Regulatory GuideAugust 29, 2026 · 20 min read · VEMERIX

How to Place a Medical Device on the Australian Market in 2026: ARTG Inclusion versus Australian Sponsor versus Manufacturer Evidence, TGA Classification, Comparable Overseas Regulator Evidence, and Why 1 July 2026 UDI Starts Only After You Know the TGA Class

An operational decision guide for international distributors, private-label/OEM buyers, and overseas manufacturers: navigating Australian Register of Therapeutic Goods (ARTG) inclusion under the Therapeutic Goods Act 1989, the Australian sponsor mandate, Manufacturer Evidence pre-approval, TGA risk classification (Classes I, IIa, IIb, III), Comparable Overseas Regulator (COR) pathways, July 2026 fee schedules, and the class-phased 1 July 2026 Unique Device Identification (AusUDID) rollout.

Australia Market AccessARTGTGA SponsorDistributor Due Diligence
VEMERIX regulatory guide cover illustrating the 2026 Australian medical device market placement workflow: TGA ARTG inclusion under the Therapeutic Goods Act 1989, Australian Sponsor requirements, Manufacturer Evidence pre-approval, TGA classification (Classes I–III), Comparable Overseas Regulator (COR) pathways, and class-phased AusUDID requirements.

Does a CE Mark, FDA 510(k), or China NMPA Certificate Replace ARTG Inclusion?

For medical device manufacturers and international distributors evaluating the Australian healthcare market, one pervasive myth causes severe commercial and legal friction: the assumption that holding a valid European CE mark, a US FDA 510(k) clearance, or a China NMPA registration certificate permits immediate commercial export and supply to Australian hospitals and clinics. Overseas sales managers frequently tell Australian distributors that their device is "globally approved" and ready to clear Australian Border Force (ABF) customs. Under Australian statutory law, that assumption is entirely false 1.

The commercial supply of medical devices in Australia is strictly governed by Commonwealth statutory law under the Therapeutic Goods Act 1989 and the Therapeutic Goods (Medical Devices) Regulations 2002 4. Under Chapter 4 of the Act, all therapeutic goods—unless covered by a narrow statutory exemption such as the Special Access Scheme (SAS), Authorised Prescriber Scheme, or Clinical Trial Notification (CTN)—must be included in the Australian Register of Therapeutic Goods (ARTG) before they can be imported, exported, advertised, or supplied for commercial or clinical use in Australia 2.

Unless a specific exemption applies, medical devices must be included on the ARTG before they can be supplied in Australia. Each ARTG entry is unique to the sponsor, manufacturer and the kind of device.Therapeutic Goods Administration (TGA), Importing and Supplying Medical Devices (13 January 2026)

A European CE certificate (under EU MDR 2017/745 or an applicable predecessor directive), a US FDA 510(k) letter, or an NMPA registration certificate is never an automatic market passport to Australia 2. Instead, foreign approvals operate strictly as supporting conformity assessment evidence within the TGA's comparable-overseas-regulator framework 13. They allow an Australian sponsor to attach the documents TGA Table 2 requires to pass preliminary assessment—provided the evidence matches the class and the named overseas body 6. The final legal instrument authorising commercial distribution is always the ARTG Certificate of Inclusion issued directly to the Australian sponsor 1. For the corresponding Great Britain framework, compare how Great Britain placement differs when a CE mark is already in hand. An SFDA MDMA likewise does not place the same device in Australia; see why an SFDA MDMA does not place the same device in Australia. Verify a 510(k) number used as supporting evidence in how to verify a 510(k) number used as supporting evidence in an ARTG file.

Supplying a medical device in Australia without a valid ARTG inclusion is a serious statutory offence. The TGA importing-and-supplying page describes penalties of up to five years imprisonment and/or 5,000 penalty units, and states that one Commonwealth penalty unit is currently valued at AUD 330 under the Crimes Act 1914 (5,000 × AUD 330 = AUD 1,650,000) 2. Those figures are the page's printed maximums, not an incidence estimate and not a prediction of any particular prosecution.

Who Must Be the Australian Sponsor, and Can the Overseas Manufacturer File Directly?

A second common point of failure for overseas manufacturers is attempting to open an account on TGA Business Services (TBS) and submit an ARTG inclusion application directly from an offshore office in Shanghai, Shenzhen, Tuttlingen, or Minneapolis. Under Australian law, an overseas manufacturer cannot act as the legal applicant or hold an ARTG inclusion in its own foreign corporate name 1.

Under Section 3 of the Therapeutic Goods Act 1989, the applicant must be an Australian Sponsor, defined strictly as 4:

  • A person who is a resident of Australia; or
  • A body corporate incorporated in Australia and conducting business in Australia, who imports therapeutic goods into Australia, arranges for the importation of therapeutic goods into Australia, manufactures therapeutic goods in Australia, or arranges for another person to manufacture therapeutic goods in Australia for supply.

The Australian Sponsor is not merely a nominal postbox or customs clearance agent; they are the primary legal entity held accountable by the Commonwealth Government for the ongoing safety, quality, and regulatory compliance of the device 3. The statutory responsibilities of the Australian Sponsor include:

  • Submitting Manufacturer Evidence and ARTG Applications: Holding the active TBS account, verifying technical dossiers, obtaining Manufacturer Evidence pre-clearance, and submitting the inclusion application 1.
  • Ensuring Essential Principles Conformity: Legally certifying that the device conforms to the Essential Principles of Safety and Performance set out in Schedule 1 of the 2002 Regulations 6.
  • Maintaining Technical Documentation: Keeping complete technical files, clinical evaluations, and Declarations of Conformity accessible for TGA audit. The 20-working-day clock on the processing page is TGA’s decision-notification standard after the inclusion fee is paid, not a separate sponsor-document deadline 9.
  • Post-Market Vigilance and Recall Coordination: Investigating adverse events and submitting mandatory initial reports within the printed windows: 48 hours for a serious public-health threat; 10 days for death or serious deterioration in health; 30 days for an event that might lead to death or serious deterioration 17.
  • Australian Labelling and Annual Charges: Ensuring Australian labelling includes the sponsor’s corporate name and Australian street/suburb address, and paying mandatory annual ARTG maintenance charges every financial year 14.

