NON-MEDICAL DEVICE PROJECT PROCESS

Break a complex project into five stages that can be confirmed, delivered and tracked.

A non-medical-device classification project is not simple document preparation. It starts with the real product and progressively aligns the regulatory pathway, product definition, technical parameters, verification evidence and market communications into a dossier that can be submitted and consistently implemented.

PROJECT OVERVIEW

Confirm the review pathway before committing dossier and testing resources.

The review level depends on product origin, technical mechanism, applicant and authority requirements. The timeframes below are planning references, not fixed approval deadlines.

01

National-Level Pathway

Imported products, complex mechanisms or projects requiring national-level determination are generally prepared against the national classification pathway. The final review level is determined by the competent authority and system rules.

Complex projects commonly take about 12–18 months
02

Local Regulatory Pathway

Eligible China-manufactured products may enter the relevant local pathway according to the company location, actual product and local regulatory requirements.

Commonly about 3–6 months

Actual timing may be affected by dossier completeness, the number of questions, supplementary testing, third-party work and authority processing time.

FIVE-STAGE DELIVERY

Full Project Process

Each stage has defined client actions and Basic Law deliverables. The next stage starts only after the preceding conclusion can be reviewed and confirmed.

01

Dossier Preparation

Build a factual baseline that reflects the real product.

Client Actions

Provide product instructions, overview, photographs, operating principle, technical parameters, use videos and existing test information.

Basic Law Work

Review completeness, product version and visible gaps, and issue an initial material checklist.

02

Pathway Diagnosis

Determine whether an executable non-medical pathway exists before full investment.

Client Actions

Confirm actual use, target users, commercial purpose, target market and current project stage.

Basic Law Work

Assess product-status risk, review level, redesign scope, evidence needs and the boundary of subsequent work.

03

Product and Dossier Reconstruction

Align product facts, submission materials and the intended market.

Client Actions

Confirm the product name, intended purpose, version and parameters, and coordinate samples, testing and internal R&D confirmation.

Basic Law Work

Draft or reconstruct the instructions, product overview, technical requirements, risk analysis and verification-evidence matrix within a non-medical boundary.

04

Confirmation and Submission

Complete the final version, company confirmation and formal filing.

Client Actions

Confirm the submission strategy and complete account, corporate stamp and required authorisations; imported projects add notarised and bilingual documents at the formal stage.

Basic Law Work

Perform the final consistency review, control document versions, complete system forms and organise the formal submission.

05

Regulatory Communication and Result

Continue substantiation around questions from the competent authority.

Client Actions

Provide samples, testing, R&D explanations or corporate confirmations when required, and promptly approve response content.

Basic Law Work

Track the review, organise responses, supplementary testing and additional documents until a classification result or staged regulatory opinion is received.

WORKING RESPONSIBILITIES

Division of Responsibilities

Project efficiency depends on the product facts, company confirmations and professional dossier remaining on the same version. Clear responsibilities reduce repeated revisions and avoidable waiting.

CLIENT

The Client Primarily Provides

  • Product information consistent with actual manufacture, import, sale and use
  • Confirmation of product name, intended purpose, operating principle, parameter ranges and product version
  • Coordination of samples, testing, R&D explanations and internal technical personnel
  • Corporate accounts, stamping, authorisations and applicant documents required for the formal project
  • Timely confirmation of strategies, versions and responses to regulatory questions
BASIC LAW

Basic Law Primarily Delivers

  • Proposed submission direction with feasibility and major-risk analysis
  • Reconstruction of the product instructions and product definition within a non-medical boundary
  • Standards research and preparation of the product overview, technical requirements and risk materials
  • Verification-evidence structure and recommendations for testing or supplementary information
  • Consistency review, system submission and document-version management
  • Authority follow-up, response preparation, supplementary-question management and project records
PROJECT DELIVERABLES

Typical Project Deliverables

The final deliverables depend on the product mechanism, dossier condition and agreed scope. Project value is not measured by the number of documents.

01Regulatory-pathway and feasibility diagnosis
02Product name, intended purpose and non-medical boundary definition
03Product instructions reconstructed for the non-medical position
04Product overview and technical requirements
05Risk analysis, verification-evidence matrix and testing recommendations
06Classification submission dossier and version archive
07Regulatory responses and supplementary-document package
MATERIAL CHECKLIST

A first assessment does not require every document at once.

Start with the core information that explains the real product. After review, the consultant will request formal materials according to the project stage.

Recommended for the Initial Review

  • Product instructions or operating manual
  • Product overview or technical introduction
  • Product photographs and use videos
  • Structure and operating principle
  • Output parameters, levels, treatment time and control logic
  • Existing test, experimental or risk-analysis materials
  • Planned intended purpose, marketing materials and target market

Added During the Formal Stage for Imported Products

  • Overseas manufacturer corporate information
  • China agent and applicant information
  • Product agency authorisation
  • Notarisation and bilingual versions
  • Overseas certifications, market records or test materials

Notarised authorisation is not required for the initial assessment. It is prepared after the pathway is confirmed and the formal project begins.

Confirm the product pathway before entering a long-term submission.

An existing manual, parameter list and product images are enough to start. Missing materials can be added through the Compliance Center as the project progresses.

Product status, review level and classification results are determined by the competent authority based on the actual product and formal dossier. This page explains a general project process and does not promise a result or fixed timeline for a specific product.

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