Drug Device Combination
Products

The National Medical Products Administration (NMPA) defines drug-device combination products as medical products composed of both drugs and medical devices, integrated into a single entity.

To register a combination product with the NMPA, you must first determine the product’s Primary Mode of Action (PMOA):

Drug-led combination products registration applications must be submitted to the Center for Drug Evaluation (CDE)
Device-led combination products must be submitted to the Center for Medical Device Evaluation (CMDE).

If the device PMOA is unclear, applicants can apply for an attribute definition from the NMPA’s Center for Medical Device Standards Management (CMDSM) before submitting the premarket approval application.

Single entity combination products
Drug products inside delivery device

Joint Evaluation of Drug Device 
Combination Products

During a joint evaluation, the CDE and CMDE collaborate to assess the product's safety, effectiveness, and quality control. Each center issues an evaluation report covering its respective component, and the leading unit consolidates these findings into an overall evaluation report. This report is then submitted to the relevant NMPA department for administrative approval.

For drug-led combination products, the CDE leads the evaluation. If a joint evaluation is required, the application dossier is transferred to the CMDE for synchronized evaluation.

For device-led combination products, the CMDE leads the evaluation. If a joint evaluation is required, the dossier is transferred to the CDE.

During a joint evaluation, the CDE and CMDE collaborate to assess the product's safety, effectiveness, and quality control. Each center issues an evaluation report covering its respective component, and the leading unit consolidates these findings into an overall evaluation report. This report is then submitted to the relevant NMPA department for administrative approval.

Our China Drug-Device Combination Product Services

With expertise in both pharmaceutical and medical device regulations, we assist with the classification, registration and compliance of both drug and device-led combination products.

‍Our services include:

Regulatory Pathway Assessment

If uncertain, we assist in applying for an attribute definition with the Center for Medical Device Standards Management (CMDSM).
Determine the product’s primary mode of action (PMOA) to classify it as drug-led or device-led.

Registration Strategy Development

Develop a customized regulatory strategy aligned with the requirements of the Center for Drug Evaluation (CDE) or the Center for Medical Device Evaluation (CMDE), depending on the product’s classification.
Coordinate with both centers for joint evaluations as required.

Dossier Preparation & Submission

Ensure that documentation covers both drug and device components, including safety, efficacy, and quality control data including the necessary type testing in China.
Prepare and compile the registration dossier, ensuring compliance with NMPA guidelines.
Submit the application through the NMPA online platform.

Clinical Trial Application (CTA)

Ensure compliance with Good Clinical Practice (GCP) standards for both drug and device components.
Assist in obtaining approval for clinical trials if required.

Communication & Coordination with Regulatory Authorities

Liaise with the CDE and CMDE to facilitate the evaluation process.
Address enquiries and provide additional documentation as requested by regulators.

Post-Approval Compliance

Ensure compliance with post-market surveillance requirements, including pharmacovigilance and medical device vigilance.
Support registration renewals, variations, and amendments.

Request a Proposal from Our Life Sciences Team about Your Combination Product

Let Cisema help turn your plans into reality.

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