvalThe recognised approval; for EU and TGA approvals the manufacturer’s declaration of conformity as well, and an English translation of Japanese and Thai certificatesIf applicable
7. Conformity assessmentCAB name, registration number, certificate and reportUpdated CAB report and certificate
8. Post-market surveillanceReportable adverse events and FCAs for the past 3 years, or a no-events attestation letterUpdated PMS
9. Declaration of ConformityAppendix 3 format, signed by top management, valid QMS detailsUpdated DoC; change notification letters or a no-change declaration for the last 5 years

Documents must be in English or Bahasa Malaysia, complete, legible, valid, signed and dated, and the same dossier the CAB reviewed goes into MeDC@St. The dossier format is on our CSDT page.

MDA review and deadlines

  • Review time: 30 working days for Class B, C and D once documents are complete and payment has cleared (MDA/GD/0070 section 6.4). The full sequence is on our registration timeline page.
  • Queries: answer each one in writing in MeDC@St. Information MDA requests must arrive within 90 working days or the application is rejected and the fee is not refunded; you may apply again.
  • Refusal: MDA will not register a device that is not a medical device, is wrongly classified, lacks mandatory information within 30 working days, fails the Act, Regulations or guidance, or whose establishment licence has been revoked.

The routes compared

RouteForCAB work
Verification (this page)Class B–D with a recognised approval and a clean last yearVerifies the evidence behind the approval; about 1.5 months
Singapore HSAClass B–D on the SMDRThe same verification process; the MDA–HSA joint statement put CAB review at 30 working days
Full conformity assessmentNo recognised approval, or one that was cancelledAssesses the device from scratch
Class AClass A devicesNo CAB; straight to MDA

Points to watch

  • Same device, same claims. The intended use in MeDC@St must match the intended use approved abroad, and the brand name must appear on the label, the DoC and the technical documentation.
  • A cancelled foreign approval sends the device to full conformity assessment.
  • MDSAP helps the QMS section, not the route. Since 25 September 2025 MDA accepts MDSAP reports and certificates from MDSAP-recognised auditing organisations as QMS evidence for foreign manufacturers, but an MDSAP certificate is not an approval in Annex 1.
  • Outdated standards in the essential principles checklist need a gap assessment, and every non-applicable principle needs a rationale.
  • Circular numbers. The guidance documents still cite Circular No. 2 of 2014 and No. 1 of 2025; the current policy is Circular No. 2 of 2025, which revoked No. 1 of 2025 on 30 September 2025.
  • Fees. MDA’s registration fees are set by the Fifth Schedule of the Regulations as amended from 1 January 2026; the fee table printed in MDA/GD/0070 does not reflect every current figure, so use our cost guide.
Jawapan ringkas · Bahasa Malaysia

Apakah laluan verifikasi MDA untuk pendaftaran peranti perubatan?

Peranti Kelas B, C dan D yang telah diluluskan oleh pihak berkuasa yang diiktiraf MDA (badan notifikasi EU, US FDA, Health Canada, TGA, MHLW Jepun, MHRA UK, HSA Singapura atau FDA Thailand) boleh menjalani penilaian pematuhan secara verifikasi oleh CAB berdaftar, mengikut Surat Pekeliling MDA Bil. 2 Tahun 2025, MDA/GD/0068 dan MDA/GD/0070. Peranti mesti mempunyai reka bentuk dan tujuan penggunaan yang sama, tiada kematian atau kemerosotan kesihatan serius dilaporkan dalam setahun lepas, tiada tindakan pembetulan lapangan yang masih terbuka, dan tidak pernah ditolak atau ditarik balik. CAB mengambil kira-kira 1.5 bulan dan MDA 30 hari bekerja. WhatsApp 010-206 2070.

FAQ

Frequently asked questions

What is conformity assessment by way of verification?
It is MDA’s abridged conformity assessment for Class B, C and D devices that already hold an approval from a regulator MDA recognises. Instead of assessing the device from scratch, a registered conformity assessment body (CAB) verifies the evidence behind the foreign approval, issues a certificate of conformity, and the establishment then applies for registration in MeDC@St. The policy is set by MDA Circular Letter No. 2 of 2025 (30 September 2025); the CAB follows MDA/GD/0068 and the applicant follows MDA/GD/0070, both in their Second Editions.
Which foreign approvals qualify?
Those listed in Annex 1 of MDA/GD/0070 (Appendix 1 of MDA/GD/0068): EU notified-body certificates under specified MDD, MDR, AIMDD, IVDD and IVDR annexes; Japan Shonin from MHLW or Ninsho from a registered certification body; an ARTG registration certificate from Australia’s TGA; a Health Canada licence; US FDA 510(k) clearance or PMA; UK MHRA (UKCA, UKNI or the listed EC certificates); registration on Singapore’s SMDR; and a Thai FDA Certificate of Notified (Class 2–3) or Licensed (Class 4) Medical Device.
Our device is CE marked. Does it qualify automatically?
No. The CE certificate must come from a notified body under one of the annexes MDA lists for the Malaysian class, and the device must also pass four tests in Table 1 of MDA/GD/0070: the same design and intended purpose as the approved device; no reported deaths or serious deterioration in health anywhere in the last year; no open field safety corrective action or recall when you submit; and no rejection or withdrawal by any recognised regulator or notified body. A self-declared EU Class I device has no notified-body certificate, so there is nothing on the EU side to verify.
Is an MDSAP or ISO 13485 certificate enough for verification?
No. Those are quality management system evidence, not a recognised pre-market approval. MDA/GD/0070 accepts ISO 13485, MDSAP, US FDA QSR or Japan MHLW Ordinance 169 certificates as QMS evidence, and since MDA became an MDSAP Affiliate Member (effective 16 September 2025) foreign manufacturers may use MDSAP reports and certificates as QMS evidence. Verification still needs one of the approvals in Annex 1.
How long does the verification route take?
MDA/GD/0068 estimates about 1.5 months for the CAB, from engagement to certificate, excluding the time you take to respond. MDA/GD/0070 then gives MDA 30 working days for a Class B, C or D application once documents are complete and payment has cleared. If MDA asks for more information you have 90 working days to answer, or the application is rejected and the fee is not refunded.
Can a device that went through full conformity assessment use verification at re-registration?
Yes. Table 1 of MDA/GD/0070 allows a recertification assessment by way of verification for a device registered with MDA through either pathway, provided its registration certificate is still valid, there have been no changes to design, specifications, features or registration information that were not notified to MDA, and MDA has not rejected or cancelled its registration.
Does verification mean the CAB does not look at the dossier?
No. Under MDA/GD/0068 the CAB still verifies all four conformity assessment elements: the quality management system, the post-market surveillance system, the technical documentation and the Declaration of Conformity. It checks the CSDT, the essential principles checklist, pre-clinical studies, the clinical evaluation report, labelling and the ISO 14971 risk analysis, and confirms the foreign approval against the regulator’s database where one exists. The same dossier the CAB reviewed is then uploaded to MeDC@St.

Already approved abroad?

Send us the EC certificate, 510(k), ARTG, Health Canada, Japanese, MHRA, HSA or Thai approval and the device list. We will confirm whether the verification route applies, map the approval to the Malaysian class, build the CSDT and DoC, appoint the CAB and file in MeDC@St as your authorised representative.

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