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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€‹

SectionRequired Information
Site identificationFacility name, address, GPS location, contact details
PremisesDescription of buildings, zoning (manufacturing, QC, storage), cleanroom specifications
Organisational structureOrganisation chart, quality roles, qualified person(s)
Products manufacturedAll product categories manufactured at the site
Manufacturing activitiesProcess summary, key equipment, outsourced activities
Quality systemQMS standard (ISO 13485), certification details, last internal audit
Regulatory historyApprovals held in other countries; history of regulatory inspections
Recent deviationsAny significant non-conformities from recent audits

On-Site Audit Processโ€‹

  1. MAH submits SMF to NMRA Medical Devices Regulatory Division
  2. NMRA reviews SMF and determines if on-site audit is required
  3. NMRA schedules audit โ€” manufacturer notified in advance
  4. NMRA inspector(s) conduct on-site audit:
    • GMP compliance review
    • QMS implementation assessment
    • Facility and equipment inspection
    • Personnel interview
  5. Audit report issued with any findings
  6. Manufacturer addresses non-conformities
  7. 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 2โ€“3 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€‹

ActivityEstimated Duration
SMF preparation4โ€“8 weeks
NMRA SMF review4โ€“8 weeks
On-site audit scheduling and conduct4โ€“12 weeks
Non-conformity resolution and site approval2โ€“8 weeks
Total if audit required14โ€“36 weeks
Total with audit waiver8โ€“16 weeks

Start facility registration before preparing the product registration dossier โ€” particularly if an on-site audit is likely.