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  • 1.  China UDI locked fields

    This message was posted by a user wishing to remain anonymous
    Posted 25-Sep-2020 16:28
    This message was posted by a user wishing to remain anonymous

    Hi,

    I attended a webinar regarding China UDI requirements recently and it was mentioned that in NMPA's system there are 5 locked fields, as compared to >10 with FDA. Does anyone know which data fields are locked in China's system, or which specific guidance/standard would call this out? I know there are several guidance and standards published for UDI and I'm trying to narrow down which one(s) I need to translate to get this information. 

    Thanks in advance.


  • 2.  RE: China UDI locked fields

    Posted 29-Sep-2020 20:36

    Details related to your questions can be found from Medical device unique device identification management information system user manual (Trial Version) - Dec, 2019 (Here is the link to the manual in Chinese). We've also confirmed with NMPA that following fields are locked once the record has been published:

    1. Device identifier on the minimum sales unit (primary DI) 
    2. DI coding system name
    3. Public Release Date
    4. Quantity per minimum sales unit

    Additional information can be added to following 2 fields later on, just be aware that original data is not editable once the record is published.

    a. Registration/Filing Certificate Number (Note: If we have received a new license, we could add the new license number to the original license)

    b. Packaging Data(Package UDI-DI/ Packaging Level / Packaging DI/ Quantity per Package / Contains UDI-DI )(Note: If the product has multiple level packaging and we would like to add a higher level packaging, we could certainly add that information, but the original package level data is not editable.)

    Please note that UDI has to be included in the initial submission starting on October 1, 2020. The license holder shall upload the product identification data to the China UDI database within 60 days after the product is approved or renewed, and before the commercialization of the product. if multiple UDI change applications are submitted to NMPA and have not yet gone through approval process, the system will only document the latest change application. After change applications are approved, there will be historical versions available for review.  

    Last year, NMPA issued a number of UDI related policies regarding the UDI implementation. There is a UDI database portal (https://udi.nmpa.gov.cn) established which includes sections of Filing entrance, UDI regulations, UDI news, Database operation user manual, Data declaration manual, Data docking manual, Q&A, and Issuing agents & rule.

    Here is a list of regulations and standards that have published so far. English translations are available upon request.

    • Guiding Opinions on Medical Security Standardization (June 20, 2019)
    • Notice regarding the Information Maintenance for Reimbursed Drugs and Medical Consumables (June 25, 2019)
    • Work Plan for the Pilot of Unique Device Identification System (July 3, 2019)
    • Interpretation of Rules for Unique Device Identification System (August 3, 2019)
    • First Group of Unique Device Identification Devices (Draft) (September 17, 2019)
    • GB/T 33993-2017 Product QR Code (July 12, 2017)
    • YY/T 1630-2018 Basic Requirements for Unique Identification of Medical Devices (November 27, 2017)
    • GB/T 12905-2019 Barcode Terminology (March 25, 2019)
    • YY/T 1681-2019 Basic Terminology of the Unique Identification System for Medical Devices (July 24, 2019)
    • YY/T 1752-2020 Basic Data Set of Medical Device Unique Identification Database (July 9, 2020)
    • YY/T 1753-2020 Guidelines for Filling in the Unique Identification Database of Medical Devices (July 9, 2020)


    ------------------------------
    Grace Fu Palma
    ChinaMed Device, LLC
    MA, U.S.
    gpalma@ChinaMedDevice.com
    978-390-4453
    www.ChinaMedDevice.com
    ------------------------------



  • 3.  RE: China UDI locked fields

    Posted 01-Oct-2020 04:21
    Grace,
    Thank you for this information! Who do we submit the request for English translations of the regulations and standards from?

    ------------------------------
    Lena Cordie-Bancroft
    Victoria MN
    United States
    ------------------------------



  • 4.  RE: China UDI locked fields

    Posted 02-Oct-2020 10:51

    For English versions of NMPA regulations, we do not have everything in English.  We have all the Chinese ones.  For the English ones that we have, they are free to download at.  NMPA (CFDA) English Regulations - China Med Device

    https://chinameddevice.com/resources2/nmpa-cfda-regulations/

    As new ones become available, we will add them to the page for free download.



    ------------------------------
    Grace Fu Palma
    ChinaMed Device, LLC
    MA, U.S.
    gpalma@ChinaMedDevice.com
    978-390-4453
    www.ChinaMedDevice.com
    ------------------------------