Overseas manufacturers typically structure their Australian presence through one of two models: (1) appointing an independent, third-party Australian regulatory sponsor-for-hire while contracting with multiple commercial distributors; or (2) appointing an exclusive commercial distributor in Australia to act as the legal sponsor. While the distributor-as-sponsor model avoids third-party representation fees, the distributor owns and controls the ARTG inclusion. If the commercial relationship terminates, transferring the ARTG entry to a new distributor requires formal written consent from the existing sponsor, creating severe commercial lock-in if not governed by robust distributor agreements.

Why Another Company’s ARTG Entry for a Similar Device Does Not Cover Your Shipment

A critical legal principle that distinguishes Australian device regulation from many other jurisdictions is the strict legal uniqueness of every ARTG inclusion. Overseas manufacturers frequently ask: "Our competitor already registered this circumcision stapler in Australia—can we use their ARTG number to clear our shipment?" Alternatively, a newly appointed Australian distributor might ask: "Our manufacturer already has an ARTG number held by their previous Australian partner—can we import under that existing number?" 2

The TGA’s official guidance on importing and supplying medical devices directly addresses and refutes this practice 2:

Every sponsor must apply to have their imported devices included on the ARTG. This is even the case when another sponsor already has an ARTG entry for the same device.Therapeutic Goods Administration (TGA), Importing and Supplying Medical Devices (13 January 2026)

An ARTG inclusion is not a general market authorisation for a physical device in the abstract; it is a specific statutory licence granted to a named Australian Sponsor to supply a specific "kind of medical device" produced by a named legal manufacturer 8. If Sponsor A holds an ARTG inclusion for a single-use circumcision stapler from a named Chinese manufacturer, that inclusion grants legal authority only to Sponsor A. If Sponsor B imports the exact same stapler from the exact same factory, Sponsor B is committing a statutory offence under Chapter 4 of the Act unless Sponsor B holds its own separate, valid ARTG inclusion 2.

Furthermore, the TGA explicitly notes that health professionals, hospitals, or clinics that import medical devices directly from overseas for use in their own clinical practice become the legal sponsor under Australian law 2. The Personal Importation Scheme applies exclusively to individual patients importing therapeutic goods for personal use; it does not extend to clinicians or facilities importing devices for outpatient surgery or patient treatment 2.

What Manufacturer Evidence Is, Why It Must Be Accepted Before Inclusion, and What It Costs

In the TGA regulatory workflow, the most common procedural error made by novice sponsors is attempting to fill out the ARTG medical device inclusion application form before submitting Manufacturer Evidence. On the TBS portal, the inclusion form contains a mandatory dropdown field requiring a validated Manufacturer Evidence Identifier. If Manufacturer Evidence has not been formally submitted and approved by the TGA, the inclusion form cannot proceed 5.

Manufacturer Evidence is the formal regulatory mechanism by which the TGA reviews and accepts the overseas legal manufacturer's Quality Management System (QMS) and conformity assessment documentation before any product-specific inclusion is considered 5. Acceptable forms of Manufacturer Evidence depend on the device's risk class and include 5:

  • TGA Conformity Assessment Certificate: Issued directly by the TGA following assessment of the manufacturer. This remains an acceptable Manufacturer Evidence document. It is not described here as still mandatory for every animal-tissue, medicinal-substance, or recombinant-DNA device after the 2021 repeal of Regulation 4.1 5.
  • Comparable Overseas Regulator (COR) Evidence: Valid QMS and product certificates issued by a recognised foreign body, such as an EU MDR Annex IX/XI Chapter I certificate from an EU Notified Body, an MDSAP audit certificate and report, a US FDA 510(k)/PMA confirmation, a Health Canada MDL, a Japan PMDA certificate, or a Singapore HSA approval 12.
  • Schedule 3, Clause 7.5 Declaration: A specialized Australian Declaration of Conformity for medical device systems or procedure packs 5.
Regulatory Instrument / RoleGoverning Statutory RuleLegal Holder / ApplicantCore Regulatory FunctionTGA Fees & Processing Standard
ARTG Certificate of InclusionTherapeutic Goods Act 1989, s 41FD & s 41FEAustralian Sponsor (corporate or resident)Legal authorization permitting commercial supply, import, and distribution in Australia. Tied uniquely to sponsor, manufacturer, and kind of device.Application fee AUD 651 (Class I) / AUD 1,244 (Class IIa and IIb) / AUD 1,603 (Class III); annual charge AUD 121 / 879 / 1,305 / 1,662 by class. Target decision notification within 20 working days after fee payment if not selected for audit.
Australian Sponsor MandateTherapeutic Goods Act 1989, s 3 & s 41FNAustralian legal entity (Pty Ltd or resident)Acts as primary legal liaison with TGA. Submits files, manages TBS, holds technical documentation, coordinates vigilance/recalls, and ensures Australian labeling compliance.Sponsor service fees contracted privately (or managed by local subsidiary/distributor). Responsible for paying statutory annual charges.
Manufacturer Evidence IdentifierTherapeutic Goods Regulations 2002, r 4.3 & r 4.4Overseas Legal Manufacturer (submitted via Sponsor on TBS)Establishes pre-cleared proof of valid QMS (ISO 13485 / MDSAP) and overseas market authorization from a Comparable Overseas Regulator.No government application fee. TGA target processing timeline: 15 working days. Must be accepted before inclusion filing.
Australian Declaration of Conformity (DoC)Schedule 3, Regulations 2002 & TGA TemplateLegal Manufacturer (signed by authorized executive)Formal legal declaration certifying finished device conforms to Australian Essential Principles and conformity assessment procedures. EU MDD DoC strictly rejected.Internal manufacturer technical file deliverable. Must be attached to ARTG inclusion submission to pass preliminary assessment.
Overseas Supporting Technical FileISO 13485, ISO 14971, ISO 10993, ISO 11135Legal Manufacturer (OEM / Contract Manufacturer)Underlying technical dossier (design history, bench testing, biocompatibility, sterilization validation, risk file, clinical evaluation) backing the Australian DoC.Must be maintained by manufacturer and accessible by Australian sponsor within 20 working days upon TGA audit request.
Table 1: Australian Medical Device Market Access Architecture: ARTG vs. Sponsor vs. Manufacturer Evidence vs. DoC

Two operational facts regarding Manufacturer Evidence matter for planning: first, the TGA charges no fee for submitting a Manufacturer Evidence application; second, the TGA operates a published target processing timeframe of 15 working days 5. Those clocks are service-standard prints, not guaranteed calendars. If Manufacturer Evidence that already applies to a new inclusion is on the sponsor's TBS account, TGA says you will not need to submit that evidence again 5. To verify the Quality Management System documentation used for this step, see how to verify the ISO 13485 or MDSAP certificate used as TGA Manufacturer Evidence.

