China Clinical Trials

China has emerged as a significant player in the global clinical trials landscape, with a growing number of trials being conducted within the country.

The need to perform studies for your device or IVD for the purposes of product approval in China varies depending on their risk classification, whether exemptions exist, and the legal requirements for clinical data.

The complexities and regulatory requirements surrounding clinical trial approvals in China can affect the efficiency of the trials, with necessary documentation and quality control challenges.

Urgent clinical development
Clinical evidence

Considerations Before Starting CTs in China

Clinical Trial Exemptions

Qualifying for an exemption usually means that the device or the IVD is listed in their respective exemption catalogues:

NMPA Medical Device Clinical Evaluation Exemption Catalogue
NMPA IVD Clinical Evaluation Exemption Catalogue.

Although IVDs included in the exemption list can avoid general trials, clinical studies in China are usually unavoidable.
The National Medical Products Administration (NMPA) publishes and updates these clinical evaluation exemption lists, known as catalogues, on a regular basis. Please check with us to determine if your product is on these lists.

Predicate Comparison

A clinical study may not be necessary if you can demonstrate substantial equivalence to an approved device or IVD in the People's Republic of China (PRC) through a CER.

Please note that if there are significant differences in the intended use, technical features, or biological characteristics compared to devices already approved in the PRC, the product is generally classified as a new type of device. In such cases, the predicate device pathway is typically not applicable, and a clinical evaluation is usually required based on study data—either from a trial conducted overseas or in the PRC.

Use of Overseas Data

If the declared product has undergone studies outside the PRC that meet or exceed the requirements of Chinese regulations, the product can avoid having to undertake studies in the PRC.

Use of Real-World Data

Another alternative is the use of Real-World Data from sources such as patient-generated data or data derived from electronic health records. As specific guidelines for RWD have not yet been released, this data is typically used as supplementary information in Clinical Evaluation Reports.

Risk Classification

Clinical trials are not necessary for Class I devices or IVDs.
Class II & III devices and IVDs may qualify for an exemption.

China Clinical Trials Registry

The Chinese Clinical Trial Registry, established by the NMPA, serves as the primary registry, providing a centralized platform for trial application, approval, and monitoring.

This registry is a crucial tool for ensuring transparency and accountability in clinical research. It allows for systematic tracking, from their inception to completion, ensuring they meet the stringent regulatory standards set by the NMPA. This registry not only facilitates the approval process but also helps in maintaining high standards of quality control and compliance with the Personal Information Protection Law.

Role of a China Agent

Clinical Trial Process for MDs & IVDs in China

There is a structured process and procedures to follow to ensure the study meets NMPA regulatory requirements. Here is an overview of the key steps:

1

Development & Strategy Consulting

Relevant clinical endpoints to assess safety and effectiveness
Study design and methodology
Patient selection criteria
Data collection and analysis methods

2

Ethics Approval & Trial Registration

Submitting the protocol for ethics committee approval at the study site(s).
For those involving Class II devices and certain Class III products that meet specified conditions, the applicant must submit a notification to the drug regulatory authority of the corresponding province and obtain a filing number before commencing the study in humans.
For those involving high-risk Class III devices (such as implants or life-support devices), the applicant must submit an application to the NMPA. The study may proceed only after the application has passed a technical review and received authorization. The NMPA must issue a decision within 60 working days of accepting the application; if no decision is issued within this timeframe, the application is considered approved by default.

3

Conducting the Clinical Trial

Patient recruitment
Device application and monitoring
Data collection and interim analysis.

For implants or other high-risk devices, preclinical animal studies are often required before the human trial stage to validate safety and biocompatibility.

4

Data Collection, Analysis, & Clinical Trial Report

The collected data is analyzed and summarized.
Patient A final Clinical Trial Report (CTR) is prepared, detailing the outcomes.

5

Submission to the NMPA

The CTR and trial protocol must be included in the submission dossier when applying for device and IVD marketing authorization. The NMPA will review the data to assess whether the necessary safety and efficacy standards have been met.

Our China Clinical Trials Services

We make medical device and in vitro diagnostic (IVD) CTs in the PRC easier by guiding you through Chinese regulations, Good Clinical Practice (GCP) standards, and ethical requirements. With our expert support, we help you navigate the process smoothly, stay compliant, and move efficiently toward marketing authorization.

Our services include:

CT Strategy & Regulatory Assessment

We design tailored clinical development strategies aligned with product type, classification, and regional requirements. Our roadmaps integrate regulatory timelines, resource planning, and clinical milestones to support both early-stage feasibility and late-stage execution.

Feasibility analysis: Assess whether requirements or exemptions apply.
Regulatory roadmap: Develop a customized strategy for NMPA approval.
Compliance evaluation: Ensure adherence to the PRC's Good Clinical Practice (GCP) for Medical Devices (Decree #25).

Type Testing & Pre-Trial Preparation

Local type testing coordination at an NMPA-designated lab to meet China’s standards.
Clinical trial protocol (CTP) drafting, ensuring alignment with NMPA requirements.
Ethics Committee (EC) approval support, including preparation of required documentation.
Registration of the CT with NMPA where applicable.

Clinical Trial Execution Support

Selection of accredited clinical trial sites in China.
Negotiation of contracts with sites and medical institutions.
Monitoring of trial progress, ensuring compliance with protocol and GCP guidelines.
Adverse event reporting and safety monitoring.

Data Management & Submission

Data collection and analysis in compliance with NMPA submission standards.
Preparation of the Clinical Trial Report (CTR), summarizing results for regulatory review.
Submission to NMPA as part of the registration dossier for device or IVD market authorization.

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