What is Quality System Documentation (QSD)?

QSD is a conformity assessment required for each individual foreign medical device manufacturer* to demonstrate the quality management system documentation is compliant with the regulatory requirements prior to market approval, unless specifically exempted by the competent authority.

Foreign manufacturers are required to apply for a QSD conformity assessment. The QSD Manufacturing License must be obtained before commencing production. Although the QSD application may be submitted concurrently with the medical device product registration or listing application, the Taiwan Food and Drug Administration (TFDA) require QSD approval before granting the product license or listing.

*According to the Medical Devices Act, medical device manufacturers are referring to businesses that fall into the following two types:

(1) Engaging in the manufacturing, packaging, labeling, sterilization, or final inspection and release of medical devices.

(2) Engaging in the design of medical devices and marketing the devices under their name.

*According to the Medical Devices Act, medical device manufacturers are referring to businesses that fall into the following two types:

(1) Engaging in the manufacturing, packaging, labeling, sterilization, or final inspection and release of medical devices.

(2) Engaging in the design of medical devices and marketing the devices under their name.

Medical Devices Exempted from QSD Conformity Assessment and Manufacturing License

A QSD Manufacturing License is required for most foreign medical device manufacturers. However, manufacturers of some non-sterilized medical devices falling into the product items designated by the TFDA may be exempted from the requirement to obtain a manufacturing license. The list of these specific product items may be reviewed and updated by the TFDA.

QSD Conformity Assessment Application

There are two modes of QMS regulatory requirements, i.e., Standard Mode and Essential Mode. The Essential Mode is applicable only to manufacturers producing non-sterilized product items specified in the Annex of the Medical Device Quality Management System Regulations.

The key difference between the Standard and Essential Modes lies in the scope of regulatory compliance. Under the Essential Mode, manufacturers are subject to a limited set of regulatory requirements, resulting in exemption from certain QMS procedure documents.

Moreover, there are three Abbreviated Modes are specifically available for manufacturers located in the United States, the European region (including Switzerland and Liechtenstein), and Japan. Under this mode, manufacturers may submit documentation equivalent to Medical Device QMS Requirements (i.e., Certificate of Compliance with ISO 13485) and eligible audit reports to substitute certain documentation requirements.

Medical Device QMS Requirements
(Chapters 2 to 6 of Medical Device QMS Regulations)

Standard Mode (Article 4~77)

Essential Mode (Article 11, 12, 13, 47, 55, 64, 69, 76 and 77)

Abbreviated Application Modes
(Document Substitution / Exemption)

US Manufacturing Site

EU Manufacturing Site (TCP III)

Japanese Manufacturing Site

A Summary Table of Documents Required

Application Mode Required Docs Standard NT$60,000 (US$2,000)/ Essential NT$30,000 (US$1,000)
Non-Abbreviated Abbreviated
US Manufacturing Site EU Manufacturing Site (TCPIII) JP Manufacturing Site
Commonly Required
Documents
Administrative Documents
Manufacturing Process Diagrams
Medical Device File List
Certificate of Compliance
QMS Cert
CFG/FSC/CFS
ISO 13485 ISO 13485 (MDSAP) ISO 13485 ISO 13485 or QMS Cert
(CFG or FSC/CFS) CFG FSC/CFS X
Quality Manual X X
Quality SOPS EIR/MDSAP Audit Report Inspection report issued by EU NB partners MDSAP Audit Report/QMS Inspection Report
Document Master List X X
Plant Layout Diagram X X
Production Area Information X X
Main Manufacturing and
Testing Equipment List
X X

QSD Manufacturing License

The manufacturing license will be issued to the applicants when the conclusion of the conformity assessment is compliance, which includes information about:

  1. Name and address of the medical device manufacturer
  2. Approved product items and manufacturing activities
  3. Local license holder
  4. License number
  5. Validity

Renewal

Manufacturing license reviewal is considered a form of re-registration. The renewal must be conducted every three years, with actions initiated 6 to 12 months before its expiry.
The renewed manufacturing license may maintain the previously approved scope. If needed, manufacturers may also add or remove registered product items and manufacturing activities, as long as the required documents are properly prepared and submitted.

Change Application

All change applications do not extend the original expiry date and can be categorized into two types:

  1. Significant Changes (requiring prior approval):
    • Changes to registered product items or manufacturing activities
    • Relocation of the manufacturing facility or site (requires a new QSD registration as a re-application)
  2. Administrative changes (within 30 calendar days after the change is implemented):
    • Name of the manufacturer
    • Address of the manufacturer (non-relocation)
    • Name of the local medical device firm
    • Transfer of license holder

Fees and Timelines

Application Fee TFDA Turn-around Time announced
New Application, Renewal,
and Significant Change
Standard
NT$60,000 (US$2,000)
120 calendar days
Essential
NT$30,000 (US$1,000)
Administrative Changes NT$10,000 (US$333) 60 calendar days

QSD Assessment Organizations

The QSD conformity assessment is conducted by the Taiwan Food and Drug Administration (TFDA) in collaboration with designated assessment organizations.  Currently, the designated organizations include:

  • Center for Measurement Standards of the Industrial Technology Research Institute (ITRI), 
  • Metal Industries Research & Development Centre (MIRDC), 
  • Taiwan Testing and Certification Center (ETC), and 
  • Plastics Industry Development Center (PIDC).