Regulatory GuideAugust 25, 2026 · 18 min read · VEMERIX

How to Place a Medical Device on the Saudi Market in 2026: MDMA versus Authorized Representative versus Establishment License, SFDA Classes A–D, 2025 Fees, and the May 2026 Bundling Rules

An operational decision guide for international distributors, private-label/OEM buyers, and overseas manufacturers: navigating the Kingdom of Saudi Arabia's MDMA requirements under Law M/54, the Technical File Assessment route, SFDA Classes A–D (MDS-G008), the May 2025 fee schedule, the 3 May 2026 bundling criteria (MDS-G028), Authorized Representative mandates, importer establishment licensing, and port-clearance verification.

SFDA MDMASaudi Market AccessAuthorized RepresentativeDistributor Due Diligence
VEMERIX regulatory guide cover showing the Saudi Arabia medical device market placement workflow: SFDA MDMA under Law M/54, MDS-G008 risk classification (Classes A–D), May 2025 fee schedule, MDS-G028 bundling rules (3 May 2026), Authorized Representative mandate via GHAD, and MDS-REQ 5 shipment clearance.

What Is in Force on the Saudi Market Today: MDMA, CE Reliance, or Both?

For international medical device manufacturers and Middle Eastern distributors structuring supply agreements for the Kingdom of Saudi Arabia (KSA), few regulatory topics generate as much commercial confusion as the relationship between European CE marking, US FDA clearance, and Saudi Food and Drug Authority (SFDA) marketing authorization. Overseas sales teams frequently present CE certificates or 510(k) letters to Saudi distributors under the assumption that Saudi Arabia operates an expedited 'mutual recognition' or 'regulatory reliance' gateway. That assumption does not match the in-force SFDA technical-file pathway 1.

The regulatory framework governing medical device commercialization in Saudi Arabia is codified in the Medical Devices and Supplies Law, promulgated by Royal Decree No. (M/54) dated 6/7/1442 H, and its formal Implementing Regulation enacted under Board of Directors Decree No. (3-29-1443) 10. MDS-REQ 1 requires SFDA registration and an MDMA based on technical documentation and the Essential Principles of Safety and Performance; it does not describe a GHTF reference-country reliance route or treat a CE mark or 510(k) as a substitute for MDMA 1. Consultancy pages that still cite the 2008 Medical Device Interim Regulation or GHTF reliance are describing a superseded framework, not the current filing test.

Today, placing any medical device on the Saudi market requires a full, independent Medical Devices Marketing Authorization (MDMA) issued directly by the SFDA 9. Applications must be submitted through the SFDA's unified electronic system, known as GHAD (the Unified Electronic System for Medical Devices and Supplies), under MDS-REQ 1. SFDA FAQs still refer to this as the Technical File Assessment (TFA) track 1.

Marketing Authorization (MDMA): A document issued by the SFDA permitting the circulation of a medical device in the market.SFDA MDS-G028, Annex 1 (version 1.0, 3 May 2026)

While a European CE certificate or US FDA 510(k) clearance does not grant automatic market entry, foreign approvals remain highly valuable. Under MDS-REQ 1, clinical evaluation reports, ISO 10993 biocompatibility dossiers, sterilization validation reports (ISO 11135 or ISO 11137), and risk management files (ISO 14971) prepared for European Notified Bodies or the US FDA serve as core technical documentation in the GHAD submission 1. However, the SFDA conducts its own substantive review, verifies conformity against Saudi Essential Principles, reviews Arabic labeling and IFU requirements, and issues a standalone Saudi MDMA certificate 9.

MDS-REQ 1's submission architecture is a technical-file assessment against Saudi Essential Principles, not a reliance file that lists a prior CE mark, 510(k), or country-of-origin approval as a prerequisite 1. A device that holds China NMPA registration without an EU CE mark can still be filed if the manufacturer compiles the documentation MDS-REQ 1 requires. Existing CE or 510(k) evidence still belongs in that file as supporting technical documentation after it has been verified; it does not replace the MDMA 9. For the Great Britain analogue of this country-entry decision, see placing the same device on the Great Britain market.

How Do MDMA, the Authorized Representative License, and the Importer/Distributor Establishment License Differ?

One of the most frequent structural errors made by international procurement teams is treating the Saudi regulatory process as a single commercial agreement. Commercial teams often ask: 'Does our Saudi distributor hold the registration, or do we?' In Saudi law, market access is partitioned into three distinct legal pillars that must never be conflated 6:

  • 1. Medical Devices Marketing Authorization (MDMA): The product-specific marketing license issued by the SFDA. The MDMA is granted in the name of the legal manufacturer (with the Authorized Representative listed as the local administrative liaison). The MDMA establishes that the specific device design, packaging, sterilization, and labeling meet Saudi statutory standards 1.
  • 2. Authorized Representative (AR) License: The legal representation license required for any overseas manufacturer that does not maintain a direct corporate entity within the Kingdom. The AR must be a Saudi legal entity formally appointed by the manufacturer through an authenticated mandate contract and licensed by the SFDA under Article 6 of Law M/54 6.
  • 3. Establishment License for Importers and Distributors: The commercial establishment license required under MDS-REQ 9 and Article 6 of Law M/54 for any commercial entity that physically imports, warehouses, transports, or sells medical devices within Saudi Arabia 7.