Crucially, an EU Medical Devices Directive (MDD 93/42/EEC) Declaration of Conformity is not an acceptable Australian Declaration of Conformity 6. The TGA requires an Australian Declaration of Conformity drafted specifically to the Australian conformity assessment procedures under Schedule 3 of the 2002 Regulations, executed using official TGA templates 6. For details on foreign certificate authenticity checks, review how to verify a CE certificate before you attach it to a TGA Manufacturer Evidence file.

How TGA Classifies Devices, Why EU Class IIa or China NMPA Class II Is Not the TGA Class, and Why Wrong-Class Fees Are Non-Refundable

A dangerous assumption made by international regulatory teams is copying a device's European CE classification (e.g., "Class IIa under Rule 6") or Chinese NMPA classification (e.g., "Class II under NMPA Order 739") directly into the Australian TBS inclusion form. While Australian classification rules share historical roots with the Global Harmonization Task Force (GHTF) and European principles, Australian device classification is governed strictly and independently by Schedule 2 of the Therapeutic Goods (Medical Devices) Regulations 2002 7.

The TGA explicitly places legal responsibility for classification on the legal manufacturer, not the sponsor 7:

Manufacturers are responsible for classifying their medical devices. You must enter the correct class when you apply to include a device in the ARTG. We cannot refund application fees for applications entered with the wrong class.Therapeutic Goods Administration (TGA), Classification of Medical Devices

Under Schedule 2, medical devices (excluding IVDs) are classified into non-IVD risk tiers including Class I, Class I (sterile or measuring), Class IIa, Class IIb, and Class III / AIMD 7. If more than one classification rule applies based on the manufacturer’s stated intended purpose, the highest applicable risk class applies 7. This article does not assign a TGA class to any named VEMERIX SKU.

TGA Risk Class (Regulations 2002)Statutory Risk DefinitionGoverning Classification Criteria (Schedule 2)Corresponding EU MDR / US FDA TierTypical Consumable & Surgical Examples
Class I (non-sterile, non-measuring)Low riskNon-invasive devices and other Schedule 2 Part 2 mappings that remain Class I when not supplied sterile and not measuring.EU MDR Class I (basic) / US FDA Class I (often 510(k)-exempt)Non-sterile examination gloves; some non-sterile drapes used only as a mechanical barrier.
Class I (sterile — Is / measuring — Im)Low–medium riskClass I devices supplied sterile or incorporating a measuring function (still Class I, but Manufacturer Evidence and annual charges differ from basic Class I).EU MDR Class Is/Im / US FDA Class I or 510(k)Sterile procedure drapes; some calibrated measuring containers.
Class IIaLow–medium risk (invasive / transient)Schedule 2 clause 3.2(2): surgically invasive devices for transient use are Class IIa, unless a higher rule applies. Short-term invasive devices and some wound-microenvironment dressings also map here under other clauses.EU MDR Class IIa / US FDA Class II (510(k)) analogue — not interchangeableGeneric transient surgically invasive instruments. A circumcision ring or stapler is not assigned a TGA class in this article.
Class IIbMedium–high risk (active / long-term / energy)Long-term surgically invasive and implantable devices under clause 3.4(2) are Class IIb unless a higher rule applies. Active devices that administer or exchange energy can also land in Class IIb depending on intended purpose.EU MDR Class IIb analogue — not interchangeableGeneric long-term implants and some active therapeutic devices. An endovenous laser fiber is not assigned a TGA class in this article.
Class III / AIMDHigh risk (critical contact / implantable)Devices contacting the central circulatory or central nervous system, absorbable implants, and devices incorporating animal tissues or medicinal substances, as mapped by the applicable Schedule 2 clauses.EU MDR Class III / US FDA Class III (PMA) analogue — not interchangeableVascular stent systems, bioabsorbable implants, AIMDs. Not used as a VEMERIX SKU class.
Table 2: TGA medical device classification architecture (Schedule 2) versus EU MDR and US FDA — orientation only. The manufacturer classifies under Australian rules; the examples are generic device types from TGA classification guidance, not a TGA class for any named VEMERIX SKU.

The commercial danger of misclassification is practical: TGA application fees for the wrong class are not refunded 79. If a sponsor files a sterile surgically invasive consumable as Class I sterile (AUD 651 application fee under the July 2026 schedule) when the manufacturer’s Australian classification is Class IIa (AUD 1,244), TGA cannot change the class on that application. The sponsor forfeits the fee and must submit a new application 9. That is why EU IIa or NMPA Class II must not be copied into the TBS class field.

What "Kind of Medical Device" Means for Grouping, GMDN Codes, and Unique Product Identifiers

In Australia, medical devices are not included in the ARTG as individual catalog stock keeping units (SKUs) or part numbers. Instead, under Section 41BE of the Therapeutic Goods Act 1989 and Regulation 1.6 of the 2002 Regulations, devices are included by "kind of medical device" 8.

An individual ARTG inclusion covers all device variants, models, and sizes that share four mandatory statutory attributes 8:

  1. Same Australian Sponsor: The inclusion is held by the same legal sponsor entity 8.
  2. Same Legal Manufacturer: Produced by the exact same corporate manufacturer named on the conformity assessment certificate 8.
  3. Same TGA Risk Classification: Categorized under the exact same risk classification tier (e.g., all items are Class IIa) 8.
  4. Same Global Medical Device Nomenclature (GMDN) Preferred Term: Governed by the same 5-digit GMDN code and definition (the GMDN preferred term the manufacturer assigns — do not invent a code) 8.

This grouping architecture can create real commercial efficiencies for multi-size lines. If several diameters of the same stapler share the same sponsor, the same legal manufacturer, the same TGA class, and the same GMDN preferred term, they can be grouped under one ARTG inclusion with one application fee and one annual charge 8. That is a kind-of-device test, not a promise that any named VEMERIX size range is already grouped or classified.

