Self-testing IVD registration · Southeast Asia

Self-Testing IVD (Home-Use Tests) Registration in Five ASEAN Markets

Repackaging a professional assay into a single-use kit with a pictorial leaflet does not make it an approved home test. Self-testing changes the operator, the specimen collection, the interpretation of results and the consequences of misuse; more importantly, not every test is accepted for self-testing in every market. MediPass first confirms, market by market, whether your product can be filed for self-test use and at which class, then files and holds the registration through its own companies in five countries.

Singapore HSA · Malaysia MDA · Thai FDA · Vietnam MoH · Indonesia MoH

Self-testing is an intended use, not a risk class

Whether the same professional assay can be filed for self-test use differs across the five markets. Some markets do not accept self-test filings for certain tests at all: an influenza A/B self-test, for example, is currently not accepted in Malaysia but is in the other four markets. Where self-testing is accepted, the class is still decided product by product: AMDD Annex 3 Rule 4 starts at Class C with a Class B exception, an influenza A/B self-test is Class B in Singapore, while an HIV self-test is expressly Class D in Malaysia.

So MediPass’s first step is not to look up rules but to hear your plan: which products, which countries, which users. From that we confirm for each market whether the product can be filed for self-test use, at which class, and whether a disease-specific procedure applies, before we quote.

What we do for self-testing IVDs

The first question in a self-test project is “can it be done”, then “how”. MediPass first confirms whether each target market accepts a self-test filing for your product, then connects classification, evidence and filing into one plan.

Step 01Use & feasibility

Confirm whether the product can be filed as a self-test, and the class in each market

You tell us the product and the target markets; we check for each one whether self-testing is permitted for that test, which classification rule applies, which class results and whether a disease-specific requirement applies (HIV self-tests, for example). Self-testing, home collection with laboratory analysis and professional point-of-care use are judged separately, by who performs which step rather than where.

The deliverable is a market-by-market feasibility conclusion: where a self-test filing is possible and at which class, and where it is not accepted or needs a dedicated procedure.

Step 02Evidence & gaps

Review the evidence item by item once the project starts

Before quoting, we only confirm whether the product can be filed and meets the basic local requirements; once the project starts we review the analytical, clinical and lay-user usability studies item by item. Self-test evidence must cover the whole user journey: enough specimen, correct application, reading within the time window, recognising weak positives and invalid results.

The review produces an evidence gap list marking what can be used as is, what needs bridging and what needs a new study.

Step 03Labelling & IFU

Check labelling, IFU and local-language translations

A self-test IFU must suit the comprehension of the intended user, say when to consult a healthcare professional and state what the test cannot answer. We help verify the local-language label and IFU translations so that they match the filed intended use.

Some markets restrict who may supply self-tests to the public and online sales; we flag these up front in the plan, while channel and promotional arrangements remain with you and your distributors.

Step 04Filing & holding

Filed and held by MediPass’s own companies in five markets

MediPass has its own licensed company in Singapore, Malaysia, Thailand, Vietnam and Indonesia. Each can act as applicant, authorised representative or local registration holder: submitting, answering regulator queries, maintaining the certificate and carrying post-market obligations. The registration stays independent of any distributor.

See the local entities and credentials in five markets.

Change of registrant and licence-holding services

Self-test classification and requirements in five markets

The five markets start self-test IVDs at a similar class, but whether a given test is accepted for self-testing, the wording of exceptions and disease-specific procedures differ. The table compares frameworks; each product still has to be confirmed market by market.

MarketSelf-test classification basisFeasibility and specific requirements
SingaporeGN-14 R3 Rule 4: Class C start, Class B exception, decided per product (influenza A/B self-test is Class B)Professional approval is not consumer approval; the self-test use must be within the registration scope
MalaysiaMDA/GD/0001 s. 8.4: Class C start, Class B exceptionNot every test is accepted for self-testing (influenza A/B currently is not); HIV self-tests are Class D under MDA/GD/0065 with dedicated requirements
ThailandClass 1–4 under the AMDD IVD annexSelf-test use assessed product by product; HIV self-tests follow a dedicated procedure; pure self-collection kits treated as low risk
Vietnam05/2022/TT-BYT Rule 4: Class C start, Class B exceptionProcedure confirmed per product: Class A, B declaration, Class C, D registration
IndonesiaPermenkes 5/2026 Art. 55, Class A–DEvery class needs an izin edar; self-test use and disease-specific requirements verified separately

Singapore

HSA · GN-14 R3 Rule 4Self-tests start at Class C with a Class B exception

Rule 4 covers both self-testing and near-patient testing, starting at Class C with a Class B exception; the final class is decided per product. An influenza A/B self-test, for example, is Class B in Singapore. A professional-use approval is not an approval for consumer use.

View self-test notesHide notes

Section 1.4 of GN-14 R3 defines self-testing as testing by a lay person and near-patient testing as testing by healthcare professionals outside a laboratory. The GN-16 essential principles require designs to account for lay users’ skills, technique and environment and to indicate invalid results; the GN-23 labelling guidance requires a statement on when to consult a healthcare professional. Dossiers follow GN-18 R5.

MediPass Pte. Ltd. holds HSA importer’s and wholesaler’s licences and can file as the Singapore registrant.