To visualize how these three instruments interact during market entry and ongoing commercial distribution, review the regulatory architecture below:

Regulatory InstrumentStatutory Governing RuleWho Holds the Instrument?Scope & PurposeOfficial SFDA Fees & Validity
Medical Devices Marketing Authorization (MDMA)Law M/54 & MDS-REQ 1 (TFA Route)Legal Manufacturer (overseas), represented by its appointed ARAuthorizes the specific device/model to be placed on the Saudi market. Proves design, safety, bench testing, sterility, and labeling compliance.15,000 to 23,000 SAR base fee based on risk class (May 2025 schedule). Certificate validity is printed on the MDMA itself (MDS-REQ 1 Annex 13); renewal may be submitted from 90 days before expiry. MDS-REQ 1 Annex 12 defers the term to SFDA circulars rather than printing a 3-year or 5-year statutory term.
Authorized Representative (AR) LicenseLaw M/54 Art. 6, MDS-REQ 9, & 2024 Licensing ProceduresSaudi-registered legal entity formally mandated by the foreign manufacturerActs as the legal proxy for the overseas manufacturer before the SFDA. Manages GHAD submissions, maintains technical files, coordinates vigilance, and handles recalls.2,600 SAR annually per foreign manufacturer contract. Renewable annually via GHAD upon submission of authenticated mandate.
Importer / Distributor Establishment LicenseLaw M/54 Art. 6, MDS-REQ 9, & Good Distribution PracticeSaudi commercial distributor, logistics provider, or trading companyAuthorizes commercial customs clearance, bonded warehousing, cold-chain/temperature storage, transport, and commercial invoicing inside KSA.Establishment licensing fees vary by activity and facility size. Mandates ISO 13485 or SFDA QMS compliance and approved warehouse inspection.
Port Customs Clearance ReleaseMDS-REQ 5 v6.0 (Importation & Clearance)Customs clearance agent acting for the licensed Saudi ImporterVerifies physical shipment against active GHAD records. Requires automated match between shipment invoice, valid MDMA, licensed AR, and licensed Importer.Port inspection and customs administrative processing. Requires Declaration of Conformity and authenticated shipping documents.
Table 1: Regulatory Architecture: MDMA vs. AR License vs. Importer/Distributor Establishment License

Can a single Saudi company serve as both the Authorized Representative and the commercial distributor? Yes, but this requires strict contractual discipline. When an exclusive distributor also acts as the AR, the distributor controls the GHAD portal access and the MDMA administrative certificate 6. If the commercial relationship sours, transferring the MDMA to a new partner requires an official AR mandate cancellation and transfer on GHAD, which can stall commercial supply if the distribution agreement did not explicitly separate AR responsibilities from sales quotas.

For this reason, many international manufacturers prefer to appoint an independent third-party regulatory entity as their licensed Saudi Authorized Representative, and then grant non-exclusive or territory-specific distribution rights to multiple commercial importers who hold their own establishment licenses under MDS-REQ 9 7. To verify the Quality Management System documentation underpinning a prospective Saudi AR or distributor, teams should consult our comprehensive guide on verifying ISO 13485 QMS certificates.

How Does SFDA Classify Devices A–D, and Why Must You Not Import an EU IIa or US Class II Label as the Saudi Class?

Device classification in Saudi Arabia is governed by guidance document MDS-G008 (Guidance on Medical Devices Classification, version 2.0 dated 13 December 2022), which formally replaced the earlier MDS-G42 guidance 3. Under MDS-G008, medical devices (excluding In Vitro Diagnostics, which follow a dedicated IVD schema) are categorized into four risk classes: Class A (Low Risk), Class B (Low-Medium Risk), Class C (Medium-High Risk), and Class D (High Risk) 3.

A critical compliance principle emphasized in SFDA FAQ 73908 is that the legal manufacturer is strictly responsible for classifying the medical device using the rules set out in MDS-G008 8. The manufacturer must evaluate all classification rules against the device's specific intended medical purpose and assign the device to the highest risk class triggered by any applicable rule 3. FAQ 73908 still hyperlinks the withdrawn MDS-G42 PDF; use MDS-G008 as the live guidance.

SFDA Risk Class (MDS-G008)Statutory Risk DefinitionCorresponding EU MDR 2017/745 ClassCorresponding US FDA 21 CFR TierTypical Surgical & Consumable Examples
Class ALow Risk (Non-invasive or basic transient contact)Class I (Non-sterile, non-measuring)Class I (General Controls, mostly 510(k) exempt)Manual examination gloves, non-sterile post-operative protective garments, non-sterile basic bandages, manual hospital beds. Illustrative only — the manufacturer assigns the Saudi class under MDS-G008.
Class A (Special Sub-categories: Sterile / Measuring / Reusable)Low-Medium Risk (Low risk with specific manufacturing/sterilization controls)Class Is (Sterile), Class Im (Measuring), Class Ir (Reusable Surgical)Class I (Sterile) or Class IISterile non-invasive wound dressings, reusable stainless steel surgical scalpel handles, reusable bone reamers, measuring droppers.
Class BLow-Medium Risk (Transient surgically invasive, short-term mucosal contact)Class IIaClass II (Special Controls, 510(k) required)Illustrative Rule 6 starting points: single-use scalpels, hypodermic needles, and other transient surgically invasive single-use instruments listed as Class B examples in MDS-G008. A named SKU is classified only after the manufacturer runs the full rule-set.
Class CMedium-High Risk (Long-term surgically invasive, central vascular/neural contact, energy delivery)Class IIbClass II (High complexity 510(k)) or Class IIIIllustrative Class C territory under later rules includes devices that administer energy in a potentially hazardous way (MDS-G008 Rule 9 examples include surgical lasers) and long-term surgically invasive devices (Rule 8). A partner-supplied laser generator is not classified here as a VEMERIX product.
Class DHigh Risk (Direct contact with heart, central circulatory system, or central nervous system; implantable biologically active devices)Class IIIClass III (Premarket Approval - PMA)Drug-eluting coronary stents, prosthetic heart valves, implantable cardiac pacemakers, spinal cord stimulators, neurological vascular clips.
Table 2: SFDA Risk Classification Architecture (MDS-G008) vs. EU MDR & US FDA

Why is it a severe regulatory mistake to copy an EU or US classification label directly into a Saudi filing? Regulatory consultancies frequently make the error of describing Saudi devices using European roman numerals (such as 'SFDA Class IIa' or 'Class IIb') or US three-tier numbering ('SFDA Class II') 3. These labels do not exist in Saudi law. When an applicant selects the wrong classification nomenclature or misinterprets the underlying rule, the GHAD system rejects the submission, resulting in forfeited review fees and substantial project delays.

