CSDT & Technical Documentation
TH-Unique ยท Common Submission Dossier Template ยท ASEAN AMDD aligned
What Is the CSDT?โ
The Common Submission Dossier Template (CSDT) is the ASEAN-standard dossier format adopted by Thailand for all Class 2, 3, and 4 medical device registration applications. It provides a consistent structure aligned across ASEAN member states, meaning a dossier prepared for Thailand is largely reusable for Malaysia, Philippines, Indonesia, and other ASEAN markets.
CSDT Full Format โ For Class 2, 3, and 4โ
The CSDT Full format is required for all Notification (Class 2โ3) and License (Class 4) applications. Class 1 Listing uses a simplified form.
Dossier Structureโ
| Section | Content |
|---|---|
| Administrative section | Applicant details, product identification, application type, Establishment License reference |
| Device overview and description | Intended purpose, operating principle, materials, configurations/models covered |
| Classification justification | Class assignment with reference to applicable MoPH classification rules |
| Essential principles checklist | Mapping of each essential principle to compliance evidence |
| Design verification and validation | Bench test reports, laboratory testing evidence |
| Risk management | ISO 14971 summary โ hazard identification, controls, residual risk |
| Clinical / performance evaluation | CER (general devices) or performance evaluation report (IVDs) |
| Labelling | Proposed Thai labelling and IFU โ compliant with MoPH Notification 137 |
| QMS evidence | ISO 13485 certificate โ valid, scope-appropriate, accredited CB |
| Manufacturing information | Manufacturing site details, GMP evidence |
| Post-market surveillance plan | PMS commitments for Class 3โ4 |
QMS Requirements โ ISO 13485โ
ISO 13485 certification is required for all Class 2, 3, and 4 registrations:
- Certificate from an internationally accredited certification body
- Scope must cover the specific device category
- Current at time of submission
- Covers the manufacturing site
Thai FDA recognises certificates from internationally accredited CBs โ no separate Thai FDA QMS approval process.
Essential Principles of Safety and Performanceโ
All devices must comply with the ASEAN AMDD Essential Principles as required by Thai FDA. Key areas:
| Principle Area | Key Standards |
|---|---|
| General safety | ISO 14971 risk management; benefit-risk analysis |
| Biocompatibility | ISO 10993 series |
| Sterility | ISO 11135, 11137, 17665 as applicable |
| Active devices โ electrical safety | IEC 60601-1 and sub-parts |
| Software | IEC 62304 (lifecycle), IEC 62366 (usability) |
| Performance | Device-specific standards |
| Electromagnetic compatibility | IEC 60601-1-2 |
Risk Management โ ISO 14971โ
Every CSDT must include a risk management summary:
- Hazards identified for the specific device and intended use
- Risk estimation (probability ร severity)
- Risk control measures implemented
- Residual risk evaluation
- Benefit-risk analysis โ benefits must outweigh residual risks
Clinical Evidenceโ
| Class | Clinical Evidence Expectation |
|---|---|
| 2 | Literature-based review; performance data; clinical evaluation report |
| 3 | Detailed CER; clinical investigation data may be required for novel technologies |
| 4 | Comprehensive clinical data; usually includes clinical investigation results |
| IVDs | Performance evaluation: sensitivity, specificity, precision, accuracy, stability, reference interval |
Overseas clinical data is accepted where the patient population and intended use are equivalent to Thai context.
In-Country Testing โ TH-Uniqueโ
For certain device categories, Thai FDA may require local testing to be conducted in Thailand:
- High-risk IVDs โ potential requirement for local testing
- Medical gloves โ local testing may be required
- Determination is made case-by-case by Thai FDA
Confirm whether local testing is required for your specific device type before finalising your dossier preparation timeline.