Malaysia

MDA · MDA/GD/0001 s. 8.4Confirm that a self-test filing is accepted before classifying

Malaysia does not accept self-test filings for every test. In our project experience an influenza A/B test currently cannot be registered for self-test use there, while it can in the other four markets. Where self-testing is accepted, the product is classified under section 8.4 of MDA/GD/0001, Class C start with a Class B exception.

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HIV self-tests are the example with dedicated guidance: MDA/GD/0065 places them at Class D and sets performance thresholds, a lay-user usability report and supply-channel limits. For other self-tests, acceptance by MDA should be confirmed product by product before quoting. Applications are filed through MeDC@St by a Malaysian authorised representative.

Medipass Sdn. Bhd. holds MDA establishment licences as authorised representative, importer and distributor, with GDPMD certification, and can act as your Malaysian AR.

Thailand

Thai FDA · Class 1–4Self-test use assessed product by product

Self-test IVDs are classified Class 1–4 under the AMDD IVD annex and mapped to Listed, Notified or Licensed certificates. Whether a test can be filed for self-test use is confirmed product by product; some tests, such as HIV self-tests, follow a dedicated application procedure.

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Pure self-collection kits (specimen sent to a laboratory) are treated as low risk in principle and must be labelled as collection items only; this no longer applies once a diagnostic claim is added. Medical device advertising requires approval. The importer must first complete establishment registration.

MediPass Healthcare Solutions (Thailand) Co., Ltd. files and holds Thai registrations.

Vietnam

MoH · 05/2022/TT-BYTIVD Rule 4: self-tests start at Class C

Self-test IVDs are usually Class C with a Class B exception; near-patient blood gas and glucose are listed separately and other point-of-care tests follow their own rules. Class A and B obtain a declaration number, Class C and D a registration certificate.

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A formal classification must test the intended use against all rules, not just quote “self-tests are Class C”. Classification is carried out, under its own responsibility, by the entity filing the declaration or registration. Traders of Class B, C and D devices must complete a trading-eligibility declaration.

Công ty TNHH Medipass Việt Nam has completed the Class B, C and D trading declaration and can act as applicant and registration holder in Vietnam.

Indonesia

MoH · Permenkes 5/2026Class A–D · marketing authorisation (izin edar)

Every class needs an izin edar, and in-vitro reagents are expressly within the device definition. Self-test use and disease-specific requirements are verified product by product; COVID-19 self-tests had a dedicated circular and traceability arrangements.

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Article 55 classifies by risk and use and Article 50 sets the izin edar requirement; the regulation revokes Permenkes 62/2017. A marketplace listing that says “self-test” does not show that a self-test use is authorised, so current registration records and IFU claims should be verified before a project starts. Applications are filed by an Indonesian IDAK holder.

PT Medipass Indonesia Sejahtera holds IDAK and CDAKB certification and can act as your registration holder in Indonesia.

Feasibility first, then the quote

Tell us the product, target user, target markets and existing professional-use approvals. MediPass first confirms, market by market, whether the product can be filed for self-test use, then provides a registration roadmap and an itemised quotation: the registration service fee, the annual holding fee and government fees are listed separately, government fees are passed through at cost, and the holding fee starts one year after the certificate is issued (see the fee structure).

Request a feasibility check and quote

Frequently asked questions

Can the same product be filed as a self-test in all five markets?

Not necessarily. Some markets do not accept self-test filings for certain tests: an influenza A/B test, for example, currently cannot be registered for self-test use in Malaysia, while it can in Singapore and other markets. We confirm this for each market before quoting.

We hold a professional-use registration. Can we sell the self-test version now?

Not automatically. The approved use must be checked first, then the evidence and route for the changed user, specimen collection and packaging; professional-operator data is not lay-user data. Singapore has required professional antigen kits that reached the public to be returned.

Are all self-tests Class C?

No. Rule 4 has a Class B exception and the class is decided per product: an influenza A/B self-test is Class B in Singapore, and pregnancy and ovulation tests usually fall within the exception too. Other high-risk rules may still apply; Malaysia classes HIV self-tests as D.

Will a usability study accepted in one market be accepted in the other four?

It cannot be guaranteed in advance. Reusable data should show that the product version, language, user profile and environment apply; disease-specific requirements and regulator views must be checked in each market.

Is a home-collection kit sent to a laboratory a self-test IVD?

Usually not. With pure collection kits the laboratory performs the test; Thai FDA treats them as low risk in principle, provided the label says they are collection items only. The analysis changes as soon as the kit contains a test reaction or carries a diagnostic claim.

If MediPass holds the registration, who owns it?

The certificate is held by the MediPass local company, with ownership and control assigned to the manufacturer by agreement. You can change or add distributors at any time; MediPass does not sell products. See change of registrant and licence-holding services.

Bringing a self-test to Southeast Asia?

Tell us the product, target user, specimen type, target markets and existing professional-use approvals. MediPass first confirms, market by market, whether a self-test filing is possible, then provides a registration roadmap and an itemised quotation: the registration service fee, the annual holding fee and government fees are listed separately, government fees are passed through at cost, and the holding fee starts one year after the certificate is issued (see the fee structure).

Enquire about self-test IVD registration

Or email contact@aseanmedipass.com.

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