Consider the crucial application of MDS-G008 Rule 6 (Surgically Invasive Devices Intended for Transient Use). Rule 6 governs medical devices that penetrate the body through the surface or via surgical incision for a transient duration (defined as continuous use for less than 60 minutes) 3:

  • Default Rule 6 Classification: All surgically invasive devices intended for transient use are classified as Class B by default 3. MDS-G008's own examples of that default include single-use scalpels and hypodermic needles. A sterile single-use circumcision stapler, circumcision ring, or energy-delivery fiber is not a reusable surgical instrument under the Class A exception, but the manufacturer still has to apply every remaining rule — including Rule 9 for active therapeutic energy devices and dedicated accessories — and file the highest class.
  • Rule 6 Specific Class A Exception: The only exception that permits a transient surgically invasive device to be down-classified to Class A is if the device is a reusable surgical instrument (defined as instruments used in surgery for cutting, drilling, sawing, scraping, clamping, or retracting, without being connected to an active medical device, and intended to be cleaned and sterilized between uses) 3.
  • The Single-Use Consumable Pitfall: A sterile single-use circumcision stapler, circumcision ring, or puncture needle is not a reusable surgical instrument. Footnote 7 of Rule 6 states that single-use surgical instruments remain Class B under that rule. That is a rule illustration, not a filed class for a named VEMERIX SKU; the manufacturer still documents the highest applicable rule 3.

For a comparative analysis of how circumcision devices and single-use staplers are categorized across global regulatory regimes, see our dedicated guide on US, EU, and China circumcision evidence packs.

What Does the May 2025 MDMA Fee Table Actually Charge, and Which Lead Time Is Printed?

Budgeting for Saudi market access requires strict adherence to the official Elevation Fees of Medical Device Marketing Authorization (MDMA) schedule published by the SFDA in May 2025 4. Many commercial proposals circulating in the Middle East continue to cite superseded 2019 fee structures or inaccurate flat-rate estimates.

The May 2025 elevation schedule establishes base application fees strictly stratified by the device's SFDA risk class (Classes A through D), alongside standardized fees for renewals and post-approval administrative variations 4:

May 2025 SFDA MDMA fees (Saudi riyals)
Class A (Low Risk)15,000Class B (Low-Medium)19,000Class C (Medium-High)21,000Class D (High Risk)23,000Reduced Renewal5,000Administrative Update

New-application fees by SFDA class, plus reduced renewal and administrative-update fees as printed on the May 2025 elevation sheet. Only the Class A row prints a 35 working-day lead time.

Source: SFDA, Elevation Fees of Medical Device Marketing Authorization (MDMA), May 2025

MDMA Transaction / Application TypeRisk Class ScopeOfficial Fee (SAR)Official Printed Review TimeframeOperational Notes & Clock Conditions
New MDMA Application — Class AClass A (Low Risk non-invasive / reusable)15,000 SAR35 Working DaysThe 35 working days lead time is printed on the May 2025 fee schedule in the Class A row only. The sheet does not describe clock-stop rules for questions raised in GHAD.
New MDMA Application — Class BClass B (Transient invasive / low-medium risk)19,000 SARNot printed on the May 2025 fee sheetDo not invent a B/C/D statutory clock. FAQ 73938's 60 calendar days is the applicant response window on a returned file, not SFDA's review duration.
New MDMA Application — Class CClass C (Medium-High risk / active energy / pumps)21,000 SARNot printed on fee sheetPay the Class C fee only after the manufacturer has documented Class C as the highest applicable MDS-G008 rule. Do not copy an EU IIb or US Class II label into this row.
New MDMA Application — Class DClass D (High risk implants / cardiovascular)23,000 SARNot printed on fee sheetGoverns high-risk implants and devices with direct blood-contact/cardiac interfaces. Involves in-depth clinical data evaluation and expert committee review.
MDMA Renewal (All Classes)Classes A, B, C, and D5,000 SARVariable (Standard administrative queue)MDS-REQ 1 and MDS-REQ 5 allow a renewal request from 90 days before expiry; the certificate must still be valid at circulation clearance. Do not treat 90 days as a late-filing penalty window invented by consultancies.
Minor Administrative VariationAll Classes (Label, IFU, or Advertising updates only)1,100 SARFast-track administrative queueApplicable strictly when changes do not affect intended use, device design, raw materials, sterilization modality, or clinical indications.
Major Technical Variation / ReclassificationAll Classes (Change in risk class or legal manufacturer)Full Base Fee for the Applicable Class (15,000–23,000 SAR)Full technical file review queueTransferring legal manufacturer identity or changing classification rule triggers a complete new technical evaluation and full class fee.
Table 3: Official May 2025 SFDA MDMA Fee Schedule & Administrative Charges

A crucial nuance regarding review timelines: on the official May 2025 fee elevation sheet, 35 working days is printed exclusively in the row corresponding to Class A applications 4. Classes B, C, and D do not have a statutory timeline printed on the fee schedule. A December 2024 SFDA fee sheet had printed 35 working days beside Classes A–D; the later May 2025 elevation sheet dropped those B/C/D cells. Do not treat FAQ 73908 (classification) as a review-clock source. When SFDA returns a file with observations, FAQ 73938 explains that the applicant has 60 calendar days in total across three cycles to fulfil those requirements — that is an applicant-response window, not a promise of how long SFDA will take to review a complete Class B or Class C file 14.

Additionally, regulatory managers must avoid another prevalent online myth: claiming that an SFDA MDMA certificate is valid for five years. MDS-REQ 1 does not print a 3-year or 5-year statutory term. Annex 12 points fees, review time and validity to SFDA circulars; Annex 13 says the certificate itself states the period of its validity 1. What is in the current requirement documents is the duty to renew before expiry, with a renewal request permitted from 90 days before expiry under both MDS-REQ 1 and MDS-REQ 5 5. Read the term on the certificate in GHAD; do not budget from a consultancy page.

When Can Multiple Sizes, a System, or a Procedure Pack Share One MDMA under MDS-G028 (3 May 2026)?

When an international manufacturer produces a medical device line with multiple sizes (for example, a circumcision stapler available in 10 mm through 38 mm diameters, or laser fibers with radial versus bare-tip configurations), a central commercial question arises: Must we pay 19,000 SAR for every individual SKU, or can the entire portfolio share a single MDMA application?

This question is now governed authoritatively by guidance document MDS-G028 (Guidance on Bundling Criteria for Medical Devices within a Single MDMA Application, version 1.0, dated 3 May 2026) 2. MDS-G028 formally replaced and superseded Annex 15 of MDS-REQ 1, introducing precise statutory criteria and strict numerical ceilings that every applicant must obey 2.

