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PMDA Approval: How to Register a Medical Device in Japan

Japan has several medical-device regulatory routes, not one universal PMDA approval. The route depends on classification and certification standards, while overseas manufacturers also need a local authorization arrangement and must address site registration and QMS review.
From TheFinanceBase Team4 min to read
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There is no single “PMDA approval” route for every medical device in Japan. The route depends on the device’s Japanese classification and, for some Class II and III devices, whether a certification standard applies: Class I devices are notified, qualifying Class II and III devices can be certified by a registered certification body (RCB), and the remaining Class II and III devices plus all Class IV devices require MHLW approval with PMDA review. Overseas manufacturers also need an appropriate Japan-based authorization arrangement and must address foreign manufacturing-site registration and quality-management-system (QMS) review.

What “PMDA approval” means in Japan

PMDA is Japan’s Pharmaceuticals and Medical Devices Agency. The Ministry of Health, Labour and Welfare (MHLW) and prefectural authorities also have regulatory roles. Under Japan’s PMD Act, commercial shipment of a medical device is subject to the applicable regulatory permission, registration, or approval; the term “PMDA approval” is often used loosely for several different procedures.

For a device requiring MHLW approval, PMDA conducts the product review. Other devices follow notification or RCB certification routes instead. A product authorization, registration of a foreign manufacturer or site, and the Japanese marketing authorization holder’s (MAH’s) license are separate matters, not one universal “PMDA registration.” PMDA’s English procedural guide, a provisional translation dated August 2025, says the Japanese original prevails if the two versions differ.

Which regulatory route applies?

PMDA describes four risk classes. Classification alone does not settle every route: for Class II and III, whether a certification standard applies also matters.

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Japanese device class or condition Route Who handles the route PMDA product review?
Class I Notification Notification is made to PMDA. No MHLW approval review is described for this route.
Class II with an applicable certification standard Certification A registered certification body (RCB). No PMDA product review is described for this certification route.
Class II without an applicable certification standard MHLW approval Application is submitted to PMDA for review for MHLW approval. Yes.
Class III with an applicable certification standard Certification An RCB. No PMDA product review is described for this certification route.
Class III without an applicable certification standard MHLW approval Application is submitted to PMDA for review for MHLW approval. Yes.
Class IV MHLW approval Application is submitted to PMDA for review for MHLW approval. Yes.

These are route categories, not a substitute for classifying a particular product. The intended use, Japanese general name, and applicable standard matter. The MAH must ensure efficacy, safety, and quality on the basis of evidence before submission. PMDA says product requirements are assessed case by case and offers fee-based face-to-face consultations.

How an overseas manufacturer can approach market entry

  1. Confirm whether the product is regulated as a medical device or IVD. If this is uncertain, PMDA directs applicants to the competent prefectural pharmaceutical-affairs division. For a formal determination, it recommends consulting through a Japan-based MAH with the authority that has jurisdiction over the MAH, or contacting MHLW. PMDA also points software as a medical device (SaMD) questions to a dedicated consultation route.
  2. Determine the Japanese classification and route. Establish the relevant general name, risk class, and—if the device is Class II or III—whether a certification standard applies. That determines whether the procedure is notification, RCB certification, or MHLW approval with PMDA review.
  3. Set up the Japan-based authorization arrangement. A foreign manufacturer proceeds through a Japanese MAH or an appointed Japanese manufacturer, as appropriate to the procedure. The MAH has corporate accountability and quality-assurance and safety-management responsibilities; it is not merely a local mailing address.
  4. Arrange foreign manufacturer and site registration. Before applying, obtain manufacturer codes from MHLW for the foreign manufacturing company and each relevant manufacturing site. PMDA handles the foreign-manufacturer registration procedure. The foreign manufacturer is the applicant, but an agent—typically the related marketing authorization business—must submit on its behalf; PMDA says direct filing without an agent is not permitted. Obtaining codes alone does not complete registration.
  5. Prepare and submit the route-specific product filing. Class I follows notification; qualifying Class II and III devices go to an RCB for certification; devices requiring MHLW approval are submitted to PMDA for review. The evidence and forms depend on the product and route. PMDA assesses evidence for efficacy, safety, and quality in its product-review role.
  6. Complete the applicable QMS inspection. PMDA may conduct a document-based or on-site inspection of registered device manufacturing sites in Japan or overseas. This assesses QMS compliance and whether the site can manufacture products of adequate quality; it is distinct from review of the product’s evidence.
  7. Maintain the local responsibilities after market entry. PMDA’s FAQ says the Japanese MAH distributing the product in Japan submits post-marketing safety reports. Market entry therefore does not end the MAH’s safety and quality responsibilities.

What foreign applicants should plan for

Japanese-language filings

PMDA says it does not accept marketing applications in languages other than Japanese; forms related to the application must also be submitted in Japanese. Plan for translation and regulatory review as part of preparing the filing.

Clinical data from outside Japan

PMDA accepts and reviews clinical data from studies conducted outside Japan for medical-device marketing approval applications. That does not establish that a particular dataset is sufficient for a specific product; its relevance and adequacy should be discussed with the MAH and agency.

Product review and manufacturing-system review

Product review addresses the evidence for a device’s efficacy, safety, and quality. QMS review examines the manufacturing system and relevant site compliance. Depending on the applicable requirements, the latter may involve documents, an on-site inspection, or both; completing one assessment does not make the other a substitute.

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Classification and case-specific requirements

When classification, an applicable standard, or the filing route is uncertain, resolve that question before building the submission. The relevant prefectural authority may be involved in formal device-status determinations, while PMDA consultations can address product-specific requirements. Confirm current forms and requirements with the MAH and appropriate regulator.

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Timing and cost depend on the route

There is no universal approval duration or cost established for these routes. Classification, certification-standard availability, product-specific evidence requirements, consultation needs, and applicable reviews affect the work required. Do not treat an estimate for one product or route as a general Japan market-entry timeline or fee.

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