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.

Useful Articles

View More

Understanding Local Testing for Medical Devices & IVDs in Indonesia: Requirements & Registration Guide

Learn when local testing is required for medical devices and IVDs in Indonesia, which products are affected, and how testing impacts registration requirements.

August 31, 2026
Understanding Local Testing for Medical Devices & IVDs in Indonesia: Requirements & Registration Guide
An Indonesian male medical professional in profile, wearing dark blue scrubs, a blue surgical cap, safety glasses, a white mask, and a blue-tubed stethoscope, presses a button on a dual-monitor medical control panel in a clinical operating setting.

China Medical Device GMP vs ISO 13485: Key Differences Explained

Understand the key differences between China Medical Device GMP and ISO 13485, including requirements for quality management, suppliers, facilities and documentation.

August 26, 2026
China Medical Device GMP vs ISO 13485: Key Differences Explained
Two Chinese medical device technicians, a woman and a man wearing white lab coats, surgical caps, face masks, and protective gloves, stand side by side in a sterile cleanroom environment.

5-Step Guide to Taiwan Medical Device Classification (TFDA)

How to determine medical device classification in Taiwan: the TFDA catalogue, the 16 categories, Class I-III risk levels, and what to do when no item matches.

August 21, 2026
5-Step Guide to Taiwan Medical Device Classification (TFDA)

Guide to Indonesia Medical Device Post-Registration Changes: Notification, Variation, or New Registration

Learn when medical device and IVD changes in Indonesia require a notification, variation, or new registration, and how to maintain ongoing regulatory compliance.

August 5, 2026
Guide to Indonesia Medical Device Post-Registration Changes: Notification, Variation, or New Registration

How Vietnam Medical Device Registration Works (Timelines, Fees, & AR Strategy)

Gain an overview of the medical device registration process in Vietnam with timelines, fees, and Authorized Representative requirements.

August 4, 2026
How Vietnam Medical Device Registration Works (Timelines, Fees, & AR Strategy)

Understanding the ASEAN Medical Device Market: Comparing 6 Strategic Markets

Explore the medical device market opportunities, regulations, and registration pathways across Malaysia, Singapore, Vietnam, and other key ASEAN countries.

August 4, 2026
Understanding the ASEAN Medical Device Market: Comparing 6 Strategic Markets
Previous
Previous

Explore Related Services

Whether you’re just starting out or are a blue-chip, access our wide range of services and solutions to help your business thrive.

Medical Device Registration

We guide you through every step of the process. We take care of compliance with NMPA requirements, advising you on the optimal market entry pathway, and helping you through the whole process.

Learn more

Drug Device Combination Products

We assist with the classification, registration and compliance of combination products in the PRC, whether drug or device led.

Learn more

China NMPA IVD Registration

We support you through every stage of the process, ensuring compliance with NMPA regulations. From choosing the best market entry strategy to handling regulatory requirements, we make the process as smooth as possible.

Learn more

NMPA Clinical Evaluation Report

Clinical Evaluation Reports can avoid the need for a China clinical trial in some instances. Our experts can advise and prepare NMPA compliant CERs.

Learn more

NMPA Legal Agent

We are your authorized representative in China, and fulfill your registrations and filings as well as ensuring compliance and PMS requirements.

Learn more

NMPA Type Testing

Our on-site test engineers coordinate and supervise type tests of your medical products in NMPA-accredited laboratories.

Learn more

Device PMS & Vigilance

The NMPA is placing greater focus on Post-Market Surveillance (PMS) such as more in-market sampling inspections and regular standard changes.Our specialist PMS team means you stay up to date with the many aspects of compliance.

Learn more

Regulatory Outsourcing

If you are seeking specific specialist expertise or have ongoing resource-intensive needs, we have a variety of solutions to meet your needs.

Learn more

China Device Quality Compliance

We help you achieve and ensure ongoing compliance with Chinese requirements.Our experts prepare and assist you for official NMPA inspections.

Learn more

Latest Insights

View More

Malaysia NPRA Updates Cosmetic Ingredient Requirements Under the ASEAN Cosmetic Directive

Circular No. 2/2026 revises prohibited, restricted, colorant, and preservative requirements for cosmetics marketed in Malaysia.

August 20, 2026
Malaysia NPRA Updates Cosmetic Ingredient Requirements Under the ASEAN Cosmetic Directive

China Overhauls Cosmetic Safety Rules with GB 7916-2026: Is Your Brand Ready?

Brands must audit ingredients, suppliers and packaging before January 2028 to ensure compliance with GB 7916-2026.

August 18, 2026
China Overhauls Cosmetic Safety Rules with GB 7916-2026: Is Your Brand Ready?
Scientist in clean modern room inspects cosmetics.

China Expands Animal Testing Data Exemptions in Major Cosmetics Registration and Filing Reform

Companies can benefit from expanded toxicology data exemptions, simplified cosmetics registration procedures, and more efficient compliance pathways

August 18, 2026
China Expands Animal Testing Data Exemptions in Major Cosmetics Registration and Filing Reform

Taiwan Extends Cosmetic GMP Requirements to Nearly All Manufacturing Sites

As of July 1, 2026, Taiwan has completed its cosmetic GMP rollout, extending mandatory ISO 22716-based manufacturing standards to nearly all cosmetic factories

August 18, 2026
Taiwan Extends Cosmetic GMP Requirements to Nearly All Manufacturing Sites

China Updates New Cosmetic Ingredient Registration Rules: Several Higher-Risk Ingredient Categories Removed

New NCI rules reduce administrative burden, streamline dossiers, and expand opportunities to reuse existing safety data.

August 18, 2026
China Updates New Cosmetic Ingredient Registration Rules: Several Higher-Risk Ingredient Categories Removed
This stock photo features a close-up, high-angle shot focusing on a skincare product arrangement set against a light-colored, wood-grain surface.

NMPA Opens Consultation on Two Draft Cosmetic Adverse Reaction Standards: Cosmetic Cheilitis & Cosmetic Contact Urticaria

Review China's new draft standards for cosmetic cheilitis and contact urticaria before the August 15, 2026, consultation deadline.

August 18, 2026
NMPA Opens Consultation on Two Draft Cosmetic Adverse Reaction Standards: Cosmetic Cheilitis & Cosmetic Contact Urticaria
Previous
Previous

Get in Touch with Our Life Sciences Team

And discover how we can support you in undertaking the Type Testing for your medical device or IVD in China.

Request Proposal