Under MDS-G028, multiple medical device SKUs can be bundled into a single MDMA application only if they qualify under one of four designated bundling categories: Medical Device Family, Medical Device System, Medical Device Procedure Pack (Convenience Kit), or In Vitro Diagnostic Category 2.

Bundling Category (MDS-G028)Mandatory Qualifying CriteriaStatutory Application CapsStrict Bundling ProhibitionsConsumable & Surgical Applications
Medical Device FamilyMust share: (1) Same Legal Manufacturer, (2) Same Intended Medical Use, (3) Same Risk Classification, (4) Same GMDN Code Definition (when available), (5) Common physical design, construction material and manufacturing process.Maximum 5 Technical Files AND Maximum 50 Individual Items/SKUs per MDMA.Cannot mix different risk classes in one family. Family criterion A is the same legal manufacturer; do not assume two factories can share a family MDMA unless that test is actually met.Circumcision stapler size ranges (10–38 mm); self-detaching circumcision ring size variants; single-use laser fibers sharing common core glass and cladding.
Medical Device SystemA collection of medical devices, accessories, and instrumentation intended to be used in combination to achieve a single unified therapeutic or diagnostic purpose.Maximum 5 Technical Files AND Maximum 50 Individual Items/SKUs per MDMA.System components must share the same legal manufacturer and be intended to be used in combination to complete a common intended use. Mixed risk classes take the highest class. One system per application.Do not treat a partner-supplied laser generator and a separately manufactured single-use fiber as one system MDMA: MDS-G028 requires the same legal manufacturer for a system. File each legal manufacturer's devices on their own application unless they truly share one manufacturer.
Medical Device Procedure Pack (Convenience Kit)A collection of medical devices (and possibly drugs or non-medical items) assembled and packaged together into a single commercial pack to be used during a specific surgical or clinical procedure.Pack Technical File PLUS individual Component Technical Files (capped at 5 TFs / 50 items).CRITICAL PROHIBITION: A standalone product CANNOT be bundled with a set or kit in the same MDMA. The pack must be registered as a unified commercial pack.Circumcision Anastomat Kit (packaging the circumcision device together with surgical drape, gauze, measuring tape, and protective bandage in a single sterile tray).
Procedure Pack with Drug ComponentProcedure packs incorporating a pharmaceutical substance (e.g. skin prep antiseptic, local anesthetic vial, or antibiotic swab).Requires full SFDA Medical Device review PLUS formal SFDA Drug Sector marketing authorization for the drug component.Cannot clear port if the drug component does not possess an active SFDA Drug Registration number.Surgical prep trays incorporating chlorhexidine/alcohol applicators or wound-care procedure kits with topical pharmaceuticals.
Table 4: MDS-G028 (3 May 2026) Bundling Decision Matrix & Statutory Caps

Beyond the family and system rules, MDS-G028 imposes three non-negotiable operational requirements that prevent common bundling rejections 2:

  • The Hard Ceiling of 5 Technical Files and 50 Items: No single MDMA application may contain more than five (5) distinct technical construction files or more than fifty (50) individual item codes / SKUs. If a manufacturer produces 75 size variants or accessories, the portfolio must be split into at least two separate MDMA applications with two separate application fees 2.
  • The Standalone-Plus-Kit Prohibition: MDS-G028 explicitly forbids bundling a standalone commercial SKU (sold separately) with a procedural set or kit in a single MDMA. For example, if a manufacturer sells the Circumcision Anastomat as a standalone sterile device AND also sells a pre-packaged Circumcision Anastomat Procedure Kit containing drapes and gauze, the standalone device and the procedure kit require separate MDMA applications 2.
  • Component Manufacturer Letters of Agreement: For procedure packs containing components sourced from third-party manufacturers, MDS-G028 mandates that the pack assembler include a formal Letter of Agreement from each component manufacturer agreeing to provide full technical documentation and design master files directly to the SFDA upon request 2.

For a detailed comparison of how procedure packs and convenience kits are regulated under US FDA and European MDR Article 22 frameworks, see our operational guide on sterile procedure kit regulation in the US and EU.

What Do GHAD Submission and Shipment Clearance (MDS-REQ 5) Still Check Before the First Container Is Released?

Obtaining an approved MDMA certificate is a major milestone, but it does not guarantee that a container will clear Saudi customs. Commercial importation and physical shipment release at Saudi seaports, airports, and land border crossings are governed by MDS-REQ 5 (Requirements on Importation and Shipments Clearance of Medical Devices and Supplies, version 6.0 dated 19 July 2023) 5.

Under MDS-REQ 5, Saudi Customs systems (FASAH) are integrated directly with the SFDA's GHAD electronic database. When a shipment arrives at the port of entry (such as King Abdulaziz Port in Dammam, Jeddah Islamic Port, or King Khalid International Airport in Riyadh), customs automated screening cross-checks four mandatory regulatory data points before releasing the physical cargo 5:

Clearance Verification GateAutomated System CheckRequired Documentation / EvidenceFailure Mode & Red Flag
1. Active & Valid MDMA CertificateGHAD electronic lookup against product model numbers and catalog codesCopy of the active SFDA MDMA certificate. Must match device commercial brand name, model numbers, and intended use exactly.MDMA expired or pending renewal. Renewal may be submitted from 90 days before expiry; an expired MDMA fails the circulation-import check.
2. Active Authorized Representative LicenseAutomatic verification of overseas manufacturer's AR mandate in GHADValid SFDA AR License number. Mandate contract between foreign manufacturer and Saudi AR must be active.AR license expired or annual representation fee (2,600 SAR) unpaid. Circulation clearance requires an active AR license, which MDS-REQ 5 says is automatically verified.
3. Licensed Saudi Importer EstablishmentVerification of the consignee's SFDA establishment licenseImporter's active establishment license covering the specific activity (importation and wholesale distribution) and warehouse storage conditions.Consignee holds a general commercial trading license but lacks an SFDA establishment license under MDS-REQ 9. Goods cannot be released to an unlicensed entity.
4. Manufacturer Declaration of Conformity (DoC)Physical and electronic review of shipping dossierOriginal Manufacturer Declaration of Conformity referencing the valid MDMA number and naming the licensed Saudi Authorized Representative.AR name missing from DoC. (Note: Exemption applies ONLY to low-risk non-sterile non-measuring Class A devices; sterile consumables must name the AR).
5. Shipping Invoice & Packing List AlignmentConsignment line-item reconciliationCommercial invoice, packing list, certificate of origin, and bill of lading matching the exact SKU descriptions approved in the MDMA.Invoice lists unregistered accessories or modified brand names not included in the GHAD technical file approval.
Table 5: MDS-REQ 5 Customs Shipment Clearance Verification Gates

