Bryan Gilburg - China

“Addressing China’s many unique product standards will be the trick to taking advantage of this new guidance.”

Bryan Gilburg

Managing Director

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NMPA Issues New Guidance for Reviewing Medical Device Software in China

Published on: July 10th, 2022

In March of 2022, the NMPA’s Center for Medical Device Evaluation (CMDE) released new guidance pertaining to registering medical device software in China. Referred to as the “Guiding Principles,” this new document provides technical considerations for 18 product categories including stand-alone software and software included in physical medical devices, including in-vitro medical devices. The new guidance can be found here in Chinese and here in English.

Basic Principles

The new guidance intends to provide manufacturers planning to register their medical device software in China with an understanding of how their software will be evaluated by the authorities. As with most countries, the NMPA’s review will look at the software life cycle (GB/T 20158-2006) to ensure manufacturers are taking appropriate risk mitigation steps to ensure safety throughout the product’s time on the market. The NMPA will look specifically at the design and verification process as this is equivalent to a physical device’s manufacturing process. Additionally, security, specifically cyber security, will also be evaluated in accordance with IMDRF/CYBER WG/N60FINAL : 20 20 , Principles and Practices for Medical Device Cybersecurity.

Technical Considerations

The guidance also outlines the various technical considerations medical device manufacturers should consider before registering their software in China. Depending on the product’s functions, some or all may need to be considered and evaluated.

The Technical Considerations outlined in the guidance include:

  1. Registration Unit and Detection Unit
  2. Basic Principles of Clinical Evaluation
  3. Network Security
  4. Cloud Computing
  5. Mobile Computing
  6. Artificial Intelligence
  7. Human Factors and Availability
  8. Interoperability
  9. Measurement Functions
  10. Remote Access and Control
  11. General Computing Platform
  12. Non-Medical Device Functions
  13. Implantable Product Design Software
  14. Terms of Use
  15. Exception Handling
  16. Functional Safety and Software Reliability
  17. Implementation Requirements of GB/T 25000.51
  18. Imported Medical Device Software

Standalone Software Technical Requirements

As part of the guidance, the CMDE had provided a Technical Requirements template for medical device software products. An outline of this template has been extracted for convenience but more information for each section can be found at the bottom of their guidance.

1. Product model/specification and its division description

1.1 Software Model Specifications

1.2 Software Release Version

1.3 Software Version Naming Rules

2. Performance indicators

2.1 General requirements

2.1.1 Function

2.1.2 Usage Restrictions

2.1.3 Input and output

2.1.4 Interface

2.1.5 Necessary software and hardware

2.1.6 Operating Environment

2.1.7 Performance Efficiency

2.1.8 Maximum concurrent number

2.1.9 User Interface

2.1.10 Messages

2.1.1 1 User Error Defense

2.1.1 2 Access Control

2.1.1 3 Copyright protection

2.1.14 Reliability

2.1.1 5 Maintainability

2.2 Special requirements ( if applicable )

2.3 Safety requirements ( if applicable )

3. Inspection method

4. Terminology/Definitions (if applicable)


Which may include:

  1. Architecture diagram
  2. User interface diagram and main interface diagram
  3. Physical topology

Come Grow With Us

Please contact us if you’d like support understanding these new software registration requirements or are interested in registering your product in China. Asia Actual specializes in helping medical device manufacturers grow their sales in Asia with experienced, bi-lingual commercial and regulatory experts on the ground in each market. Contact Asia Actual today with any questions or support requests.

Asia Actual is a regulatory consulting company specializing in helping manufacturers grow their sales through independent license holding, direct fulfillment, and a variety of sales channel support services.

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