Bryan Gilburg - China

“By avoiding the Specialist Review, the Program intends to reduce the review time to 60 days while also saving manufacturers the $1,700 (53,000 Baht) Review fee.”

Bryan Gilburg

Managing Director

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Thailand Fast Tracks Class D Medical Device Registration with Singapore Approval Status

Published on: October 25th, 2021

Fast Track Option Reduces Review Time and Saves Money

The Thai FDA has formally adopted the Regulatory Reliance Program in which Class D (Class 4 in Thailand) medical devices and IVDs listed on the Singapore Medical Device Registry can be exempted from the Specialist Review requirement in Thailand. By avoiding the Specialist Review, the Program intends to reduce the review time to 60 days while also saving manufacturers the $1,700 (53,000 Baht) Review fee. The program is meant to leverage device conformity assessments performed by the Singapore HSA for expedited registration in Thailand.

The process involves the local Thai authorized representative submitting a standard registration application for pre-submission to the Medical Device Control Division of the Thai FDA with the addition of (1) a letter of request to participate in the Regulatory Reliance Program, and (2) evidence of registration in Singapore. Note that the CSDT documents must match exactly with those submitted (updated with any change notification) in Singapore.

Coordinating with the Manufacturer’s Singapore Registrant

Subsequently, the Registrant (license holder) for the device in Singapore will then submit a Consent Form to the Singapore Health Sciences Authority (HSA), thus providing the authority for a HSA application evaluation report to be shared with the Thai FDA.

This process is fairly straightforward, but it will require full cooperation and close coordination between the Registrant in Singapore and the applying license holder in Thailand.

After experience with the Thailand FDA – HSA Singapore Regulatory Reliance program is well established with high-risk class devices, it is likely to then be extended to lower risk category devices

Specialist Reviews in Thailand

Not all Class 4 devices will be selected by the TFDA for a Specialist Review but those that do are often novel devices, those with short market history, and/or lacking sufficient documentation in their opinion. Being selected for Specialist Reviews can add 90-120 days to an application’s review time along with an additional $1,700 fee. Currently, the TFDA has been selecting every device utilizing Artificial Intelligence (AI) for a Specialist Review due their unfamiliarity with the technology and its novelty. When combined with the Malaysia Medical Device Authority’s preference for Singapore approved devices, this new program offers manufacturers of high risk, high-tech devices a quick, inexpensive pathway to grow their sales in the region.

Below are the fees associated with Class 4 applications in Thailand:

Risk Classification Registration Type Submission Fee Specialist Review Fee (Novel Devices) Approval Fee Total Fee (with Specialist Review) Max Review Time
Class 4 Licensing 1,000 Baht

(US$105)

53,000 Baht

(US$ 1,767)

20,000 Baht

(US$ 667)

74,000 Baht

(US$ 2,539)

150 to 300 days with a Specialist Review

Come Grow with Us

Asia Actual has an office in Singapore and Bangkok staffed by experienced, bilingual regulatory and commercial professionals to address any questions or provide support.  Please contact us to explore if this new program is appropriate for your devices.

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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