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How does Hong Kong’s pharmaceutical licensing system regulate “medical devices”?

A complete explanation of the regulatory basis, Drew Tang’s recommendations and risk alerts. The original material dates from 2025; read it alongside the latest official requirements.

Original guide, 2025 edition: These FAQs are provided for topic-based reference and have not all been individually checked against current rules. Please confirm fees, personnel, renewal, changes and product requirements against the professional in-depth guide for the relevant licence type and the official requirements in force at the time.

Drug Office, Department of Health Chinese Medicines Board

Q43 · Category A: Pharmacy licensing system and regulatory foundations (Q1-Q50)
At present, regulation of most “medical devices” in Hong Kong is voluntary, but this is changing. The Medical Device Division (MDD) under the Department of Health has established the Medical Device Administrative Control System (MDACS). Under this system, manufacturers and importers may voluntarily apply to have their medical devices listed to demonstrate that they meet basic safety and performance requirements. Devices are classified into four risk classes (I, II, III and IV). However, if a medical device is used in combination with a pharmaceutical product (for example, a pre-filled medicine syringe or a drug-eluting stent), the “drug-device combination product” will generally be regarded as a pharmaceutical product and subject to mandatory regulation under the Pharmacy and Poisons Ordinance. The Hong Kong Government is planning a comprehensive statutory regulatory framework for medical devices, and it is expected that all medical devices will require mandatory registration before they can be marketed in future.

📘 Regulatory basis

At present, the main basis is the administrative guidance issued by the Department of Health’s Medical Device Division: the Medical Device Administrative Control System. The Pharmacy and Poisons Ordinance applies to drug-device combination products. Mandatory legislation is currently being developed.

📗 Drew Tang's recommendations

For medical device manufacturers and distributors, we strongly recommend participating in the current voluntary listing scheme as early as possible. This not only demonstrates your commitment to product quality to customers and the public, but also prepares you for the future introduction of mandatory regulations and gives you a head start.

📕 Risk notice

Do not assume that all medical devices are unregulated. Regulatory requirements may already be very stringent for high-risk devices, implantable devices or devices used in combination with medicines. Detailed classification and regulatory assessment are essential before introducing any new device.

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