Pay particular attention to the footnote in MDS-REQ 5 regarding the Manufacturer's Declaration of Conformity: the note stating that naming the Authorized Representative on the circulation Declaration of Conformity is 'Not applicable for low-risk medical devices that are non-sterile and not having measuring function' 5. Sales representatives frequently cite this note to argue that an AR is not needed. The note is limited to low-risk devices that are non-sterile and not measuring. Sterile surgical consumables do not meet those three conditions and should name the licensed Authorized Representative on the circulation DoC 5.

Does a CE Certificate or 510(k) Clearance Replace the Technical File, and What Does It Still Contribute?

Because MDS-REQ 1 is a technical-file assessment rather than a CE or 510(k) reliance route, what role do existing European CE certificates or US FDA 510(k) clearances actually play in a 2026 Saudi MDMA filing? They do not replace the technical file. They can shorten assembly of the GHAD dossier when the underlying reports already map to Saudi Essential Principles 1.

SFDA's Overview Medical page describes the sector's framework as aligned with IMDRF and GHWP practice, and MDS-REQ 1 requires evidence of conformity with the Essential Principles 9. A manufacturer that already maintains EU MDR technical documentation or an FDA 510(k) design-history file can usually reuse the following sections as supporting evidence — SFDA still reviews them against Saudi requirements rather than accepting a foreign certificate as automatic proof:

  • Biocompatibility Evaluation (ISO 10993 Series): ISO 10993-series biological evaluation reports prepared for European or US regulators can be placed in the technical file as evidence of Essential Principles conformity; they are not a substitute for SFDA review 1. See our guide on reviewing ISO 10993 biocompatibility files.
  • Sterilization Validation & Bioburden Controls: Ethylene oxide (ISO 11135) or radiation (ISO 11137) sterilization validation dossiers, EO residual testing (ISO 10993-7), and packaging sterile-barrier integrity testing (ISO 11607-1/2) can usually be reused in the Saudi file when they still cover the marketed configuration; they do not by themselves prove SFDA acceptance. See our EO sterilization guide and sterile-barrier packaging guide.
  • Clinical Evaluation Reports (CER): Clinical evaluation evidence belongs in the technical documentation; MDS-REQ 1 Annex 6 covers clinical evaluation and post-market clinical follow-up. MEDDEV 2.7/1 or MDCG 2020-6 structure can help assemble that evidence, but those EU documents are not a Saudi statutory section 1.
  • Risk Management File (ISO 14971): Risk analysis, hazard identification, and risk-benefit conclusions prepared for CE marking are typical inputs to the MDS-REQ 1 risk-management file; SFDA still assesses whether they cover the Saudi intended use and Essential Principles.

However, distributors must verify the authenticity and scope of any foreign certificate before submitting it to the SFDA. Submitting an expired, suspended, or scope-mismatched CE certificate or 510(k) printout is a foreseeable cause of questions, delay, or refusal. To verify foreign regulatory documents independently, distributors should consult our guide on verifying CE certificates and Notified Body designations and our step-by-step 510(k) verification methodology.

If the SFDA technical reviewer requests a Certificate of Free Sale (CFS) or Certificate to Foreign Government (CFG) from the country of origin to verify legal commercialization, teams should follow our dedicated guide on authenticating Certificates of Free Sale and export certificates.

Arabic Labeling, Saudi-DI UDI, and Post-Market Duties That Apply After MDMA

Once the MDMA certificate is granted, the manufacturer and its Authorized Representative inherit ongoing post-market compliance obligations under Law M/54 that must be maintained throughout the product lifecycle 10:

  • Dual-Language Labeling Requirements: SFDA labeling rules enforce strict language standards based on user persona. MDS-REQ 1 Essential Principles require information supplied by the manufacturer for devices for use by lay persons to be in both Arabic and English, including an Arabic trade name as pronounced in English on the label 1. The same annex does not print a blanket 'English-only is always sufficient' permission for professional-use IFUs. Confirm GHAD artwork requirements with the Authorized Representative for each SKU rather than assuming hospital-use devices need no Arabic.
  • Saudi-DI (Unique Device Identification): MDS-REQ 7 requires the manufacturer to assign UDI using an accepted issuing agency (GS1, HIBCC or ICCBBA). The UDI comprises UDI-DI and UDI-PI. The manufacturer or Authorized Representative shall submit and maintain the data in the Saudi-DI database; UDI-DI data shall be available in that database at the time the device is placed on the market 15. US GUDID or EUDAMED entries are not a substitute. For private-label UDI architecture outside KSA, see our guide on UDI for private-label medical devices.
  • Post-Market Vigilance & Mandatory Incident Reporting: SFDA FAQ 59933 sets the incident clocks from the date of awareness: not later than 2 working days for a serious public health threat; not later than 10 working days for an unanticipated death or unanticipated serious injury; and not later than 30 calendar days for events, incidents and complaints not associated with high risks 11. MDS-REQ 9 refers incident and shortage notifications to the National Center for Medical Devices Reporting (NCMDR). Do not cite Law M/54 Article 24 for these clocks — SFDA cites Articles 24 and 25 of the Law for advertising and promotion, not for vigilance 10.
  • Field Safety Corrective Actions (FSCA) & Recalls: Field safety corrective actions that affect the Kingdom must be notified to SFDA through the Authorized Representative or importer. Do not invent a 48-hour statutory clock; use the current SFDA FSCA/NCMDR procedure and the incident clocks in FAQ 59933 where they apply 11.

