Regulatory Open Forum

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  • 1.  Submitting in Singapore?

    Posted 29-Apr-2020 08:25

    Hi All.

    I hope everyone is keeping safe. 

    could anyone share their experience for submitting a device for Regulatory Clearance in Singapore? From what I have read, there are three routes. Immediate, Expedited and Abridged and this is determined on whether you have received clearance in a reference market, e.g. USA, Europe etc.

    Has anyone submitted to Singapore? Is it quite straight forward if you have received clearance in a reference market? What kind of timescales, problems did you encounter?

    I am sure people will have differing experiences but I would like to get an understanding of what is involved.

    Thanks

    James



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    James
    Head of QARA
    UK
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  • 2.  RE: Submitting in Singapore?

    Posted 30-Apr-2020 02:56

    Hi James,

    We have recently received approval for a class 3 IVD in Singapore using the abridged pathway. We leveraged from an Australian approval and we were required to provide evidence of approval (e.g. Aust Declaration of Conformity and ARTG certificate). We were still required to provide the necessary technical documentation to support the application, but the HSA reviewer was able to meet the regulatory agency's timelines despite the COVID-19 crisis.

     

    The process  to submit in Singapore is reasonably straight forward and the HSA has guidance documents which clearly describe the regulatory pathways and submission content. See https://www.hsa.gov.sg/medical-devices/guidance-documents

     

    Don't forget that you will need a local representative to hold the necessary licenses (e.g. importer, wholesaler).

     

    I hope this information is helpful.

     

    Elizabeth Freitas, PhD

    Assoc. Director, Regulatory Affairs- APJ

    Illumina

     






  • 3.  RE: Submitting in Singapore?

    Posted 30-Apr-2020 03:02
    Hi James,

    Speaking from my past experience as a medical device regulator at Health Science Authority (HSA), Singapore, yes, you are correct that there are 3 routes available for class B, C and D medical devices in Singapore based on prior approval from the 5 reference agencies recognized by HSA ie. US FDA, EU, Health Canada, Australia TGA and Japan MHLW for the devices to be registered. For a device which has no prior approval at all a full evaluation route will be the only option not forgetting all Class A medical device will not require product registration but registrant will have to perform a self declaration online on the Class A medical device registry to add the device to the list.

    Each of the submission route will have different fees and turn-around-time which are publicly made available on HSA website:

    https://www.hsa.gov.sg/medical-devices/registration

    Each submission route will have its own set of challenges but in general is a risk-based approach to the evaluation of the submitted dossier. We can discuss more if you would like to know more in details via my personal email: ng.weibeng@gmail.com

    Best regards
    WeiBeng, Ng



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    Wei-Beng Ng
    Singapore
    Singapore
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  • 4.  RE: Submitting in Singapore?

    Posted 30-Apr-2020 04:59
    Edited by Soumya Rajesh 30-Apr-2020 05:00
    Hi James,

    Recently we registered our product with HSA and it was pretty easy. We had appointed a third party to help us with the registration process. Our device is Class B and was qualified for an immediate route as we have an EU sales history of more than 5years + ARTG approval.

    The registration process is as below.

    Depending on the types of foreign certificates, such as CE-marking and FDA clearance, various registration routes apply. If the product is class 1(510k exempt),510K exemption cannot be counted as 1 agency approval for Singapore because the Singapore Health Sciences Authority (HSA) rely on US FDA formal review (510K or PMA) to justify a shorter review period.

    Based on the 'abridged route', the processing of the application is as follows: Prepare documentation for submission to submit the file to HAS in collaboration with local partner à Screening of application by HSA à Evaluation of the application by HSA à Regulatory decision and listing for successful registration.

    The evaluation is based on the data set submitted by the applicant. The estimated turnaround time from the authorities is estimated at 5-6 months. These commence from the date of receipt of the application to HSA.

     

    For an 'immediate route', the device must be already registered in Canada or if the product must be sold in the EU for at least 3 years. There is no turnaround time for the 'immediate route' as your registration takes place upon submission. The below set of documents are required for immediate route

    • Sales report (last 3 years),. Any other proof of marketing history that you consider relevant.
    • IFU and technical file
    • Device description if not mentioned in one of the above points.
    • Product brochure
    • Label
    • Manufacturer information (site's name and address)
    • CE certificate
    • Quality Management Certificate such as ISO 13485
    • Declaration of no adverse events or safety issues.


    Please note that a local partner (based in Singapore) must be identified prior to submission. He/she will be responsible for

    • Becoming the license holder (also known as a registrant in Singapore)
    • Registration of product
    • Appointing client importer/ distributor

    Note: you can also appoint the importer/distributor independently. 

    The importer/ distributor should already be a qualified entity (with Good Distribution Practice certification and with a valid importer/ wholesaler license from the Singapore authority HSA).

    Hope this helps!

    Regards,

    ------------------------------
    Soumya Rajesh
    Quality and Regulatory Affairs Manager
    Den Haag
    Netherlands
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  • 5.  RE: Submitting in Singapore?

    Posted 07-Sep-2021 14:51
    Sorry for resurrecting this, but can this sentence be further clarified:

    "For an 'immediate route', the device must be already registered in Canada or if the product must be sold in the EU for at least 3 years. "

    Does this mean either 1) it's registered in Canada for sale or 2) in the EU for 3 years already or 3) both? I don't understand how this is phrased.

    Our device is a wearable class II FDA, Class IIa MDD device, also cleared in Australia under TGA, and Canada under the Interim Order.

    Thanks!

    Ed


    ------------------------------
    Edward Panek
    VP, QA/RA
    Med Device
    USN Veteran
    Research into Neural Nets - https://www.twitch.tv/edosani
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  • 6.  RE: Submitting in Singapore?

    Posted 08-Sep-2021 02:10
    Hi Ed.

    I agree that the wording is not the best, I read this as either / or. There is a footnote after 'route', does that give any further guidance?

    Thanks
    James

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    James
    Head of QARA
    UK
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  • 7.  RE: Submitting in Singapore?

    Posted 09-Sep-2021 19:00
    Not sure if you are interested, but there is a course via Udemy on Singapore medical device registration.  I haven't taken their courses, was actually looking for something else and came across it.  

    https://www.udemy.com/course/singapore-medical-device-regulations/

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    Gretchen Upton
    RAC, CQA, CCRP
    QA/RA consultant
    San Antonio, TX
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  • 8.  RE: Submitting in Singapore?

    Posted 01-May-2020 10:42
    Thanks all, really useful.

    We are in the process of gaining CE and FDA clearance so my next port of call will be other territories and Singapore is one are that we are looking at. Emergo have quite a nice tool where you can get information on different territories and I wondered how accurate it might be! Sounds like it might be quite on point with what is being saiid. 

    Thanks
    James

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    James
    Head of QARA
    UK
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