There is a further characteristic for Class III medical devices, Active Implantable Medical Devices (AIMD), and Class 4 IVDs (other than a stated immunohaematology-reagent exception): the Unique Product Identifier (UPI) 8. Those kinds are not one GMDN code covering unlimited models. TGA still allows listed variants of the same UPI under one entry; a different UPI or intended purpose requires a separate inclusion.

Which Overseas Certificates TGA Treats as Comparable Overseas Regulator Evidence—and Why NMPA Is Not a Recognized COR

To streamline market access while maintaining rigorous clinical safety standards, the TGA operates the Comparable Overseas Regulator (COR) pathway under the Therapeutic Goods (Overseas Regulators) Determination 2018 (latest compilation F2025C01149, 1 December 2025) 12. Under this framework, the TGA accepts conformity assessment decisions, QMS certificates, and marketing clearances issued by designated international regulatory authorities as valid Manufacturer Evidence to support abridged ARTG inclusion applications 13.

Under Determination 2018 and TGA guidance, recognized Comparable Overseas Regulators include 12:

  • IAF-accredited ISO 13485 conformity assessment bodies (Determination 2018 s 5(a)) 12.
  • European notified bodies designated by an EU member state and notified to the Commission (s 5(b)) 12.
  • MDSAP recognised or authorised auditing organisations (s 5(c)) 12.
  • Health Canada (s 5(d)) 12.
  • Singapore Health Sciences Authority (HSA) (s 5(e)) 12.
  • Japan MHLW and PMDA (s 5(f)–(g)) 12.
  • United States Food and Drug Administration (s 5(h)) 12.
  • UK approved bodies under the UK Medical Devices Regulations 2002 as in force in England, Wales and Scotland (s 5(i)) 12.
Overseas Regulator / AuthorityDetermination 2018 StatusAcceptable Evidence TypesTGA Table 2 Required AttachmentsApplicability to Chinese Sterile Consumables
European Union Notified Bodies (EU MDR)Recognised Comparable RegulatorEU MDR Annex IX Chapter I (QMS) & Chapter II (Technical Assessment) Certificates.Valid CE Certificate, Notified Body audit reports, Summary Technical Documentation, Australian DoC.Primary pathway for CE-marked Chinese consumables when the live certificate matches TGA Table 2 (confirm MDR versus a predecessor directive before attaching).
US FDA (CDRH)Recognised Comparable Regulator510(k) clearance letter, PMA approval order, De Novo classification, Establishment Registration.FDA clearance letter, Device Listing screenshot, 510(k) Summary, ISO 13485 / MDSAP certificate, Australian DoC.Viable pathway if manufacturer holds US 510(k) clearance and third-party ISO 13485 / MDSAP QMS certification.
Medical Device Single Audit Program (MDSAP)Named in Determination 2018 s 5(c) as an MDSAP auditing organisationMDSAP audit certificate and report covering the TGA jurisdiction.Full MDSAP audit report, stage 2 close-out evidence, Australian DoC, design dossier summary.Provides QMS Manufacturer Evidence for facilities audited under MDSAP; still requires product-specific clinical/technical evidence.
Health Canada / Japan PMDA / Singapore HSARecognised Comparable RegulatorMedical Device Licence (Canada), Shonin/Ninsho (Japan), Device Registration (Singapore HSA).Official registration certificate, evaluation summary report, ISO 13485 certificate, Australian DoC.Alternative abridged pathway if the device already achieved regulatory registration in Canada, Japan, or Singapore.
China NMPA (National Medical Products Admin)Not named in Determination 2018 s 5China NMPA Medical Device Registration Certificate (Class II / Class III) & Production License.Cannot be submitted as comparable-overseas-regulator evidence under Determination 2018 s 5.NMPA-only devices cannot bypass TGA evaluation. Must establish alternative COR evidence (e.g. MDSAP + CE/510k) or undergo direct TGA conformity assessment.
Table 3: TGA Comparable Overseas Regulator (COR) Pathways Under Determination 2018

The load-bearing takeaway for a China-made sterile consumable is that China’s NMPA is not named as an overseas regulator in Determination 2018 s 5 12. An NMPA Class II certificate cannot be attached as comparable-overseas-regulator evidence to abridge ARTG inclusion. The manufacturer must use a body that s 5 actually names (for example an EU notified body, FDA, MDSAP auditing organisation, or IAF-accredited ISO 13485 body, as applicable to class and Table 2) or apply for TGA conformity assessment 5. To verify NMPA documents used as country-of-origin background, see how to verify the China NMPA certificate used as country-of-origin evidence.

What the Live TGA Application, Audit, and Annual-Charge Cards Print from July 2026

Financial budgeting and timeline forecasting for Australian market entry must be based on the official TGA Summary of Fees and Charges (in force from 1 July 2026) and the Cost Recovery Implementation Statement (CRIS), rather than generic consultancy ballparks 14.

The Australian cost architecture consists of four distinct fee categories 14:

  1. Manufacturer Evidence submission: no fee. Processing standard: 15 working days 5.
  2. ARTG inclusion application fee: paid on TBS when the inclusion application is submitted. Class I (sterile, measuring, or other) AUD 651; Class IIa and Class IIb AUD 1,244; Class III AUD 1,603 14.
  3. Application audit assessment fee: levied if the application is selected for audit. Level 1 (verification of the application, evidence of conformity, and aspects of Essential Principles compliance) is AUD 4,926; Level 2 (Level 1 activities plus in-depth technical documentation review for Class III) is AUD 18,118 14.
  4. Annual maintenance charge: billed for an active ARTG inclusion. Class I other AUD 121; Class I sterile or measuring AUD 879; Class IIa and Class IIb AUD 1,305; Class III / AIMD AUD 1,662 14.
Official TGA medical device inclusion fees and annual charges (from 1 July 2026, AUD)
Application fee (AUD)Annual charge (AUD)
Class I (other)651121Class I (sterile / measur…651879Class IIa1,2441,305Class IIb1,2441,305Class III1,6031,662

Application fees (Table 41) and annual charges from the TGA Fees and charges summary, 1 July 2026, Version 1.0. Manufacturer Evidence is no-fee. Application audit assessment fees are separate: Level 1 AUD 4,926; Level 2 (Class III) AUD 18,118. Annual Charge Exemption may defer an annual charge until first turnover; it is not a published AUD 0 Class I rate.

