Registration Pathway Overview
NMRA ยท Two-step market entry ยท Consolidated Dossier ยท F-MDR-035
The Two-Step Market Entry โ LK-Uniqueโ
Sri Lanka requires two separate regulatory approvals before a device can be commercially supplied:
| Step | Approval | What It Means |
|---|---|---|
| 1 | Registration Certificate | Device assessed and found to meet NMRA safety and performance requirements |
| 2 | Import Licence | Device may be commercially imported and supplied to the Sri Lankan market |
Each step requires a separate application to the NMRA. The Registration Certificate must be obtained before the Import Licence can be applied for.
Pre-Registration Prerequisitesโ
Before submitting a Registration Certificate application:
1. Appoint a Marketing Authorization Holder (MAH)โ
The MAH must be a Sri Lanka-based entity. The MAH submits the application, holds all approvals, and bears full post-market regulatory responsibility.
2. Register the Manufacturing Facility with NMRAโ
Foreign manufacturing sites must be registered with and approved by the NMRA before any product application can be submitted. This is a standalone process involving:
- Submission of a Site Master File (SMF)
- NMRA review and possible on-site audit
- Audit waiver available for SRA-inspected sites or WHO PQ-certified sites
See Foreign Facility Registration for details.
3. Obtain Sample Import Licence (if local testing required)โ
For device categories requiring local testing (blood-contacting devices, latex products, feeding bottles, etc.), a Sample Import Licence must be obtained to bring in test samples before registration is complete.
Submitting the Registration Applicationโ
The MAH submits a Consolidated Dossier to the NMRA Medical Devices Regulatory Division using the F-MDR-035 checklist (revised format effective 2 June 2026).
Two registration routes are available:
| Route | Basis | Best For | Class III? |
|---|---|---|---|
| Full Registration | Complete NMRA review | Devices without reference country approval | MDEC review required |
| Reliance Pathway | Reference country approval (from Oct 2025) | Class I/IIa/IIb with FDA/CE/TGA/etc. approval | Still requires MDEC review |
MDEC Review โ For High-Risk Devicesโ
Applications for Class IIb and Class III devices are referred to the Medical Devices Evaluation Committee (MDEC) for expert technical review. MDEC provides a recommendation to the NMRA, which makes the final regulatory decision.
MDEC review adds time to the process โ plan for at least 6 months for Class IIb/III devices, and longer for novel or complex technologies.
Registration Certificateโ
Upon approval, the NMRA issues a Registration Certificate to the MAH. The initial certificate is typically valid for 1โ2 years (provisional), after which renewal is needed.
Import Licence Applicationโ
Once the Registration Certificate is issued, the MAH submits a separate Import Licence application to the NMRA, which authorises commercial importation for market supply.
Timeline Summaryโ
| Route | Class | Approximate Timeline |
|---|---|---|
| Reliance | I / IIa | 2โ4 months |
| Reliance | IIb | 3โ5 months (MDEC) |
| Full | I / IIa | 4โ6 months |
| Full | IIb | 5โ8 months (MDEC) |
| Full | III | 6โ12+ months (MDEC) |