China Regulatory Research · Medical Devices

Medical Devices: documentation and language requirements in China

Article 17 of SAMR Order No. 47 requires Chinese registration and filing material, with the original supplied when translated from foreign-language material. Article 9 of the 2014 instructions and labelling provisions requires Chinese text and makes Chinese the governing version when other languages are added. Confirm the product-specific dossier and attestation requirements before submission.

Authority NMPASource record 2026-08-26Editorial update 2026-10-11
Compiled from public sources

Compiled from public official sources. The source retrieval dates below apply to the cited findings; this editorial review does not revalidate every provision or current standard edition. A language requirement marked to verify has not been established from the cited text. Confirm current product-specific requirements before filing or making an external commitment.

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 Registration and filing material must use Chinese; where translated from foreign-language material, the original must be supplied as well. Confirm the detailed dossier and signature or seal requirements for the actual procedure. Procedure-specific signature, seal or translator declaration requirements were not revalidated in this review.Measures for the Administration of Medical Device Registration and Filing, SAMR Order No. 47 (2021), Article 17www.samr.gov.cn2026-10-11verifiable
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 9yjj.sh.gov.cn2026-10-11verifiable
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 9yjj.sh.gov.cn2026-10-11verifiable
Technical documentation and test reportsRequired Where this material forms part of registration or filing documentation, Article 17 requires Chinese and the foreign-language original where a translation is supplied. Procedure-specific signature, seal or translator declaration requirements were not revalidated in this review.Measures for the Administration of Medical Device Registration and Filing, SAMR Order No. 47 (2021), Article 17www.samr.gov.cn2026-10-11verifiable
Clinical evaluation materialRequired Where this material forms part of registration or filing documentation, Article 17 requires Chinese and the foreign-language original where a translation is supplied. Procedure-specific signature, seal or translator declaration requirements were not revalidated in this review.Measures for the Administration of Medical Device Registration and Filing, SAMR Order No. 47 (2021), Article 17www.samr.gov.cn2026-10-11verifiable
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.cn2026-08-26portal only
Adverse event reports and recall documentationTo verify A specific language provision for these reports was not established from the cited material. Confirm the reporting route and documentation requirements before submission. Carried as open — see gaps.Measures for Medical Device Adverse Event Monitoring and Re-evaluationwww.nmpa.gov.cn2026-08-26verifiable

About the source markers

verifiable
The link opens the provision itself — you can check that row by clicking it.
portal only
The link opens the authority's portal. It confirms the body and the scheme, but the specific reference or status on that row cannot be verified from that page alone.

Terminology consistency across submissions

Instructions and labelling must correspond to the registered or filed content. This supports controlled terminology; it does not mean an approved term can never be changed through the applicable procedure.

  • 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.
Keep approved product names and source references available for later revisions. Proposed changes should be assessed through the applicable regulatory process rather than silently carried forward or silently rewritten.

yjj.sh.gov.cn · retrieved 2026-10-11

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.

yjj.sh.gov.cn
02

Assuming a provincial administration reviews imported devices

Imported device registration and filing involve national-level requirements, but the current receiving route, classification and any delegated arrangements should be confirmed for the product. Do not infer the competent authority from the location of a distributor.

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.

yjj.sh.gov.cn
04

Assuming the whole dossier can be filed in English

Article 17 of SAMR Order No. 47 requires Chinese registration and filing material and the original when translated from a foreign language. Detailed dossier and attestation requirements must still be checked for the exact procedure.

www.samr.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.

yjj.sh.gov.cn
Post-market

This research did not establish a product-specific enforcement case about translation or documentation. The authority portal alone does not prove a particular inspection or recall finding.

www.nmpa.gov.cn

Common questions

Does the registration dossier have to be in Chinese?

Yes. Article 17 of SAMR Order No. 47 requires Chinese registration and filing material and the original where translated from foreign-language material. Confirm the detailed dossier and signature or seal requirements for the actual procedure.

Retrieved 2026-10-11

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?

Confirm the current imported-device class, registration or filing route and receiving authority. National rules and the actual submission procedure govern; a provincial distributor address does not establish the review authority.

Retrieved 2026-08-26

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

Check the certificate expiry, renewal or change procedure, approved product scope and rules that apply to the intended submission. A previous approval does not by itself establish that every document or source version can be reused unchanged.

Retrieved 2026-08-26

Does the translation need a translation agency stamp?

Do not infer a translation-agency stamp requirement from a general language clause. Confirm the applicable dossier annex, agent signature or seal rules and any translator declaration for the exact procedure. These attestation details were not revalidated in this review.

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?

This page is a dated public-source research record, not a complete update bulletin. Confirm the current governing regulation, classification and dossier requirements for the specific product; the source dates below should not be read as a new verification of every later amendment.

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.

  • Procedure-specific translation agency stamp, agent signature or seal, and translator declaration requirements were not revalidated.
  • 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)
  • State Administration for Market Regulation — Order No. 47 (samr.gov.cn)

Retrieved 2026-08-26

Scope of service

We do

  • Regulatory source identification
  • Regulation-status verification
  • Clause mapping
  • Regulator identification
  • Documentation-requirement mapping
  • Multilingual regulatory research
  • Terminology alignment
  • Mapping requirements to your business documents
  • Source citation with retrieval dates

We do not

  • Legal opinions
  • Legal advice
  • Legal certification
  • Notarization
  • Government filing representation
  • Litigation representation
  • Determinations reserved to licensed counsel

Regulatory research is a separate service line. It is not a tier of the L1–L4 translation service levels.

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.

Discuss your China market project

Tell us the product, the sector and the documents you already have. We will confirm the research scope before quoting.

Discuss Your China Market Project →