Who Needs to Comply?
Manufacturers
Foreign manufacturers cannot submit MDACS listing applications directly — all applications must be submitted through an appointed Local Responsible Person (LRP).
Local Responsible Person (LRP)
The LRP is a Hong Kong-based entity that:
- Submits and manages the MDACS listing application via MDIS
- Holds the HKMD listing number
- Is responsible for post-market vigilance (adverse event reporting, FSCAs)
- Maintains complaint handling records
- Tracks devices to user level for specified device types
- Notifies MDD of significant changes
Any Hong Kong-registered company can serve as LRP — commonly the HK distributor, a regulatory service provider, or a local subsidiary. See LRP Role & Obligations.
Importers & Distributors
Importers/distributors are incentivised to source only MDACS-listed devices (for Classes II–IV / IVD B–D) to satisfy procurement and hospital requirements.
Healthcare Facilities
Public hospitals must procure MDACS-listed AMDs under Stage C. Private facilities commonly impose equivalent standards.