Worked Examples: A CE-Marked Circumcision Ring versus an NMPA-Only Laser Fiber

To demonstrate how these regulatory principles apply in practice, let us examine two real-world device configurations from the VEMERIX surgical and vascular portfolios 12:

Case Study 1: The CE-Marked Auto-Circumcision Ring

  • Device Profile: Single-use, self-detaching biodegradable circumcision ring; adult and pediatric variants across 14 size codes; supplied factory-sterile via Ethylene Oxide blister packaging 12.
  • Existing Regulatory Status: NMPA Class II (Registration: Lu Mech Reg. 20172020238) and European CE Mark certificate 12.
  • Saudi classification method: The manufacturer applies MDS-G008 to intended use and files the highest applicable rule. Rule 6's default for transient surgically invasive devices is Class B, and the Class A reusable-instrument exception does not apply to a factory-sterile single-use ring. That is a rule-path, not a filed SFDA class for this SKU 3.
  • Bundling Structure (MDS-G028): The 14 size codes can be proposed as a Medical Device Family only if they share legal manufacturer, intended use, risk class, GMDN definition when available, and common design/materials/process, and stay within five technical files and 50 items. Confirm GMDN and design-commonality on the actual IFU and technical file before paying one Class-B-or-higher fee for the whole range 2.
  • Fee if Class B is the highest applicable class: 19,000 SAR on the May 2025 new-application schedule — budget only after the manufacturer has documented the class 4.
  • Filing Strategy: The existing CE technical documentation and ISO 11135 EO validation files form the core of the GHAD submission. The CE mark accelerates the review, but the manufacturer and its licensed AR still obtain a standalone Saudi MDMA before shipping to Saudi hospitals 1.

Case Study 2: The Disposable Medical Laser Fiber

  • Device Profile: Single-use medical optical laser fiber (1470 nm endovenous laser ablation) pairing with a partner-supplied diode laser source. The console is not a Medison-manufactured or Medison-registered capital system 13.
  • Existing Regulatory Status: NMPA Class II (Registration: Lu Mech Reg. 20192010517); no European CE mark claimed by the consumable manufacturer 13.
  • Saudi classification method: The manufacturer applies every applicable MDS-G008 rule. Rule 6 is relevant because the fiber is surgically invasive and single-use. Rule 9 is also relevant because active therapeutic devices that administer energy — and dedicated accessories that influence them — can elevate to Class C when energy is administered in a potentially hazardous way; MDS-G008's Class C examples include surgical lasers. Do not file the fiber as Class B by slogan, and do not bundle it into one system MDMA with a partner-supplied generator that has a different legal manufacturer 3.
  • Is It Eligible for Saudi MDMA Without CE? Yes, as a filing pathway. MDS-REQ 1 does not list a prior CE mark or 510(k) as a submission prerequisite. The manufacturer still compiles a full technical file — NMPA bench data, ISO 10993 evaluation, optical performance, and ISO 11135 sterility — against the Essential Principles 1. To verify the underlying China NMPA certificate, see our guide on verifying China NMPA registration certificates.
  • Fee: Pay the May 2025 new-application fee for the class the manufacturer actually files, not a class copied from China NMPA 'Class II' 4.
  • Clearance Gate: Requires an active MDMA, licensed AR mandate, and licensed Saudi distributor holding an establishment license with controlled storage facilities 5.

Distributor Checklist, Agreement Terms, and Red Flags Before the First KSA Shipment

Before executing a distribution agreement or issuing purchase orders for the Saudi market, procurement teams and international manufacturers should execute the operational checklist below:

Verification DimensionRequired Objective EvidenceVerification Method & DatabaseCritical Red Flag to Reject
1. Product MDMA StatusOfficial SFDA MDMA Certificate issued in GHADObtain the current MDMA from GHAD via the licensed Authorized Representative; do not treat a screenshot or expired PDF as proof of an active certificate.Distributor claims 'CE mark covers Saudi' or provides an expired 2018 Interim Regulation filing.
2. Authorized Representative LicenseActive SFDA AR License matching the overseas legal manufacturerCross-check SFDA AR registry and confirm 2,600 SAR annual renewal is active.AR mandate held by a commercial trading firm with no medical QMS or dedicated regulatory affairs officer.
3. Importer Establishment LicenseActive SFDA establishment license for the importing commercial entityVerify the establishment license on GHAD; confirm licensed warehouse address and storage scope.Consignee attempts to clear goods using a general food/cosmetics license or subcontracted unlicensed warehouse.
4. MDS-G028 Bundling AuditConfirmation that all shipped SKUs are listed on the MDMA scheduleReconcile shipping invoice part numbers against the approved MDMA annex (max 50 SKUs).Shipped consignment contains new size variants or accessories added after MDMA approval without SFDA notification.
5. Labeling & IFU ComplianceBilingual (Arabic/English) packaging artwork for lay-use or English IFU for professional surgical devicesInspect physical blister artwork and outer carton labeling against approved GHAD artwork.Patient-contact or consumer products labeled in English only with no Arabic instructions.
6. MDS-REQ 5 Port Clearance ReadinessManufacturer Declaration of Conformity naming the licensed AR and valid MDMA numberReconcile bill of lading, commercial invoice, packing list, and DoC before container departure.DoC omits the AR name for a sterile surgical consumable that does not meet the low-risk non-sterile non-measuring note, risking detention at clearance.
Table 6: Pre-Contract & Import Due Diligence Checklist for the Saudi Market

Where VEMERIX Fits in Saudi Market Registration—and Where Due Diligence Still Begins

VEMERIX operates as the international brand of Weihai Medison Medical Equipment Co., Ltd., positioned as a Minimally Invasive Surgery Total Solution Platform serving urology, vascular surgery, and perioperative care 12.