Source: Therapeutic Goods Administration, Fees and charges: Summary From 01 July 2026, Version 1.0

On processing, TGA’s published service standard is that sponsors are notified of the inclusion decision within 20 working days after the day the application fee was paid, for applications that are not then selected for audit 9. If the application is selected for audit, TGA says it will ask for further information and supporting documentation and, if applicable, invoice an assessment fee 9. Preliminary-assessment refusal and withdrawal do not refund fees. Those clocks are service-standard prints, not a guaranteed calendar, and this article does not invent a 60-to-90-day audit duration.

Does the 1 July 2026 UDI Headline Apply to a Typical Sterile Consumable, or Only After You Know the TGA Class?

Throughout 2025 and early 2026, medical device news outlets and regulatory blogs heavily publicized the headline: "Australia Mandates Unique Device Identification (UDI) from 1 July 2026." This blanket reporting caused widespread alarm among international manufacturers of single-use surgical consumables, many of whom feared that their Australian shipments would be halted at customs on 1 July 2026 if packages lacked Australian UDI barcodes registered in the Australian UDI Database (AusUDID) 10.

The TGA’s official statutory enactments—specifically the Therapeutic Goods Legislation Amendment (Australian Unique Device Identification Database and Other Measures) Regulations 2025 (FRL F2025L00414)—establish a strictly class-phased implementation rollout 11:

From 1 July 2026, some medical devices supplied in Australia must meet Unique Device Identification (UDI) requirements. The introduction begins with higher-risk devices (Class IIb and Class III), followed by lower-risk devices (Class IIa, Class Is and in vitro diagnostic devices) over later years.Therapeutic Goods Administration, New UDI Requirements for Medical Devices Commence 1 July 2026
TGA Risk Classification TierMandatory AusUDID Compliance DateLabelling & Packaging UDI Carrier MandateAusUDID Data Submission RequirementImmediate Action Required for 2026 Shipments
Class IIb and Class III1 July 2026 (first cohort)UDI requirements commence for some devices supplied in Australia, beginning with these higher-risk classes.Follow the official UDI requirements and timeframes guidance, including AusUDID at ausudid.tga.gov.au.Do not ship a device in this cohort against the 1 July 2026 headline until the manufacturer has classified it under Australian rules and confirmed the applicable UDI duties.
Class IIa, Class Is, and IVDsLater years (date not printed in the news article)Introduction follows over later years. This article does not copy a consultancy calendar that names a later-year date.Voluntary early compliance may be possible; mandatory dates sit on the official timeframes table, not on a consultancy recap.A copied EU IIa or NMPA Class II label is the wrong input to this calendar.
Class I (basic, non-sterile) and other classes not named in the news articleNot specified in the 1 July 2026 news articleDo not infer a start date from silence.Monitor the official UDI timeframes guidance.Classification still comes first.
Table 4: Australian Unique Device Identification rollout as printed on the TGA news article of the 1 July 2026 commencement. Later-class dates are not copied from consultancy calendars; use the official UDI timeframes guidance for the live table.

The operational takeaway is: you cannot tell whether a SKU faces the 1 July 2026 UDI start until the manufacturer has classified it under Australian rules 10. If that class is IIa, the news article places it in the later-years cohort, not the 1 July 2026 start. If that class is IIb or III, it is in the first cohort. This article does not classify a VEMERIX circumcision ring or laser fiber, and it does not treat a public ARTG string hit as class proof. For US and EU UDI assignment on private-label programmes, compare how US and EU UDI rules differ from Australia's class-phased AusUDID start.

What the Public ARTG Search Can and Cannot Prove: Lessons from 61,995 Device Entries

When conducting distributor due diligence or competitor intelligence in Australia, procurement teams frequently query the publicly accessible Australian Register of Therapeutic Goods (ARTG) search directory (compliance.health.gov.au/artg/) 15. While the public search is an invaluable transparency tool, relying on search results without understanding the registry's structural limitations leads to severe errors 15.

An exhaustive analysis of the official complete public ARTG extract (snapshot dated 6 July 2026) reveals the following baseline directory facts 15:

  • Overall Registry Volume: 97,472 total therapeutic good entries across medicines, biologicals, and medical devices. 61,995 rows are categorized as Medical Devices (representing 61,994 unique ARTG IDs) across 10,457 legal manufacturers and 3,344 Australian sponsors 15.
  • No Public Classification Column: The public ARTG extract lists the ARTG ID, Product Name, Sponsor Name, Manufacturer Name, and Category (Included, Included - IVD, Included Export-Only). It does not print the TGA risk classification (Class I, IIa, IIb, III). A search result alone cannot verify a product's approved risk classification 15.
  • Circumcision device string matches: Product-name matching identifies 8 circumcision-labelled device rows across 4 unique names, including five “Circumcision stapler/staple” rows held by Australian sponsors for Chinese manufacturers (public catalogue facts as of the 6 July 2026 snapshot). That shows the category is includable. It is not a ranking, not proof VEMERIX is included, and not authorisation for another importer 15.
  • Laser Fiber Search Limitations: Text matching for endovenous laser fibers yields only 5 entries, none of which are 1470 nm radial vascular fibers (the entries comprise mechanical cleaving tools and a holmium/thulium laser system). This does not mean 1470 nm fibers are unapproved; rather, under TGA grouping rules, they are registered under broader GMDN parent terms such as "Laser, diode, surgical" or "Surgical laser fiber, single-use" 15. For more on multi-register identity mapping, see why a public ARTG title is not proof of which object is included.
  • Corporate-entity disambiguation: On Medical Device rows, a “Medison” manufacturer hit is ARTG 301721, an ultrasound system manufactured by Samsung Medison Co Ltd and sponsored by Quantum Health Group. Samsung Medison is a different legal person from Weihai Medison Medical Equipment Co., Ltd. Additional “Medison Pharma Australia” rows in the full snapshot are medicines, not devices. Searches for “Weihai” identify four Weihai Hongyu PPE/IVD rows. VEMERIX string hits: zero 15.

The fundamental due diligence rule for Australian buyers is: a public ARTG search screenshot is not an inclusion certificate, does not prove device classification, and does not authorise you to import. Buyers must demand the official ARTG Certificate of Inclusion and the public summary for that sponsor, manufacturer and kind of device 15. If an Australia-bound file also asks for an export certificate, verify it separately in how to verify a Certificate of Free Sale used in an Australia-bound file.

