IVD registration · Southeast Asia

In Vitro Diagnostic (IVD) Registration in Five ASEAN Markets

Reagents, kits, calibrators, controls, analysers and companion software are classified under dedicated IVD rules in all five markets. The deciding factor is not the assay technology but what a wrong result would do to the individual and to public health. MediPass defines the product boundary, determines class and route market by market, maps your performance evidence to CSDT, and files and holds the registration through our own companies in all five countries.

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

IVD class depends on what a wrong result would change

General device classification looks at invasiveness, contact site and duration of use. IVD classification looks at the disease tested, the population, who runs the test, whether the result is the key basis for diagnosis or treatment, and whether public-health risks such as blood-donor screening are involved. “The test never touches the patient” does not prove low risk, and “the assay is highly accurate” does not lower a class that the intended use triggers.

MediPass first writes the intended use as one statement that can run through all five submissions: analyte, specimen, population, user, setting and the action taken on the result. We then test it against each market’s IVD rules (HSA GN-14, MDA/GD/0001, AMDD Annex 3 and the Vietnamese and Indonesian rules), recording the clauses applied and excluded. Professional and self-test use, single reagents and complete systems, are argued separately.

What we do for IVD products

From regulatory scope to local licence holding, MediPass delivers the full IVD registration through its own entities in five markets. A typical project runs through four steps.

Step 01Boundary & class

Define the product boundary and determine the IVD class per market

A testing solution often bundles a sampling device, an analyser, reagents and software, and each component needs its own boundary: generic laboratory items do not become IVDs by entering a lab, instruments and reagents may be classified separately, and combined systems take the highest risk of the final intended use. We then determine the class under each market’s IVD rules, applying the highest class where several rules apply.

At the end of this step you have the IVD risk class for each of the five markets and the classification rule each conclusion relies on.

Step 02Evidence & gaps

Map analytical and clinical performance evidence to CSDT

Analytical performance (detection limit, precision, interference, cross-reactivity, stability) and clinical performance (diagnostic sensitivity and specificity, method comparison, clinical cut-offs) answer different questions, and all five markets expect both. We map your existing reports to the local submission structure (HSA GN-18 R5, the MDA IVD CSDT and others) and mark what is usable as is, what needs explanation and what needs a new study.

Before quoting, we confirm whether the product can be filed in each target market; once the project starts we review the performance reports item by item, so you know which performance evidence still has to be generated before anything is filed.

Step 03Route & grouping

Plan application scope, assessment route and labelling

We decide which configurations, pack sizes and companion items can share an application, check eligibility for abridged or reliance routes based on reference-agency approvals, and review local labelling, IFU language and user restrictions at the same time. Route eligibility depends on approval scope and intended-use consistency, not on risk class alone.

Output: a market-by-market registration roadmap with number of applications, route, applicant entity, official fees and expected timelines.

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, so you keep control of your sales channels.

See the local entities and credentials in five markets.

Change of registrant and licence-holding services

IVD classification and registration requirements in five markets

All five markets have dedicated IVD classification rules with four tiers, but the treatment of low-risk IVDs and the filing procedures differ. The table compares frameworks; a specific product’s class still has to be argued rule by rule.

MarketIVD classification basisMarket-entry procedureLow-risk IVD handling
SingaporeGN-14 R3 · Class A–DHSA product registration (Class B–D)Class A exempt from product registration; dealers still need an HSA dealer’s licence
MalaysiaMDA/GD/0001 · Class A–DMDA product registration (Class A–D)Class A exempt from CAB conformity assessment, but still registered with MDA
ThailandAMDD IVD annex · Class 1–4Listed (1) · Notified (2–3) · Licensed (4)Class 1 still requires a Listed certificate
Vietnam05/2022/TT-BYT rules · Class A–DClass A, B: declaration number · Class C, D: registration certificateClass A and B obtain a number through the declaration procedure
IndonesiaPermenkes 5/2026 · Class A–DMoH marketing authorisation (izin edar)Every class needs an izin edar; in-vitro reagents and calibrators are expressly within the device definition

Singapore

HSA · GN-14 R3IVD risk classification · GN-18 R5 IVD submission guidance

IVDs are classified under GN-14, not the general-device GN-13. Class A is exempt from product registration; Class B–D register under the GN-15 R15 routes with a CSDT dossier prepared to GN-18 R5 (October 2026).