When partnering with Middle Eastern distributors, private-label buyers, and regional hospital procurement consortia targeting the Saudi market, VEMERIX structures regulatory cooperation on complete transparency:

  • Technical File Assembly for GHAD: VEMERIX provides comprehensive technical construction files—including ISO 10993 biocompatibility testing, ISO 11135 EO sterilization validation data, design drawings, and clinical evaluation summaries—to support the distributor's appointed Saudi Authorized Representative during GHAD MDMA filing.
  • MDS-G028 Bundling Architecture: We map product families (such as the 14-size Circumcision Device range) against MDS-G028's five-technical-file and 50-item ceiling so a distributor can see what will and will not share one MDMA before paying a class fee.
  • Certified Quality Management System: All manufacturing facilities operate under certified ISO 13485 Quality Management Systems with complete traceability, supporting the Quality Management System documentation required for Saudi AR and importer filings.
  • Contractual Clarity on Regulatory Ownership: We support distributors in establishing clean, separate Authorized Representative mandates and distribution agreements, ensuring that regulatory ownership, vigilance reporting, and market access rights remain unambiguous throughout the partnership.

To explore technical specifications, request sample evaluation kits, or initiate regulatory data pack reviews for Saudi Arabia market access, explore our surgical and vascular portfolios on our Circumcision Device product page, review our Disposable Medical Laser Fiber platform, inspect our quality systems at VEMERIX Quality & Compliance, or contact our international regulatory team directly through VEMERIX Partner Inquiries.

Frequently Asked Questions

Do I need an SFDA MDMA if my device already has an EU CE mark or FDA 510(k)?
Yes. Under Law M/54 and MDS-REQ 1, every medical device placed on the Saudi market must hold an independent Medical Devices Marketing Authorization (MDMA) issued by the SFDA. European CE certificates and US FDA 510(k) clearances serve as vital supporting technical documentation in the GHAD submission, but they do not bypass the requirement for a Saudi MDMA 1.

Is a Saudi Authorized Representative (AR) the same as a commercial importer or distributor?
No. An Authorized Representative is a legal entity mandated by the foreign manufacturer to manage regulatory affairs, GHAD submissions, and vigilance before the SFDA (2,600 SAR annual contract fee). A commercial importer is a licensed entity authorized to physically import, warehouse, and sell devices under MDS-REQ 9. A single Saudi company can hold both licenses, but they represent two distinct legal responsibilities 6.

Can I bundle 50 circumcision stapler sizes into a single MDMA application?
Yes, provided they meet MDS-G028 family criteria: the same legal manufacturer, intended use, risk class, GMDN definition when available, and common physical design, construction material and manufacturing process, within the five-technical-file and 50-item caps. However, 50 is the absolute statutory cap; a 51st size would require a second MDMA application and an additional application fee 2.

How much are SFDA MDMA application fees in 2026?
Under the official May 2025 fee schedule, new MDMA application fees are: Class A (15,000 SAR), Class B (19,000 SAR), Class C (21,000 SAR), and Class D (23,000 SAR). Standard renewals cost 5,000 SAR, and minor administrative variations (label/IFU updates only) cost 1,100 SAR 4.

Does an SFDA MDMA allow me to sell devices in the UAE or other GCC countries?
No. An SFDA MDMA is a national marketing authorization valid strictly within the Kingdom of Saudi Arabia under Royal Decree M/54. Placing devices in the United Arab Emirates (UAE MoHAP), Qatar (MOPH), Kuwait, Bahrain, or Oman requires separate national registration filings in each target country 10.

Is the SFDA MDMA review always completed within 35 working days?
No. The May 2025 elevation sheet prints 35 working days only in the Class A row 4. Classes B–D have no lead time printed on that sheet. FAQ 73938's 60 calendar days is the applicant's total window to answer SFDA observations on a returned file, not a guaranteed SFDA review duration 14.

Does a sterile single-use circumcision stapler qualify for the Class A abbreviated file?
No. MDS-REQ 1's abbreviated low-risk file already excludes sterile devices. Separately, Rule 6's Class A exception is limited to reusable surgical instruments; a factory-sterilized single-use stapler is not that exception. The manufacturer still files the highest applicable MDS-G008 rule rather than copying an EU IIa or US Class II label 1.

Does VEMERIX already hold an SFDA MDMA for its surgical products?
No. This article does not claim that VEMERIX or Weihai Medison currently holds an SFDA MDMA for these SKUs. VEMERIX maintains ISO 13485 manufacturing and technical files — including China NMPA registrations and a European CE certificate where one is in force for that SKU, such as the Auto-Circumcision Ring — and can support a licensed Saudi Authorized Representative assembling a GHAD file. Due diligence still begins with the distributor's GHAD roles and a current MDMA check 12.

