Philippines Medical Device Registration: CMDN, CMDR, and ASEAN Harmonization

Medical Device Registration in the Philippines (CDRRHR)

The regulatory authority for medical device registration and regulation in the Philippines is the Center for Device Regulation, Radiation Health and Research (CDRRHR), which operates under the Department of Health (DOH). The regulatory framework is harmonized with the ASEAN Medical Devices Directive (AMDD), introducing a risk-based classification and new conformity assessment requirements under Administrative Order 2018-0002.

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Device Classification and Conformity Assessment

Devices are classified into four risk categories (A, B, C, and D) based on the AMDD. The classification dictates the required conformity assessment certificate:

• Class A (Low Risk): Requires a Certificate of Medical Device Notification (CMDN).
• Classes B, C, D (Low-moderate to High Risk): Require a Certificate of Medical Device Registration (CMDR).

The transition to these new requirements is ongoing, with the Philippines FDA issuing extensions for non-Notified Class B, C, and D devices to obtain an initial CMDN before renewal requires the more involved CMDR.

Classification Type	Risk Level	Application Fee (Approx.)	Review Time
Class A Notification (CMDN)	Low	PhP 81,000	4 to 12 weeks
Class B, C, D Registration (CMDR)	Low-moderate to High	PhP 108,000 – 117,000	Within 180 days

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Key Registration Requirements

1. Reference Country Approval: Home country approval or Reference Country approval is required for all classes of devices. Reference Countries include Australia, Canada, the European Union, Japan, and the United States.
2. Dossier Documentation: Submissions must follow the CSDT Template.
   • CMDN: Requires basic documentation, including a device description, Certificate of Conformity, Declaration of Conformity, Declaration of Shelf Life, and colored pictures of the labeling.
   • CMDR: Requires additional documentation, such as risk assessments and clinical evidence.
3. Quality System (QMS): All device classes (A, B, C, and D) require evidence of QMS compliance, typically demonstrated through an ISO 13485 certificate or an audit report from a recognized body (e.g., FDA, PMDA).
4. Expedited Review: The Philippines FDA offers an expedited approval route (aiming for 30 business days) for applications submitted with CSDT documents previously approved in other ASEAN markets.

Validity and Maintenance

Both the CMDN and CMDR certificates are valid for 5 years and must be renewed prior to their expiry. Renewals can be filed up to 90 days before expiration. Medical devices used strictly for research, clinical trials, or as donations are typically exempt from Notification and Registration but require a Certificate of Medical Device Listing.