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

To illustrate how the Australian regulatory framework operates in real-world commercial scenarios, consider two contrasting device files from the VEMERIX surgical and vascular energy portfolios 16:

Regulatory DimensionCase 1: Auto-Circumcision Ring (CE-Marked)Case 2: 1470 nm Laser Fiber (NMPA-Only)Operational Difference & Compliance Action
Device Identity & ModelVEMERIX Circumcision Device (self-detaching ring; 14 size codes; EO sterile), as described on the public product page.VEMERIX Disposable Medical Laser Fiber for 1470 nm endovenous workflows, as described on the public product page. Connector geometry is not restated here.Surgical consumable vs. active energy delivery consumable.
Country-of-Origin ApprovalChina NMPA Class II (Lu Mech Reg. 20172020238).China NMPA Class II (Lu Mech Reg. 20192010517).Both hold valid Chinese NMPA Class II marketing registrations.
International CE StatusCE yes on the public product page. Confirm whether the live certificate is MDR or a predecessor directive before attaching it; an EU MDD DoC is not the Australian DoC.No Medison CE claim on the public product page.Case 1 may support Manufacturer Evidence via a European notified-body document if Table 2 allows it. Case 2 cannot treat NMPA as Determination 2018 s 5 evidence.
TGA Risk ClassificationNot assigned in this article. Manufacturer classifies under Schedule 2. NMPA Class II and any EU class analogue are not the TGA class.Not assigned in this article. An active energy-delivery intended purpose can land in a higher Australian class than a transient surgical consumable — that is a classification exercise, not a published VEMERIX TGA class.Do not copy NMPA Class II or EU IIa/IIb into the TBS class field. Wrong-class fees are not refunded.
Manufacturer Evidence RouteMay be submitted via TBS using a European notified-body QMS/market-authorisation document if it matches TGA Table 2. No Manufacturer Evidence fee.Cannot use NMPA as comparable-overseas-regulator evidence. Needs a s 5-named body (for example MDSAP or an IAF-accredited ISO 13485 certificate, as applicable) or TGA conformity assessment.Case 1 can use the 15-working-day Manufacturer Evidence target if the file is complete. Case 2 is a QMS/COR bridging problem, not an NMPA shortcut.
ARTG Inclusion PathwayAbridged inclusion on TBS after the Manufacturer Evidence identifier is accepted, with an Australian DoC.Inclusion still required if the device will be supplied. Audit selection can add a Level 1 (AUD 4,926) or, for Class III, Level 2 (AUD 18,118) assessment fee.If classified IIa or IIb, the inclusion application fee prints AUD 1,244 on the July 2026 schedule. That is not a class assignment.
AusUDID Compliance MandateUDI date follows TGA class. If the manufacturer classifies the device as Class IIa, the news article places it in the later-years cohort, not 1 July 2026.UDI date follows TGA class. If the manufacturer classifies the device as Class IIb, it is in the 1 July 2026 first cohort.Do not print a UDI deadline on either SKU until Australian classification is done.
Table 5: Worked Australian filing contrast — CE-marked circumcision ring versus NMPA-only laser fiber. TGA class and UDI dates are not assigned to either SKU.

Table 5 is a filing-path contrast, not a classification certificate. A CE mark on the circumcision ring can support Manufacturer Evidence if the live certificate matches TGA Table 2; it still does not replace ARTG inclusion for the Australian sponsor 12. For the laser fiber, the NMPA certificate is country-of-origin evidence, not Determination 2018 s 5 evidence, and this article does not place that SKU in Class IIb or on the 1 July 2026 UDI start 10.

Distributor Checklist, Contract Terms, and Red Flags Before the First Australian Shipment

Before executing a commercial distribution agreement or issuing a purchase order for Australia-bound medical devices, distributors, procurement managers, and legal counsel must verify the following seven-point due diligence checklist 1:

  1. 1. Verify Australian Sponsor Identity and TBS Account: Confirm the sponsor is an active Australian Pty Ltd or resident with an active TGA Business Services (TBS) client account 3.
  2. 2. Inspect Manufacturer Evidence Pre-Approval: Verify that the TGA has issued a formal Manufacturer Evidence Acceptance Identifier for the legal manufacturer's specific production facility 5.
  3. 3. Audit the Australian Declaration of Conformity: Ensure the manufacturer has executed an Australian Declaration of Conformity under Schedule 3 of the 2002 Regulations. Reject any submission offering an EU MDD Declaration 6.
  4. 4. Confirm Independent TGA Risk Classification: Re-evaluate device classification under Schedule 2 of the Australian Regulations. Never accept an EU or NMPA class label as proof of Australian class 7.
  5. 5. Obtain the Official ARTG Certificate of Inclusion: Demand the official PDF Certificate of Inclusion issued to your specific sponsor. Verify that the sponsor name, manufacturer name, and GMDN term exactly match your shipment 8.
  6. 6. Audit Australian Labelling Compliance: Confirm that primary unit labels and outer packaging display the Australian Sponsor's corporate name and Australian address, alongside batch/expiry markings and sterile symbols 2.
  7. 7. Verify AusUDID Status Against Risk Class: For Class IIb and Class III devices, verify that UDI carriers are printed on labels and registered in the AusUDID database before shipment 10.

Australian distribution contracts must include explicit regulatory covenants: (a) a clause guaranteeing sponsor cooperation in transferring the ARTG inclusion if distribution terminates; (b) a mandatory 24-hour notification covenant for adverse events and customer complaints; (c) a requirement for the manufacturer to provide updated technical dossiers within 10 working days upon TGA audit notice; and (d) clear allocation of statutory annual ARTG maintenance charges.

Where VEMERIX Fits in Australian Supply—and Where Due Diligence Begins

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. For international distributors and Australian healthcare procurement teams evaluating our surgical consumables and energy platforms, we provide complete, transparent regulatory documentation 16.

Where VEMERIX fits in your Australian market-entry strategy:

  • Urology surgical consumables: The CE-marked Circumcision Device (self-detaching ring) can be discussed as a technical pack for an Australian sponsor’s Manufacturer Evidence and inclusion file. CE status is as stated on the product page; it is not an ARTG inclusion 16.
  • Vascular laser consumables: Medison’s NMPA-registered single-use Disposable Medical Laser Fiber can be discussed as an NMPA-only file that still needs an Australian sponsor and ARTG inclusion if it will be supplied. It is not treated here as a Medison CE claim, and the partner-supplied laser source is out of scope 16.
  • Next evidence step: Request the current technical pack, proposed Australian classification (manufacturer-owned), Manufacturer Evidence status, and Australian DoC draft via the quality portal or the contact desk.

