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  • 1.  IEC 60601 VS. China GB 9706.1 for Medical Electrical Equipment Testing

    Posted 09-Oct-2020 14:01

    We were asked regularly about whether China NMPA will accept IEC 60601-1 edition 3.1. Here is the latest update.

    Test reports based on IEC 60601-1 3 edition cannot be accepted by NMPA at this time. NMPA currently still requires electrical medical devices to comply with "GB 9706.1-2007", which is a mandatory national standard converted from "IEC 60601-1 edition 2". Even though on April 9, 2020, NMPA issued GB 9706.1-2020  (equivalent to IEC 60601-1 edition 3.1 ), there is a three year transition time before its official implementation in May 2023. Before GB 9706.1-2020 comes into effect in 2023, NMPA only accept test reports based on IEC 60601-1 edition 2 to determine whether  certain testing items performed overseas can be exempted from repeating a complete IEC 60601-1 edition 2  based on GB 9706.1-2007.

    Just a note that GB is an abbreviation of "Guobiao" which means 'National Standards' in Chinese. NMPA has been publishing GB standards that are adopted directly from international standards sometimes with certain modifications to suite China market needs. However, they could be in a different revision than the most current international editions or include some Chinese-specific requirements. During registrations, medical devices are required to demonstrate its full compliance with all applicable GB and YY standards.



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    Grace Fu Palma
    ChinaMed Device, LLC
    MA, U.S.
    gpalma@ChinaMedDevice.com
    978-390-4453
    www.ChinaMedDevice.com
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  • 2.  RE: IEC 60601 VS. China GB 9706.1 for Medical Electrical Equipment Testing

    Posted 12-Oct-2020 09:04
    Grace,

    I just want to thank you for your ongoing efforts at providing information on China registrations in this Forum. China is complex and quickly changing, and your posts are always to the point and helpful.

    Ginger

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    Ginger Glaser RAC
    Chief Technology Officer
    MN
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  • 3.  RE: IEC 60601 VS. China GB 9706.1 for Medical Electrical Equipment Testing

    Posted 14-Oct-2020 09:42
    Ginger, thanks so much for your compliments.  It is always encouraging us to work harder when our inputs are valued.  Indeed China NMPA or the country is like a teenager trying to grow up fast.  It has its shares of complexity and pain points but at the same time early adopters who enter China correctly can certainly benefit its 19% annual growth rate in MedTech sector for the past several years and continue so for the future years.  In the recurring pandemic in the US, China is 100% open domestically with strong monitoring where we just had 1000+ people meetings on RWD/S a couple of weeks ago. 
    I hope to learn more from you and understand the best practice from the western world.  
    Grace

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



  • 4.  RE: IEC 60601 VS. China GB 9706.1 for Medical Electrical Equipment Testing

    Posted 14-Oct-2020 16:08
    This is very useful information - I haven't worked on any registrations in China recently but I appreciate keeping up to date with the latest and greatest regulations there. Thank you Grace!

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    Christine Stahley
    Regulatory Affairs
    Marlborough MA
    United States
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  • 5.  RE: IEC 60601 VS. China GB 9706.1 for Medical Electrical Equipment Testing

    Posted 23-Oct-2020 17:42
    I want to comment on Grace's post as I'm in contact with SGS in China on a regular basis about this topic.  I'm on ETF-3 of the CB scheme so I'm connected with the IEC test labs which is not the regulator side of testing but they are connected to them in some countries and my connection in China does have that type of connection.  So, this is what I have found out. 

    It is correct that NMPA issued GB 9706.1-2020  (equivalent to IEC 60601-1 edition 3.1 was issued on April 9, 2020, and there is a 3 year transition period.  The normal expected position is "there is a 3 years transition period time before its official implementation in May 2023. Before GB 9706.1-2020 comes into effect in 2023, NMPA only accept test reports based on IEC 60601-1 edition 2 to determine whether certain testing items performed overseas can be exempted from repeating a complete IEC 60601-1 edition 2  based on GB 9706.1-2007."

    Now for what I have found out recently:
               
    1. "Because the GB 9706.1-2020 (EQV to 3.1 edition) is still a new standard for NMPA. The old acceptance criterion (GB 9706.1-2007) is still effective until there comes up with new ones.
    2. From the testing capability perspective, most of NMPA registered labs have not yet got this new standard accredited, therefore, if there was a new report tested according to new version of GB 9706.1-2020, it may encounter with a rejection letter during the registration process.

    However, I confirmed this issue with the leader of technical committee of medical devices, he told me that, currently, it's risky to submit the new reports directly till some labs obtain the accreditation in future, he and other officers are under plan to propose a suggestion to NMPA centre office that trying to accept both editions after the middle of transition period, say, in 2022 or later on, in order to let the submitters and also the NMPA staffs get used to the new reports in advance. If the proposal is accepted, there will be a guidance published accordingly for proper handling on the NMPA registration."

    This information is not set in stone but is advance information but being on standards committees does have it's advantages......



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    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
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  • 6.  RE: IEC 60601 VS. China GB 9706.1 for Medical Electrical Equipment Testing

    This message was posted by a user wishing to remain anonymous
    Posted 27-Oct-2020 17:04
    This message was posted by a user wishing to remain anonymous

    Leo,

    I had a question on this. Back in 2016, you need a webinar for Green Light Guru called, "15 Steps for IEC 60601 Approval" and you had a line that said, "China as GB 9706.1-2007 (Drafting ed. 3.1 ≈ 2016 will be mandatory)"

    My question, is the "Drafting ed. 3.1" that you referenced in that presentation the same 2020 document that is now published (rather than 2016)?


  • 7.  RE: IEC 60601 VS. China GB 9706.1 for Medical Electrical Equipment Testing

    Posted 28-Oct-2020 01:57
    I really doubt that is the same document as would have gone thru some major changes and may not be the same document at all if even the same document.    The reason being that things don't stay the same over that long of a period in China when being developed and the Chinese have gone thru a lot of changes for the 60601 series from even in 2016 til now in 2020.  This is based on discussions I have had with my counterparts that work for Chinese test houses such as Intertek and SGS, etc.

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    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------