๐Ÿ‡ฏ๐Ÿ‡ตAsia-Pacific

Medical Device Regulation in Japan

Japan regulates medical devices under the PMD Act (Pharmaceuticals and Medical Devices Act). PMDA and MHLW share responsibilities. A local Marketing Authorisation Holder (MAH) is mandatory. Japan has two premarket pathways โ€” Shonin (approval) and Ninsho (certification) โ€” and often requires Japan-specific clinical data for novel devices.

FrameworkPMD Act / QMS Ordinance (MHLW Ministerial Ordinance No. 169)
Classification systemClass I / Class II / Class III / Class IV
Primary agencyPMDA
RegionAsia-Pacific
References tracked10
Updates this year13

Sources Tracked by Qalico

Qalico continuously monitors 10 references across guidelines, regulations, and standards for Japan.

Guidelines

IMDRF โ€” Consultations1 ref
IMDRF โ€” Documents3 refs
MDSAP โ€” Documents4 refs
PMDA2 refs

Device Classification

Class IClass IIClass IIIClass IV

Class I (General Medical Devices): low risk, self-certification notification. Class II (Controlled): moderate risk, certification by Registered Certification Bodies (RCBs). Class III (Specially Controlled โ€“ lower tier): high risk, MHLW/PMDA approval. Class IV (Specially Controlled โ€“ higher tier): highest risk (e.g., cardiac pacemakers), strictest approval with extensive clinical data required.

Official classification guidance โ†’

Standards & Key Principles

Applicable Standards

ISO 13485:2016 (basis for Japan QMS Ordinance)ISO 14971:2019 (Risk Management)JIS T 0601-1 (IEC 60601-1 Japanese adoption)JIS T 11003 (IEC 62304 Japanese adoption)JIS T 0993 series (ISO 10993 Japanese adoption)

Key Principles

  • Marketing Authorisation Holder (MAH) must be established in Japan
  • Shonin (ๆ‰ฟ่ช) approval for Class III and IV via PMDA/MHLW
  • Ninsho (่ช่จผ) certification by Registered Certification Bodies for Class II and some III
  • Notification (ๅฑŠๅ‡บ) self-certification for Class I
  • QMS Ordinance inspection by PMDA prior to approval
  • Re-examination period post-approval (typically 3 years)

Pre-Market Requirements

Shonin (Marketing Approval) โ€“ Class III/IV

Full review by PMDA/MHLW: technical documentation, clinical data, QMS inspection. Target: 12 months (standard), 9 months (priority).

Ninsho (Certification) โ€“ Class II/III

Certification by Registered Certification Bodies (RCBs) against MHLW certification standards. Faster than Shonin; no PMDA review for certified product standards.

Todokede (Notification) โ€“ Class I

Self-certification notification to local prefectural government. No pre-market technical review.

QMS Inspection

PMDA conducts on-site QMS inspection of manufacturing sites prior to Shonin approval. Foreign sites via MDSAP or PMDA inspection.

Post-Market Requirements

Re-examination (ๅ†ๅฏฉๆŸป)

Post-approval monitoring period (3โ€“5 years). MAH collects safety/effectiveness data and submits Re-examination application to PMDA.

Adverse Event Reporting

Deaths/serious injuries reported to PMDA within 15 days; other adverse events within 30 days.

Post-Market Surveillance (GVP)

Ongoing PMS required; Good Vigilance Practice (GVP) Ordinance governs the vigilance system.

International Recognition & Reliance

MDSAP Members

PMDA participates in MDSAP; audit reports shared with FDA, Health Canada, TGA, ANVISA.

United States / EU

FDA/CE clinical data accepted as supporting evidence, but PMDA often requires Japan-specific bridging data for novel devices.

Stay on top of regulatory changes in Japan

Qalico monitors publications from PMDA in real time, surfacing updates that matter to your device category โ€” so your team never misses a critical change.