Where due diligence begins: VEMERIX does not claim pre-existing Australian ARTG inclusions for these SKUs, does not sell an ARTG number, and does not appoint itself as the reader’s Australian sponsor. An Australian distributor or sponsor-for-hire still has to run the TGA checks in this article. To request a current technical pack or an Australian distribution discussion, use the quality portal or the contact desk.

Frequently Asked Questions

Do I still need ARTG inclusion if my device already has a CE mark, FDA 510(k), or NMPA certificate?
Yes. Under Chapter 4 of the Therapeutic Goods Act 1989, all medical devices supplied in Australia must be included in the ARTG unless covered by a specific statutory exemption. Foreign approvals (CE, 510(k), etc.) serve only as supporting evidence within the Comparable Overseas Regulator framework; they never substitute for an ARTG inclusion 2.

Can the overseas manufacturer be the Australian sponsor?
No. Under Section 3 of the Act, the sponsor must be a resident of Australia or an Australian-incorporated body corporate conducting business in Australia. An overseas legal manufacturer must appoint an Australian sponsor to hold the ARTG inclusion and interface with the TGA 4.

Does another importer's ARTG number cover my shipment of the same device model?
No. Every ARTG entry is legally unique to the specific combination of sponsor, manufacturer, and kind of device. Every importer or distributor must hold their own ARTG inclusion. Importing against another sponsor's ARTG number is a statutory offense carrying severe civil and criminal penalties 2.

What is Manufacturer Evidence and do I pay a government fee for it?
Manufacturer Evidence is the QMS and conformity-assessment documentation submitted via TBS. The TGA charges no fee for Manufacturer Evidence applications, and processing targets 15 working days. Approval is required before the ARTG inclusion form can be initiated 5.

Is the TGA inclusion decision always made within 20 working days?
TGA’s published standard is to notify applicants within 20 working days after the day the application fee was paid, for applications that are not selected for audit. If an application is selected for audit, TGA asks for further information and may invoice an assessment fee. Refusal at preliminary assessment and withdrawal do not refund fees 9.

Does the 1 July 2026 UDI requirement apply immediately to Class IIa sterile consumables?
Not on the TGA news article’s print. From 1 July 2026 some devices must meet UDI requirements, beginning with Class IIb and Class III; Class IIa, Class Is and IVDs follow over later years. Verify the device’s Australian class before treating 1 July 2026 as a labelling deadline, and use the official timeframes guidance for later-class dates rather than a consultancy calendar 10.

Is a China NMPA certificate recognised as comparable-overseas-regulator evidence by the TGA?
No. NMPA is not named in Determination 2018 s 5. An NMPA certificate cannot be used as primary comparable-overseas-regulator evidence; the manufacturer must provide evidence from a s 5-named body or undergo TGA conformity assessment 12.

Does VEMERIX already hold an ARTG inclusion for its surgical and vascular SKUs?
No. VEMERIX can supply current technical documentation to support an Australian sponsor’s own inclusion. It does not sell pre-existing ARTG numbers, and a public ARTG hit on Samsung Medison or Weihai Hongyu is not a Weihai Medison listing 16.

