China Regulatory Research · Medical Devices

Medical Devices: documentation and language requirements in China

Registration material submitted to the NMPA must be in Chinese: all documents other than certificating documents are provided in Chinese, and foreign-language certificating documents require a Chinese translation signed and sealed by the agent. Instructions for use and labelling must carry Chinese text — other languages may be added, but the Chinese version governs. (Retrieved 2026-08-26)

Authority NMPARetrieved 2026-08-26
Pending review

Findings on this page are pending verification against the official Chinese text by a reviewer with Chinese regulatory reading capability. Confirm against the source before relying on them.

Language requirements by document type

Each row states what was established, the provision it rests on, and when it was retrieved. Rows marked to verify are ones this research could not settle against an official provision — they are shown rather than omitted.

DocumentChinese requiredDetailBasisSource
Registration dossierRequired All items other than certificating documents are provided in Chinese. Foreign-language certificating documents require a Chinese translation signed and sealed by the agent; where the dossier is translated from foreign-language material, the original must be supplied alongside it. Whether the translation additionally requires a translation agency stamp or declaration could not be confirmed.NMPA Announcement No. 121 of 2021, on registration dossier requirements and approval document formatswww.nmpa.gov.cn2026-08-26
Instructions for useRequired Devices sold or used within China must carry instructions for use. Other languages may be added, but the Chinese text governs. Content must agree with the registered or filed content. Provisions on Medical Device Instructions for Use and Labelling, Article 9www.nmpa.gov.cn2026-08-26
Labelling and packaging textRequired Text must be in Chinese; other languages may be added, with the Chinese governing. Imported devices without the required Chinese labelling and packaging text may not be sold or used. Labelling must agree with the instructions for use and with the registered content. Provisions on Medical Device Instructions for Use and Labelling, Articles 4 and 9www.nmpa.gov.cn2026-08-26
Technical documentation and test reportsRequired Chinese is required as part of the registration dossier; the foreign-language original must be supplied alongside the translation. Stamp or declaration requirements for the translation could not be confirmed.NMPA Announcement No. 121 of 2021www.nmpa.gov.cn2026-08-26
Clinical evaluation materialRequired Chinese is required as part of the registration dossier; originals are supplied alongside. Stamp or declaration requirements for the translation could not be confirmed.NMPA Announcement No. 121 of 2021www.nmpa.gov.cn2026-08-26
Quality management system documentationTo verify Chinese applies where the material forms part of the registration dossier. A provision covering QMS documentation generally could not be located. Carried as open — see gaps.Not established in this researchwww.nmpa.gov.cn2026-08-26
Adverse event reports and recall documentationTo verify Reports submitted to Chinese regulators are in Chinese. The specific language provision could not be located in this research. Carried as open — see gaps.Measures for Medical Device Adverse Event Monitoring and Re-evaluationwww.nmpa.gov.cn2026-08-26

Terminology consistency across submissions

Chinese terminology used in later submissions is required to stay consistent with what was already approved.

  • Provisions on Medical Device Instructions for Use and Labelling, Article 4 — instructions and labelling content shall be consistent with the registered or filed content.
  • Provisions on Medical Device Instructions for Use and Labelling, Article 8 — the product name for Class II and Class III devices shall be consistent with the name on the registration certificate.
  • Guideline for Drafting Product Technical Requirements — the product name in the technical requirements shall be in Chinese and consistent with the Chinese product name applied for.
A term chosen in the first submission is carried forward into renewals, changes and re-registration. Deciding it once, and recording why, is cheaper than reconciling divergent terms across a certificate's lifetime.

www.nmpa.gov.cn · retrieved 2026-08-26

Where companies get this wrong

01

Assuming an English IFU with a Chinese translation attached is sufficient

The Provisions require the text of instructions for use and labelling to be in Chinese. Other languages may be added, but the Chinese governs — it is the operative version, not a courtesy translation.

www.nmpa.gov.cn
02

Assuming a provincial administration reviews imported devices

Registration and filing of imported devices — of every class — sit with the NMPA. Provincial administrations review Class II devices manufactured domestically. This is the distinction overseas companies most often get wrong.

www.nmpa.gov.cn
03

Citing the 2004 labelling rules as current

The 2004 provisions were expressly repealed in 2014 by the current Provisions on Medical Device Instructions for Use and Labelling. Industry commentary still circulates under the old title.

www.nmpa.gov.cn
04

Assuming the whole dossier can be filed in English

Items other than certificating documents are provided in Chinese. Originals may accompany the Chinese, but a Chinese version is required.

www.nmpa.gov.cn
05

Translating both 注册 and 备案 as "registration"

Chinese regulation distinguishes registration (注册) from filing (备案): Class I devices are subject to filing, Classes II and III to registration, and the two differ in review depth and legal effect. English material that merges them can send a company down the wrong procedure. Noted as an observation from practice rather than an official provision.

