FAQs

Can an imported product be manufactured inside China?

Answer: Yes, under certain conditions.
If the imported device is already registered, and the foreign manufacturer establishes or controls a China-based company, the product may be localized under Announcement No. 30 (2025).

✅ We assist with transition planning and localized registration for previously imported devices.

What happens if the manufacturing site address changes?

A registration amendment is required.
You must submit updated supporting documents, such as:
▶ New QMS or site qualification certificates (if applicable)
▶ Updated Free Sales Certificate (FSC) or marketing authorization (if required)
▶ An explanation if no new approval is needed in the original country

● For innovative devices not yet listed overseas, FSC may be waived.

Must the overseas manufacturing site comply with Chinese production standards?

Yes.
The manufacturing site must meet relevant Chinese medical device production requirements and accept potential inspections organized by NMPA.

Is a Quality Management System (QMS) audit required for imported devices?

A: Not always.
For Class II and III imported devices, the NMPA may request a QMS inspection based on the outcome of the technical review. If required, the NMPA Inspection Center will organize an overseas audit.

● BiomenGroup can coordinate QMS readiness and audit support for your overseas site.