Sources

  1. Therapeutic Goods Administration (TGA), Medical device inclusion process. States that a person intending to supply a medical device in Australia must meet the definition of a Sponsor under the Therapeutic Goods Act 1989 and must be a recognised Australian-based legal entity. Official guidance hub covering device classification, kind of medical device grouping, conformity assessment documentation, TGA Business Services (TBS), application submission, preliminary assessment, decision processing, and printing the ARTG certificate of inclusion. Extracted 29 August 2026.
  2. Therapeutic Goods Administration, Importing and supplying medical devices (page history includes 13 January 2026). Unless a specific exemption applies, medical devices must be included on the ARTG before they can be supplied in Australia. Each ARTG entry is unique to the sponsor, manufacturer, and kind of device; every sponsor must apply to include their imported devices even when another sponsor already has an ARTG entry for the same device. Health professionals who import devices for clinical practice become sponsors; personal importation does not cover clinical-practice use. The page describes penalties of up to five years imprisonment and/or 5,000 penalty units, and states that one penalty unit is currently valued at AUD 330 under the Crimes Act 1914. Extracted 29 August 2026; independently re-checked 29 August 2026.
  3. Therapeutic Goods Administration, Role of the sponsor. Directs applicants to the statutory definition in Chapter 1 Section 3 of the Therapeutic Goods Act 1989. Establishes that the Australian sponsor is legally responsible for applying for ARTG inclusion, maintaining Manufacturer Evidence, ensuring ongoing conformity with Essential Principles, meeting post-market vigilance and adverse event reporting timelines, and paying annual charges. Extracted 29 August 2026.
  4. Therapeutic Goods Act 1989 (Cth), official compilation on the Federal Register of Legislation (FRL). Section 3 defines a sponsor in relation to therapeutic goods as a person who is a resident of Australia, or a body corporate incorporated in Australia and conducting business in Australia, who imports, arranges import, manufactures in Australia, or arranges manufacture for supply in Australia. Chapter 4 governs the medical device regulatory framework, ARTG inclusion, conditions, offenses, and civil penalty provisions. Extracted 29 August 2026.
  5. Therapeutic Goods Administration, Manufacturer Evidence for medical devices. Manufacturer Evidence is an issued conformity-assessment document relating to the manufacturer’s quality management system, or a Declaration of Conformity for a system or procedure pack. Without this evidence the device cannot be included on the ARTG. There is no fee associated with a Manufacturer Evidence application. TGA aims to process these applications within a target timeframe of 15 working days. The identifier will not appear in the inclusion form until accepted; do not start the inclusion application until the acceptance notification. Acceptable documents depend on class and include a TGA Conformity Assessment Certificate, overseas market-authorisation or QMS evidence from a comparable overseas national regulatory authority, and a Schedule 3 clause 7.5 DoC for a system or procedure pack. Extracted 29 August 2026; independently re-checked 29 August 2026.
  6. Therapeutic Goods Administration, Providing documentation for including medical devices in the ARTG. Explicitly states that a Declaration of Conformity to the European Medical Devices Directive (MDD 93/42/EEC) is not acceptable. The DoC must be drafted to Australian requirements under the Therapeutic Goods (Medical Devices) Regulations 2002 using official TGA templates. References Table 2 of the Comparable Overseas Regulator guidance for mandatory attachments required to pass preliminary assessment. Extracted 29 August 2026.
  7. Therapeutic Goods Administration, Classification of medical devices, and Classifying medical devices that are not in-vitro diagnostics (IVDs). Manufacturers classify. Sponsors must enter the correct class; TGA cannot refund application fees entered with the wrong class. Australian classification rules can differ from overseas rules. The non-IVD classification guidance places surgically invasive devices for transient use at Class IIa under Schedule 2 clause 3.2(2) as a general rule, not as a class assigned to a named SKU. Extracted 29 August 2026; independently re-checked 29 August 2026.
  8. Therapeutic Goods Administration, What "kind of medical device" is it. Section 41BE of the Act and Regulation 1.6 define "kind of medical device". Devices are grouped under a single ARTG inclusion if they share the same sponsor, same legal manufacturer, same risk classification, and same Global Medical Device Nomenclature (GMDN) preferred term code. Class III, AIMD, and Class 4 IVDs also require a Unique Product Identifier (UPI), preventing broad multi-model grouping. Extracted 29 August 2026.
  9. Therapeutic Goods Administration, Processing your application for inclusion of a medical device. After submission and payment of the application fee, TGA aims to notify the sponsor of the inclusion decision within 20 working days. If an application fails preliminary assessment or is withdrawn, application fees are strictly non-refundable. Applications selected for mandatory or discretionary application audit incur an audit assessment fee and require submission of full technical files within 20 working days. Extracted 29 August 2026.
  10. Therapeutic Goods Administration, New UDI requirements for medical devices commence 1 July 2026. From 1 July 2026 some medical devices supplied in Australia must meet Unique Device Identification requirements. Introduction begins with higher-risk devices (Class IIb and Class III), followed by lower-risk devices (Class IIa, Class Is and in vitro diagnostic devices) over later years. Points at the UDI requirements guidance, the UDI timeframes guidance, and the Australian UDI Database (AusUDID). This article uses that class-phased print and does not copy consultancy calendars that assign later classes to a specific 2027 or 2028 date. Extracted 29 August 2026; independently re-checked 29 August 2026.
  11. Therapeutic Goods Legislation Amendment (Australian Unique Device Identification Database and Other Measures) Regulations 2025 (FRL F2025L00414, 24 March 2025). Enacts statutory amendments to the Therapeutic Goods (Medical Devices) Regulations 2002 to mandate UDI carrier placement on labels and packaging, core data element submission to AusUDID, and compliance timeframes stratified by TGA device risk classification. Extracted 29 August 2026.
  12. Therapeutic Goods (Overseas Regulators) Determination 2018, Federal Register of Legislation compilation F2025C01149 (1 December 2025). Section 5 determines as overseas regulators: (a) an IAF accredited conformity assessment body; (b) a notified body; (c) a recognised or authorised MDSAP auditing organisation; (d) Health Canada; (e) Health Sciences Authority of Singapore; (f) Japan’s Ministry of Health, Labour and Welfare; (g) the Japanese Pharmaceuticals and Medical Devices Agency; (h) the United States Food and Drug Administration; (i) a UK approved body. China NMPA is not named. Independently downloaded and read 29 August 2026.
  13. Therapeutic Goods Administration, Using assessments from comparable overseas regulators for medical devices, and Use of market authorisation evidence from comparable overseas regulators and assessment bodies for medical devices (including IVDs). Guidance detailing how overseas evidence supports Manufacturer Evidence and abridged TGA ARTG inclusion. Table 2 mandates the exact documents required per regulator and class to pass preliminary assessment. Extracted 29 August 2026.
  14. Therapeutic Goods Administration, Fees and charges: Summary From 01 July 2026 (Version 1.0, July 2026). Official medical-device inclusion application fees (Table 41): Class III AUD 1,603; Class IIb AUD 1,244; Class IIa AUD 1,244; Class I sterile, measuring, or other AUD 651. Annual charges: Class III / AIMD AUD 1,662; Class IIb / Class IIa AUD 1,305; Class I sterile or measuring AUD 879; Class I other AUD 121. Application audit assessment fees (Table 43): Level 1 AUD 4,926; Level 2 (Class III, in-depth technical documentation review) AUD 18,118. Manufacturer Evidence remains no-fee per the Manufacturer Evidence page. Independently copied from the official PDF 29 August 2026.
  15. Australian Register of Therapeutic Goods public search (compliance.health.gov.au/artg/). Snapshot dated 6 July 2026 contains 97,472 therapeutic-good rows, of which 61,995 are labelled Medical Device (61,994 unique device ARTG IDs) across 10,457 named manufacturers (27 blank) and 3,344 sponsors. The extract has no TGA Class I–III column. A string search for 'Medison' on device rows returns ARTG 301721 (Samsung Medison Co Ltd ultrasound, sponsor Quantum Health Group); additional 'Medison Pharma Australia' hits in the full snapshot are medicines, not devices, and are not Weihai Medison. VEMERIX string hits: 0. Independently recomputed 29 August 2026.
  16. Public VEMERIX product pages used only as worked-example identity, not as Australian authorisation evidence: Circumcision Device (self-detaching ring; NMPA Class II, Lu Mech Reg. 20172020238; CE yes as stated on the product page; 14 size codes; EO-sterilized) and Disposable Medical Laser Fiber (NMPA Class II, Lu Mech Reg. 20192010517; 1470 nm endovenous workflow; no Medison CE claim). This article does not assign a TGA class, UDI date, ARTG number, or Australian sponsor to either SKU, and does not treat the partner-supplied NOVACURE console as a Medison-manufactured capital system. Independently checked against the public product pages 29 August 2026.
  17. Therapeutic Goods Administration, Reporting adverse events for medical devices. Initial-report timeframes: events that represent a serious threat to public health — 48 hours after becoming aware; death or serious deterioration in health — 10 days; an event that might lead to death or serious deterioration — 30 days. Follow-up no less than every 30 calendar days; final report within 120 calendar days of the initial report. Independently extracted 29 August 2026.

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.