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GN-14 R3 classifies on two axes, individual risk and public-health risk. Rule 4 starts self-test and near-patient tests at Class C with a Class B exception; higher-risk rules must still be checked. GN-18 R5 expects analytical and clinical performance to be presented separately, and the full evaluation route may require an independent clinical evaluation.

MediPass Pte. Ltd. holds HSA importer’s and wholesaler’s licences and SS620 GDPMDS certification, and can file IVD registrations as the Singapore registrant.

Malaysia

MDA · MDA/GD/0001IVD medical device classification system (2nd ed.)

Every IVD class is registered with MDA. Class A skips CAB assessment and is filed directly; Class B, C and D need CAB conformity assessment first. Blood-donor screening claims lead to Class D.

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Section 8.4.1 of MDA/GD/0001 lists near-patient blood gas and glucose at Class C and classifies other near-patient IVDs under their own rules, a different structure from Singapore’s Rule 4 that cannot simply be copied. HIV self-tests follow the dedicated MDA/GD/0065 guidance and are Class D. 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 1–4Classified under the AMDD IVD annex · three procedures

IVDs are classified Class 1–4 under the AMDD IVD annex and mapped to Listed, Notified or Licensed certificates; the importer must first complete establishment registration.

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Class 2–4 dossiers follow a full, abridged or reliance-with-HSA route. Pure self-collection kits (specimen sent to a laboratory) are treated as low risk in principle, but not once a diagnostic claim is added. HIV-related reagents and self-tests carry specific requirements. Products may be marketed only after the certificate is issued; advertising needs separate approval.

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

Vietnam

MoH · Class A–D05/2022/TT-BYT classification rules · Decree 98/2021 consolidated text

IVD instruments, reagents and systems may be classified separately, with combined systems judged on the highest risk of the final use; Class A and B obtain a declaration number, Class C and D a registration certificate.

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The annex to 05/2022/TT-BYT sets the IVD classification rules; self-test IVDs are Class C in principle with a Class B exception. Article 21 of consolidated text 08/VBHN-BYT distinguishes the two types of number; 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 with the Ho Chi Minh City Department of Health and can act as applicant and registration holder in Vietnam.

Indonesia

MoH · Class A–DPermenkes 5/2026 (effective 4 May 2026)

In-vitro reagents and calibrators are expressly within the medical device definition, and every class needs a marketing authorisation (izin edar) before distribution; applications are filed by an Indonesian entity holding an IDAK.

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Article 55 keeps the A–D risk classes and adds categories by principal function; Article 50 sets the izin edar requirement. The regulation revokes Permenkes 62/2017, so older product catalogues and guidance should be checked before use.

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

Plan a five-market IVD registration project

Tell us the product, intended use, target markets and existing approvals. MediPass first confirms whether the product can be filed in each market, then provides a registration roadmap and an itemised quotation.

Request an assessment and quote

Frequently asked questions

Is every reagent used in a laboratory an IVD?

No. What matters is whether the intended use and product claims point to in vitro examination of human specimens for a diagnostic purpose. Generic laboratory items do not become IVDs by being used in a lab; calibrators, controls, analysers and specimen receptacles may be IVDs when presented for a specific IVD use.

Our assay is highly accurate. Can that lower the risk class?

No. Class follows intended use and the applicable rules; performance evidence shows that the claims hold. Classes triggered by blood-donor screening or infectious-disease claims are not reduced by strong performance.

Our IVD is Class A in Singapore. Is it exempt from registration elsewhere?

No. Malaysia still registers Class A with MDA; Thailand requires a Listed certificate for Class 1; Vietnam requires a declaration number for Class A; Indonesia requires an izin edar for every class. Classification and exemptions must be confirmed market by market.

Our professional-use IVD is registered. Can we simply add a self-test claim?

Not automatically. Self-testing changes the user, the specimen collection and the interpretation of results, so lay-user usability evidence and a fresh classification argument are needed. See self-testing IVD registration.

Do analysers and reagents need separate registrations?

It depends on the market and how the products are combined. Grouping rules for systems, dedicated reagents and open instruments differ across the five markets, and Vietnam expressly judges combined systems on the highest risk of the final use. The roadmap sets out the application split for each market.

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 an IVD to Southeast Asia?

Tell us the product, its intended use, your target markets and existing approvals. MediPass first confirms whether the product can be filed in each market, then provides a registration roadmap and an itemised quotation.

Enquire about IVD registration

Or email contact@aseanmedipass.com.

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