Device Description and Specification
Required contentâ
The device description module must enable PMDA to fully understand what the device is, what it does, and how it is used. Required elements include:
Physical description:
- Complete device name (Japanese and English if applicable)
- Description of components, sub-assemblies, and materials
- Dimensions and weight range (for families/sizes)
- Photographs and diagrams illustrating the device and its components
- Description of any accessories or ancillary equipment
Functional description:
- Operating principle â how the device achieves its intended effect
- Intended use statement (Japanese language) â this will become the approved indication on the Shonin
- Contraindications
- User population and use setting (hospital, clinic, home use)
Technical specifications:
- Performance characteristics with acceptance criteria
- Output parameters (for active devices)
- Software version identification (for devices with software)
Intended use and intended purpose â Japan's framingâ
PMDA is precise about the intended use statement. The approved intended use (åščŊåšæ for drugs; äŊŋį¨įŽį for devices) is what appears on the Shonin and what the MAH is legally permitted to claim. Anything not in the approved intended use is an off-label claim under Japanese law.
The intended use must be drafted carefully before submission because changes after approval require Ichibu Henko (partial change approval).
Device families and variantsâ
If the application covers multiple sizes, configurations, or models:
- Clearly identify all variants included in the application
- Demonstrate that the worst-case variant(s) were tested in the performance and safety studies
- Provide a family rationale showing why all variants can be covered by the same application
JMDN code documentationâ
The application must include justification for the JMDN code assigned to the device. This includes:
- Statement of the JMDN code and the device type name it covers
- Explanation of why the device falls within this JMDN category
- Confirmation of the resulting risk class