Foreign Facility Registration
LK-Unique ยท Mandatory pre-requisite to product registration
Overviewโ
All foreign manufacturing sites must be registered and approved by the NMRA before any product registration application can be submitted. This requirement โ unique in the region โ means that market entry planning in Sri Lanka must start with facility registration.
Site Master File (SMF) Contentsโ
| Section | Required Information |
|---|---|
| Site identification | Facility name, address, GPS location, contact details |
| Premises | Description of buildings, zoning (manufacturing, QC, storage), cleanroom specifications |
| Organisational structure | Organisation chart, quality roles, qualified person(s) |
| Products manufactured | All product categories manufactured at the site |
| Manufacturing activities | Process summary, key equipment, outsourced activities |
| Quality system | QMS standard (ISO 13485), certification details, last internal audit |
| Regulatory history | Approvals held in other countries; history of regulatory inspections |
| Recent deviations | Any significant non-conformities from recent audits |
On-Site Audit Processโ
- MAH submits SMF to NMRA Medical Devices Regulatory Division
- NMRA reviews SMF and determines if on-site audit is required
- NMRA schedules audit โ manufacturer notified in advance
- NMRA inspector(s) conduct on-site audit:
- GMP compliance review
- QMS implementation assessment
- Facility and equipment inspection
- Personnel interview
- Audit report issued with any findings
- Manufacturer addresses non-conformities
- NMRA issues site approval letter
Audit costs (NMRA inspector travel, accommodation, per diem) are borne by the manufacturer/MAH.
Audit Waiver โ Evidence Requiredโ
An on-site NMRA audit may be waived with evidence of:
Option 1 โ SRA Inspection:
- Copy of the most recent inspection report from an SRA
- SRA = FDA (USA) ยท MHRA (UK) ยท TGA (Australia) ยท EMA (EU) ยท Health Canada ยท PMDA (Japan)
- Report must be recent (typically within 2โ3 years โ confirm current NMRA requirements)
- Report should show no critical findings that would prevent continued manufacture
Option 2 โ WHO Pre-Qualification:
- Current WHO PQ certificate and scope document covering the relevant product category
Waiver application: Submit waiver request with supporting evidence to the NMRA Medical Devices Regulatory Division.
Site Approval Validity and Renewalโ
- NMRA site approval has a defined validity period
- Renew before expiry to maintain eligibility for continued product registration and importation
- Changes to the manufacturing site (new buildings, major process changes, relocation) must be reported to NMRA promptly
Planning Timelineโ
| Activity | Estimated Duration |
|---|---|
| SMF preparation | 4โ8 weeks |
| NMRA SMF review | 4โ8 weeks |
| On-site audit scheduling and conduct | 4โ12 weeks |
| Non-conformity resolution and site approval | 2โ8 weeks |
| Total if audit required | 14โ36 weeks |
| Total with audit waiver | 8โ16 weeks |
Start facility registration before preparing the product registration dossier โ particularly if an on-site audit is likely.