Sources

  1. Saudi Food and Drug Authority (SFDA), Requirements for Medical Devices Marketing Authorization (MDS-REQ 1), English PDF MDS-REQ-001-V6/211219. A medical device may be made available in the Kingdom only if it is registered with SFDA and an MDMA is obtained. Technical documentation must demonstrate conformity with the Essential Principles; ISO 13485 QMS is required; applications are submitted via GHAD by a local manufacturer, an overseas manufacturer, or the overseas manufacturer's Authorized Representative. Low-risk abbreviated technical documentation excludes IVDs, sterile devices, measuring devices, reusable surgical instruments, and novel devices. The MDMA shall be renewed before expiry, and a renewal request may be submitted 90 days before expiry. Annex 12 defers fees, review time, and validity to SFDA circulars rather than printing a fixed certificate term. Annex 13 states that the MDMA certificate includes the period of its validity. Official landing last updated 18 July 2024: https://www.sfda.gov.sa/en/regulations/68759. Independently retrieved 25 August 2026.
  2. SFDA, Guidance on Bundling Criteria for Medical Devices within a Single MDMA Application (MDS-G028), version 1.0, version date 3 May 2026. Family, system, procedure-pack and IVD criteria; maximum five technical files and 50 items; family also requires the same legal manufacturer, intended use, risk class, GMDN definition when available, and common physical design, construction material and manufacturing process; standalone products may not be bundled with a set or kit; a medical-device system requires the same legal manufacturer; procedure packs require pack and component technical files plus a component-manufacturer letter of agreement; a pack that includes a drug needs SFDA Drug Sector marketing authorisation. Annex 2 states the document is new and replaces Annex 15 of MDS-REQ 1. Annex 1 defines Marketing Authorization (MDMA) as a document issued by the SFDA permitting the circulation of a medical device in the market.
  3. SFDA, Guidance on Medical Devices Classification (MDS-G008), version 2.0, version date 13 December 2022. Non-IVD devices are Class A, B, C or D. The manufacturer classifies using intended use and the highest applicable rule. Rule 6: surgically invasive devices intended for transient use (normally less than 60 minutes) are Class B by default unless a listed exception applies; reusable surgical instruments are Class A under that rule; footnote 7 states single-use surgical instruments remain Class B. Rule 9 classifies active therapeutic devices that administer energy as Class B unless they may administer energy in a potentially hazardous way, in which case they are Class C; examples of that Class C elevation include surgical lasers. Formally supersedes MDS-G42.
  4. SFDA, Elevation Fees of Medical Device Marketing Authorization (MDMA), May 2025 English fee sheet. New applications: Class A 15,000 SAR with 35 working days printed in that row; Class B 19,000 SAR; Class C 21,000 SAR; Class D 23,000 SAR. Reduced renewals 5,000 SAR. Administrative updates of labels, IFUs or advertising only 1,100 SAR. Change of risk class or legal manufacturer name/address is the full class fee. The sheet does not print lead times for Classes B–D. A December 2024 SFDA elevation-fee sheet had printed 35 working days for Classes A–D; the May 2025 sheet no longer prints those B/C/D cells.
  5. SFDA, Requirements on Importation and Shipments Clearance of Medical Devices and Supplies (MDS-REQ 5), version 6.0, version date 19 July 2023 (translated copy). Circulation imports require a valid MDMA, which may be renewed 90 days before expiry, plus importer license and AR license (AR license automatically verified for circulation). Clearance applications are submitted via the FASAH (Tabadul) platform. The circulation Declaration of Conformity notes that the Authorized Representative name field is not applicable for low-risk medical devices that are non-sterile and not having measuring function.
  6. SFDA, Guidance on the Procedures for Licensing of Medical Devices and Supplies Establishments (August 2024). Issued under Article 6 of the Medical Devices and Supplies Law (Royal Decree M/54 dated 06/07/1442 H): an establishment shall not engage in activities subject to the Law unless registered and a license is obtained. GHAD account opening. Authorized Representative license fee 2,600 SAR per year, with a contract period of one to 10 years according to the customer's choice and the period of the contract.
  7. SFDA, Requirements for Licensing of Medical Devices Establishments (MDS-REQ 9), English version 2, March 2025. Manufacturer, Authorized Representative, importer and distributor obligations, including ISO 13485 or equivalent QMS, UDI compliance, and the importer duty to hold a valid MDMA, manufacturer Declaration of Conformity, and machine-readable UDI with each device. Independently retrieved 25 August 2026; a March 2023 English PDF remains on the site but this is the later English edition.
  8. SFDA FAQ, How medical devices classification must be performed? (FAQ 73908), last updated 18 July 2024. The manufacturer determines classification using SFDA rules, considers all applicable rules, classifies on the highest risk class, and must justify the class/rule for the device and accessories. The page still hyperlinks MDS-G42 (2020-03), which returned 404 on 25 August 2026; live classification guidance is MDS-G008 (s3).
  9. SFDA Overview Medical, page dated 6 November 2024. The Medical Devices Sector reviews the technical file, clinical trials, post-market surveillance plan, quality and other technical documents prior to granting marketing authorisation, and monitors approved devices through risk-based post-market surveillance including field safety notices and adverse events. Framework described as aligned with IMDRF and GHWP.
  10. Medical Devices and Supplies Law issued by Royal Decree No. (M/54) dated 6/7/1442 H, and Implementing Regulation issued by SFDA Board of Directors decree No. (3-29-1443) dated 19/2/1443 H, as cited inside MDS-REQ 1, MDS-G008, MDS-G028, MDS-REQ 5 and the 2024 licensing-procedures guide. Article 6 (no activity without registration and license) is quoted in the licensing-procedures guide. MDS-REQ 8 cites Articles 24 and 25 of the Law for advertising and promotion, not for incident reporting. Load-bearing article numbers in this guide are only those quoted in the cited SFDA PDFs.
  11. SFDA FAQ, What is the timeframe for reporting adverse event, incident, and complaint? (FAQ 59933), last updated 18 July 2024. Manufacturers, Authorized Representatives, importers and distributors shall report upon becoming aware: not later than 2 working days for a serious public health threat; not later than 10 working days for an unanticipated death or unanticipated serious injury; not later than 30 calendar days for events, incidents and complaints not associated with high risks.
  12. VEMERIX Circumcision Device product page. Records the self-detaching circumcision ring as NMPA Class II (Lu Mech Reg. 20172020238), CE-marked, 14 size codes, EO-sterilized. Used as the CE-present worked example. Does not claim an SFDA MDMA or an SFDA class.
  13. VEMERIX Disposable Medical Laser Fiber product page. Records Medison's NMPA Class II single-use medical laser fiber (Lu Mech Reg. 20192010517) for 1470 nm endovenous workflows, pairing with a partner-supplied diode laser source, with no CE claim on the consumable. Used as the CE-absent worked example. Does not claim an SFDA MDMA or an SFDA class, and does not treat the partner-supplied console as a Medison-manufactured capital system.
  14. SFDA FAQ, What does mean, “The timeframe for returned MDMA application is 60 calendar days” in announcement (8) 8/2019? (FAQ 73938). The 60 calendar days is the total applicant response window across all three cycles to fulfil SFDA observations on a returned MDMA file, not the Authority's review clock. Extensions beyond 60 calendar days require a justified request to mdma.it@sfda.gov.sa.
  15. SFDA, Requirements for Unique Device Identification (UDI) for Medical Devices (MDS-REQ 7), version 4.0, 24 May 2022. The manufacturer shall assign and manage UDI using an accepted issuing agency (GS1, HIBCC or ICCBBA). The UDI contains UDI-DI and UDI-PI. The manufacturer or Authorized Representative shall submit and maintain the appropriate data in the Saudi-DI database; UDI-DI data shall be available in that database at the time the device is placed on the market.

Talk to VEMERIX

VEMERIX is the international brand of Weihai Medison Medical Equipment Co., Ltd., positioned as a Minimally Invasive Surgery Total Solution Platform serving urology, vascular surgery and perioperative care.