PMDA Consultations for Medical Devices | Choosing the Right Type

Choose a PMDA consultation according to the question: general consultation for regulatory systems and consultation options, simple consultation for limited procedural matters, and the appropriate face-to-face advice category for study plans or results.

The key is not simply to describe the product, but to organize "what you want to confirm," "how your company currently views the issue," and "what evidence supports that view" before the consultation.

Why Use a PMDA Consultation?

PMDA consultations provide advice on issues arising during product development, approval application preparation or post-approval changes, within the scope of the selected consultation category.

Examples of topics that may be discussed include:

  • Development plans
  • Required nonclinical testing
  • Test methods and evaluation endpoints
  • Whether a clinical trial is necessary and how it should be planned
  • Use of overseas clinical data
  • Acceptability of a Clinical Evaluation Report (CER)
  • Structure of the approval application dossier

A consultation is not the approval review itself and does not guarantee approval.

It is important to reflect the advice received in subsequent test plans and application materials.

Main Consultation Options Used for Medical Devices

General Consultation

A free consultation for general regulatory systems and notices unrelated to an individual product, and for identifying which consultation category to use.

It is not a consultation in which PMDA reviews individual product test results or determines whether approval will be granted.

Face-to-Face Advice

For specific issues related to product development or approval applications, materials are submitted in advance and advice is obtained from PMDA.

Paid consultation categories are available depending on the subject matter. Simple consultation is one of these categories.

Simple Consultation

Simple consultation is a category of face-to-face advice. The medical device and IVD category covers limited matters, such as the applicable change procedure where this can be determined from appearance, shape, intended use or specifications.

It does not evaluate approval application data. Interpretation of GCP, GLP or GPSP requirements is handled under a separate simple consultation category.

Consultation categories, scope, application procedures, and fees may be revised.

Before applying, check PMDA's latest list of consultation categories and implementation guidelines.

Matching the Question to the Consultation Category

Protocol consultations address study plans; evaluation consultations address completed study results. Examples include:

  • Nonclinical study plans: medical device protocol consultation
  • Completed nonclinical study results: medical device evaluation consultation
  • Exploratory clinical trial plans: exploratory clinical trial protocol consultation
  • Confirmatory clinical trial plans: clinical trial protocol consultation

Information to Organize in the Consultation Materials

Product Overview

Organize the intended use, target patients, structure and principle of operation, method of use, and approval and marketing status in Japan and overseas.

Regulatory Positioning

Organize the generic name, JMDN code, classification, anticipated regulatory pathway, and comparison with approved devices.

Development and Evaluation Status

List completed tests, planned tests, clinical evaluation, and the status of application dossier preparation.

Consultation Questions

For each point to be confirmed with PMDA, align your company's position with the supporting evidence.

When clinical evidence is part of the consultation, define what the available literature and data can support and where uncertainty remains; see the scope of CER preparation support.

Present Your Company's Position and Supporting Rationale

Rather than asking only, "Which tests should we conduct?", it is more effective to present your own position, for example:

  • We consider Test A necessary
  • The reason is the product structure and the differences from approved devices
  • We consider that Test B can be substituted with existing data

This makes the issues you want to confirm clearer.

From Defining the Consultation Objective to Acting on PMDA Advice

  1. 01

    Identify the Issues to Discuss

    Identify the matters in product development or application preparation for which you want PMDA's view.

  2. 02

    Confirm the Consultation Category

    Check PMDA's latest guidance to determine the consultation category that corresponds to the issue.

  3. 03

    Apply and Submit the Materials

    Confirm the prescribed application procedure and submission deadline, then submit the consultation materials.

  4. 04

    Conduct the Consultation

    Explain the consultation questions and your company's position, and identify PMDA's advice and any additional points to be confirmed.

  5. 05

    Reflect the Advice in Development and Application Planning

    Reflect the consultation outcome in test plans, clinical evaluation, application materials, and the development schedule.

    When incorporating the advice into your plan, estimate preparation, testing, and QMS work separately from official fees using the approval timeline and cost guide.

Points Often Overlooked When Preparing for a Consultation

  • The matters to be confirmed are not clearly defined
  • The company's own position is not presented
  • Supporting materials for the proposed position are insufficient
  • The intended use is not aligned with the test endpoints
  • Similarities and differences from approved devices are not organized
  • Too many unrelated issues are included in a single consultation
  • The validity of a test plan is discussed only after the major tests have been completed

MK Consulting's PMDA Consultation Support

For help planning a consultation or preparing the materials, see Regulatory Strategy & PMDA Consultation Support.

Frequently Asked Questions

Is a PMDA consultation always required before an approval application?

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No. It is not mandatory for every product. A consultation may be considered when there is uncertainty about product novelty, required testing, clinical evaluation, or the use of overseas data.

When is the best time to consult PMDA?

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Consulting before the strategy for major tests and application materials is finalized makes it easier to reflect PMDA's advice in the subsequent plan.

Can overseas clinical data be discussed?

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Yes. Overseas clinical data can be included in the consultation. The relationship to the intended use and target patient population planned for Japan should be organized in advance.

Does receiving face-to-face advice mean the device will be approved?

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No. Face-to-face advice does not guarantee approval. During the approval review, the submitted application materials are reviewed separately.

You Can Contact Us Even If You Are Not Yet Sure Whether a PMDA Consultation Is Necessary

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