APAC I JAPAN
Japan
Medical devices in Japan are regulated by the Pharmaceuticals and Medical Devices Agency (PMDA) under the policy authority of the Ministry of Health, Labour and Welfare (MHLW). The governing rule is straightforward in principle: under the Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices (the PMD Act), no device may be placed on the Japanese market without the appropriate marketing approval, certification or notification, and that authorisation can only be held by a Japan-resident Marketing Authorisation Holder.
Regulatory Complexity
HIGH
REGION
APAC
REGULATORY AUTHORITY
PMDA I MHLW
Pharmaceuticals and Medical Devices Agency
Ministry of Health and Welfare
CLASSIFICATION
CLASS I TO IV
LOCAL REPRESENTATIVE
MANDATORY
Japan-resident MAH

Spit Spot Summary
Japan operates a mature, risk-based regulatory system led by PMDA under MHLW, structured around the PMD Act and a four-tier classification (Class I to IV). Market access runs through three routes: notification, third-party certification by a Registered Certification Body (RCB), and full PMDA approval, scaling with device risk. A Japan-resident Marketing Authorisation Holder (MAH) is mandatory and non-transferable, quality management follows ISO 13485:2016 as implemented through MHLW Ordinance No. 169, and post-market surveillance obligations are substantial. As an MDSAP participating market, Japan can recognise MDSAP audit reports within its QMS conformity assessment, which can streamline the quality element of an application.
PHASE 01
Scoping the Market
PMD Act I MHLW & PMDA
Who regulates medical devices in Japan?
The Ministry of Health, Labour and Welfare (MHLW) sets overall health policy and the regulatory framework, while the Pharmaceuticals and Medical Devices Agency (PMDA) handles marketing approvals, scientific review and QMS audits. For certain lower-risk device groups, Registered Certification Bodies (RCBs)carry out third-party conformity certification.
PMD Act Art. 23-2-5(1); Art. 23-2-23(1)
Do I need approval before selling a device there?
Yes. No device may be marketed without the appropriate authorisation. Higher-risk devices require marketing approval for each item from PMDA (PMD Act Art. 23-2-5(1)); designated lower-risk devices instead obtain certification from an RCB (Art. 23-2-23(1)); the lowest-risk devices require only a marketing notification to PMDA.
PMD Act Art. 2(5)-(7); Art. 23-2-25, 23-2-23, 23-2-12
How are devices classified?
Japan uses a four-tier, risk-based scale (Class I to Class IV) mapped onto the PMD Act categories of general, controlled (Class II) and specially-controlled (Classes III–IV) medical devices. IVDs follow an aligned classification and, for the lowest class, a notification route, with certification or approval at higher classes.
PMD Act Art. 23-2(1); Art. 23-2-4 (foreign manufacturer)
Can we sell directly, or do we need someone local?
You need someone local. Only a Marketing Authorisation Holder (MAH) resident in Japan, an individual or legal entity holding a marketing licence from the prefectural government, can hold the authorisation and take full responsibility for post-market activities. Japan operates a single-MAH-per-device model; the MAH cannot be a foreign entity, and the authorisation cannot be transferred or shared between MAHs. Foreign manufacturers must additionally obtain foreign manufacturer registration for each manufacturing facility exporting to Japan (Art. 23-2-4).
PHASE 02
Planning the Submission
MHLW Ministerial Ordinance No. 169 (MO 169)
What quality management system is required?
Japan requires a quality management system aligned with ISO 13485:2016, implemented domestically through MHLW Ministerial Ordinance No. 169 (the QMS Ordinance). A QMS conformity certificate is required for Class II–IV devices, registered manufacturing-site designation applies, and design & development controls apply to Classes II–IV. As an MDSAP market, Japan can accept an MDSAP audit report toward the QMS conformity assessment.
PMD Act. Art. 23-2-5(11)-(12); 23-2-23(6)-(7)
How long is the authorisation valid, what happens when a device changes?
A marketing approval/certification remains effective for the approved device but is subject to ongoing obligations and periodic renewals of related registrations (for example, certain registrations renew on fixed multi-year cycles under the PMD Act). When a device changes, the route depends on significance: a partial-change application (审查/re-review) is required for significant changes affecting safety, efficacy or specifications, while minor changes are handled by notification.
MHLW MO 169 (labelling); Essential Principles 13 / 13A
What language must the labelling be in?
Japanese-language labelling is mandatory. The MAH name and address must appear on the label, instructions for use must be provided in Japanese, and patient implant cards are required for applicable implantable devices (Essential Principle 13A). Technical documentation submitted to PMDA is generally expected in Japanese.
CONSIDERING JAPAN FOR MARKET ENTRY?
Japan is rarely a standalone decision.
Most of the manufacturers I work with are sequencing Japan alongside several other markets and the MAH model, the MO 169 QMS route and your MDSAP strategy all interact with how you've set up elsewhere. If you tell me your device class and where you already hold approvals, I can tell you quickly where Japan fits in the programme and where the real timeline risk sits.
Disclaimer. This country profile is based on publicly available regulatory information and professional analysis. It does not constitute legal advice. Companies must verify all requirements with qualified local legal counsel and regulatory authorities before making market entry decisions. Last updated: 2026/06 — verify with current sources.