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Overview of Specialized Approval Systems for Medical Devices

The PMDA manages several frameworks to expedite the regulatory process based on the specific characteristics and clinical needs of medical devices.

A. Needs-based Medical Device System

    • Purpose: To facilitate the rapid introduction of unapproved medical devices that address high medical needs in Japan.

      Designation Process: Submission of a request form (by academia/patient groups) → Deliberation by the Needs-based Working Group (WG) → Official designation by the parent committee → "Request for Development" by the MHLW to companies.

      Regulatory Benefit: Designated devices qualify for Priority Review, which targets a reduction in the standard review timeline from 12 months to 9 months.

  • B. Rebalancing Notice

    • Purpose: To optimize the balance between pre-market and post-market data collection for devices that undergo frequent iterations, where conducting full clinical trials for every change is difficult.

      PMDA Pre-submission Consultation: The feasibility of utilizing this framework is determined through PMDA's pre-sub consultations, specifically utilizing Pre-development Consultation (KaihatsumaeSoudan) and Clinical trial Necessity Consultation (RinshoshikeYouhiSoudan).

      Example of Rebalancing: Includes the "Two-stage Approval" approach. For example, initial approval may be granted for a limited intended use based on calculated parameters, which is later expanded based on the clinical significance validated through post-market data.

  • C. Sakigake Designation System

    • Purpose: To prioritize the review of innovative products developed first in the world and initially applied for in Japan.

      Designation Process: Initial consultation with the MHLW (Initial Consultation) → (PMDA Pre-development Consultation) → Submission of Sakigake designation application → Official designation (decided through Bukai deliberation). All four (4) designation criteria must be met.

      Regulatory Benefit: Provides intensive support including prioritized PMDA consultations, Priority Reviews, and the assignment of a PMDA Concierge to guide the development process.

  • D. Specific-use Medical Device Designation System

    • Purpose: To promote the R&D of devices where medical needs are significantly unmet, such as those lacking pediatric dosage or usage settings.

      Designation Process: Submission of a request to the MHLW → PMDA Pre-development Consultation and evaluation by the Needs-based WG → Official designation via Council deliberation.

      Regulatory Benefit: Access to prioritized consultations and Priority Reviews to enhance pre-evaluation for early approval.

  • E. Conditional Early Approval System (Type 1 & Type 2: PHOENIX System)

    • Purpose: To grant early approval for devices intended for rare diseases where completing standard clinical trials would take an excessively long time due to small patient populations.

      Designation Process: PMDA Pre-development Consultation (Confirming eligibility) → Clinical Trial Necessity Consultation (including the evaluation of the Risk Management Plan: RMP).

      Post-market Requirements: Approval is linked to a Risk Management Plan (RMP), requiring a "Use Results Evaluation" (post-market surveillance) after the product is on the market.

      Regulatory Benefit: Waiver of clinical trial requirements if specific criteria of Type 1 & 2 are met.

  • F. Pre-confirmation System for Change Plans (IDATEN System)

    • Purpose: A system that approves the "Improvement/Change Plan" itself for devices expected to undergo frequent post-market modifications.

      Designation Process: PMDA Pre-development Consultation (functioning as a consultation on eligibility for the time being) → Submission of Application or Notification for the change plan → Post-market updates via Minor Change Notification in accordance with the pre-confirmed plan.

      Regulatory Benefit: If changes are made according to the pre-confirmed plan and achieve the expected results, a full Partial Change Application (Ichihen) is not required for each update.

      This is particularly applicable to Software as a Medical Device (SaMD).