PPWR imposes on all companies placing packaging on the EU market a full chain of obligations spanning substances, design, and recyclability. Medical device companies are no bystanders — although, given the special nature of their products, the primary packaging in direct contact with the product enjoys certain relaxations with regard to "recyclability" and "recycled content," core responsibilities such as minimization, hazardous substances, labeling, EPR, and the Declaration of Conformity apply in full. There is therefore no such thing as a complete exemption for medical device packaging under the PPWR framework.

The previous section outlined the general process and basic compliance requirements for NMPA renewal registration, helping enterprises successfully complete applications under routine circumstances. However, in practice, many overseas medical device companies face not standardized renewal scenarios but complex special situations involving mandatory standard updates (e.g., GB 9706), dynamic product classification adjustments, conditional approval compliance, and changes in import agents. These scenarios often fall outside the scope of general procedures, and mishandling any single step may lead to rejection of the renewal application, certificate invalidation, or even product withdrawal from the market. Therefore, this section provides clear compliance solutions for six high-risk special scenarios.

Within China's medical device import compliance system, NMPA registration certificate renewal is a routine compliance task for overseas medical device manufacturers, yet it is also a core area where compliance errors and certificate invalidation most frequently occur. Compared to domestic enterprises, overseas manufacturers commonly face challenges such as delayed access to regulatory updates, differences between Chinese and foreign compliance systems, poor control over timing, inadequate awareness of standard updates, and unfamiliarity with the agent liaison process. Many overseas companies often miss the statutory six-month application window, confuse the order of change registration versus renewal, fail to promptly adapt to new standards like GB 9706, or mishandle classification adjustments. These issues prevent normal renewal, leading to certificate expiration and forcing a complete de novo registration process, consuming substantial time, resources, and compliance costs, and directly disrupting market access in China.

China has formally launched and enforced its unified Medical Device Vigilance System, built on the newly issued Good Practice for Medical Device Vigilance (Trial) and a full set of supporting guidelines, marking a major upgrade of post-market surveillance (PMS) regulation covering the full product lifecycle. The regime places registrant responsibility at its core and establishes mandatory requirements for vigilance organization, data collection, risk control, and standardized reporting for all medical devices sold in China.

In 2026, China’s NMPA has intensified its overseas inspections of medical device manufacturers, with 33 companies targeted for unannounced on-site or remote audits. The new version of the Medical Device Good Manufacturing Practice (GMP) will take effect in November 2026, emphasizing data authenticity, lifecycle traceability, risk management, and contract manufacturing controls. Several overseas companies have already faced import suspensions due to compliance failures. To maintain market access, overseas manufacturers are advised to proactively conduct self-audits, respond quickly to inspection notices, and implement corrective actions. Consulting support is available to help navigate the stricter regulatory landscape.

The medical device technical team of CIRS Group was invited to attend the event, and jointly held a special seminar on FDA & CE MDR Certification and NMPA Clinical Evaluation with the organizer. Empowering Chinese, Korean and global medical device enterprises to comply with regulations and expand overseas with professional regulatory services, CIRS Group has gained high attention and wide recognition from the industry.

On October 16, 2025, the Shanghai Municipal Medical Products Administration, Shanghai Municipal Health Commission, and Shanghai Customs jointly issued the Shanghai Pilot Work Plan for Service Guidance on Temporary Import of Clinically Urgent Drugs and Medical Devices. 《上海市关于临床急需药械临时进口服务指导工作方案（试行）》This new plan aims to streamline the temporary import process for clinically urgent drugs and medical devices in Shanghai, helping patients gain faster access to innovative medical products.

Polycarbonate (PC), as a biodegradable polymer material, has various application scenarios in the medical field. These include disposable ophthalmic surgical knives, ophthalmic trocars/cannulas, polymer materials and products for dentures, orthopedic core drill, auxiliary instruments for vertebroplasty, and ring-handle syringes. As a raw material for medical device products, PC can undergo Master File registration. This authorizes medical device registration applicants to reference it as part of their regulatory submission when applying for medical device registration.

PPDO (Poly-p-dioxanone) is a class of aliphatic poly(ether-ester) polymers renowned for their excellent mechanical properties, biocompatibility, and biodegradability. As early as the last century, it was approved by the U.S. FDA for use in manufacturing Class III medical devices. It serves as a key material for producing absorbable sutures, cosmetic lifting threads, ligation clips, abdominal meshes for hernia repair, and other implantable devices. PPDO, along with its copolymers, blends, and composite materials, is also being developed for applications in bone repair, vascular stents, tissue adhesives, drug sustained-release carriers, and aesthetic products such as "ELLANSé" and "SCULPTRA".

The Medical Device Master File is a form of technical documentation submitted by its owner to the medical device technical review authority. It is used to authorize medical device registration applicants to reference it as part of their registration submission materials when applying for medical device registration. The Medical Device Master File system facilitates the selection of raw materials and key components by medical device manufacturers and simplify the registration and application process. Simultaneously, the principle of voluntariness and confidentiality for the master file registration effectively protect the intellectual property rights of the master file owner.