What documentation problems have led to

No public case naming a document or language problem as the stated cause was found. What follows is the regulatory position, recorded without predicting outcomes.

Registration

No public case citing document or language grounds was located; supplementation notices generally do not disclose the specific grounds.

Import

Imported devices without the required Chinese labelling and packaging text may not be sold or used. No public case of goods held specifically over missing Chinese labelling was located.

www.nmpa.gov.cn
Post-market

The NMPA has run dedicated inspections of instructions, labelling and packaging text, with use of Chinese among the items checked. No public recall attributed to a language or documentation problem was located.

www.nmpa.gov.cn

Common questions

Does the registration dossier have to be in Chinese?

Yes. Items other than certificating documents are provided in Chinese; foreign-language certificating documents require a Chinese translation signed and sealed by the agent, with the original supplied alongside.

Retrieved 2026-08-26

Are there official English versions of Chinese medical device regulations?

The NMPA publishes some English content, but the authoritative text of the governing Regulation and the departmental rules is Chinese. No official full English translation carrying legal effect was identified in this research, so English material should be treated as reference.

Retrieved 2026-08-26

Which authority actually reviews our submission?

For imported devices of any class, the NMPA. Provincial administrations review Class II devices manufactured within China; Class I domestic devices are filed at municipal level.

Retrieved 2026-08-26

Our registration material was approved three years ago — is it still valid?

Registration certificates carry a validity period and require renewal before expiry. Separately, the governing Regulation was amended in December 2024 with effect from 20 January 2025; certificates remain valid within their term, while items touched by the new requirements may need adjustment. Transitional detail was not established in this research.

Retrieved 2026-08-26

Does the translation need a translation agency stamp?

The current requirement names signature and seal by the agent. Whether a translation agency stamp or declaration is additionally required could not be confirmed against an official source, and is listed as an open item.

Retrieved 2026-08-26

Must terminology in a later submission match what was approved before?

Yes. Instructions and labelling content must agree with the registered or filed content, and the product name must match the registration certificate. Consistency across renewals and changes is a stated requirement, not a stylistic preference.

Retrieved 2026-08-26

How do we confirm a Chinese regulation is the current version?

The national laws and regulations database (flk.npc.gov.cn) shows a regulation's history and current status; NMPA pages carry issue and effective dates. Note that Chinese regulations often exist in several amended versions under the same title, so check the document number and amendment date.

Retrieved 2026-08-26

What has changed in the last two years?

The governing Regulation was amended on 6 December 2024 (State Council Order No. 797), effective 20 January 2025. In December 2025 the NMPA adjusted the classification category of 31 product types. The language requirements themselves — Chinese as the operative text — did not change fundamentally.

Retrieved 2026-08-26

What this research did not settle

The following could not be established against an official source in this round, and so was not written into the findings above. It is listed so you can see where the research stops.

  • Whether a translation agency stamp or declaration is required, beyond the agent's signature and seal
  • The language provision covering quality management system documentation
  • The language provision covering adverse event reports and recall documentation
  • Which regulations, if any, have an official English version carrying legal effect
  • Transitional arrangements following the December 2024 amendment
  • Public cases where a document or language problem was the stated cause

Sources

  • National Medical Products Administration (nmpa.gov.cn)
  • State Council policy portal (gov.cn)
  • National laws and regulations database (flk.npc.gov.cn)

Retrieved 2026-08-26

Scope of service

We do

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  • Clause mapping
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  • Source citation with retrieval dates

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About this page

This page presents regulatory research intended to help companies understand documentation requirements in a target market. It does not constitute legal advice and is not a substitute for qualified legal counsel.

All regulation numbers, effective dates, and status indicators on this page carry a source and a retrieval date. Regulations may change after that date. For determinations of legal effect, the official-language text and the current rules of the competent authority govern.

Before this material is used for filing, certification, or any external commitment, we recommend review by a licensed attorney in the target market.

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