Updated/posted: January 2011
Validated by: (in process)
Map of China



China health care delivery system is challenged by providing services for the most populous country with 1.3 billion people and a majority of rural residents. Health care delivery follows a parallel three-tiered structure established in the 1950s for rural and urban areas. In urban area, there are public hospitals which are operated independently in different level (provincial, city or district) and 1st -tired hospitals are  mostly transformed to community health center in recent years. Few private hospitals exist in China. In rural area, county hospital, township hospital and clinics compose the three-tiered structure. There are also health surveillance institutions of various levels, such as CDCs.

The total China health expenditure is 1128.95 billion RMB (US $ 164.77) in 2007 and this number is increasing in the last few years. The percentage of health expenditure paid by government, employer contributions (society) and out of pocket is 20%, 35%, 45% respectively.  (ministry of health, 2009 yellow book) available at: http://www.moh.gov.cn/publicfiles/business/htmlfiles/zwgkzt/ptjnj/200908/42635.htm

To address the escalating health expenditure, system inefficiency, and low insurance coverage, China implemented several health insurance reforms in the last few years. Besides commercial medical insurance, current health care system consists of three main social insurance programs: Urban Employee Basic Medical Insurance (UEBMI) for the urban employed (1997), Urban Resident Basic Medical Insurance (URBMI) for urban residents without formal Employment, New Cooperative Medical Scheme (NCMS) for the rural population (2003).

Figure 1: Health Insurance programs

Figure 1

Source: Ministry of Health, 2009 Yellow Book. http://www.moh.gov.cn/publicfiles/business/htmlfiles/zwgkzt/ptjnj/200908/42635.htm

Financing health insurance is different for each program. Take Shanghai URBMI for example, three different accounts are used for collecting fund and pay for specific health service.

Fig 2 URBMI Funding Source (Shanghai)

Source: Shanghai Medical Insurance Bureau http://ybj.sh.gov.cn/index.jsp
Lin Yang (2004), Study on expenditure containment of Shanghai Urban Medical Insurance System, Shanghai Jiao Tong University. (In Chinese)


The value of China’s medical device market is expected to be US$28 billion by 2014 -- more than double the data from 2006. The increasing demand for home-use devices or high-quality implants and China new policy on expanding health coverage in rural areas bring this growth in the market of medical device.

The domestic market for medical devices is still highly fragmented. Most of medical device manufacturers have limited market share and operate on a small scale with only a handful of profitable products. There are only four Chinese medical device companies traded on global exchanges. Domestic device makers are working to develop high-quality devices at a cost basis 30% lower than that of foreign competitors. Foreign companies have a comparative advantage in terms of technology and presently control 90% of the high-end device market, especially large medical device manufacturers from Japan, Germany, and the USA. Although the government is emphasizing low cost devices for rural projects, major hospitals in China still demand the best foreign equipment. Moreover, Chinese consumers are also wary of domestic brand and have increasing demand for foreign medical device when considering quality.

Source: http://www.knowledgeatwharton.com.cn/index.cfm?fa=viewArticle&articleID=2082&languageid=1




SFDA (State Food and Drug Administration) is current national authority for medical device in China. According to the current regulation issued in 2000 by State Council, medical device are categorized into three classes, and for products in each class, they must comply with different standards and requirements for registration certificates and licenses under different authorities.



Registration Authority

Class I

Safety and effectiveness can be ensured through routine administration;

Municipal Department

Class II

Further control is required to ensure their safety and effectiveness

Provincial and municipal Department

Class III

Medical device that are implanted into the human body, or used for life support or sustenance, or pose potential risk to the human body and thus must be strictly controlled in respect to safety and effectiveness.


Source: Regulations for the Supervision and Administration of Medical Devices, Decree 276 of the State Council, issued on January 4, 2000, effective since April 1, 2000 www.sfda.gov.cn


AQSIQ (General Administration of Quality Supervision, Inspection and Quarantine of People’s Republic of China)
AQSIQ is a ministerial administrative organ directly under the State Council which is in charge of Quality Supervision, Inspection and Quarantine. There are 35 CIOs (Entry-Exit Inspection and Quarantine Bureaus) and 31 provincial bureau of quality and technology supervision under AQSIQ. One important mission of AQSIQ is to carry out inspection and supervision on import and export commodity and its packaging and transportation means. Imported medical device assessment is mainly conducted by CIOs which administers the China Compulsory Certificate (CCC) program, a quality certification that is mandatory for a range of specified products, including diagnostic X-ray equipment, hemodialysis equipment, implantable cardiac pacemakers, and other medical devices.  These tests are extremely similar to the tests the SFDA required in registration process. In the fall of 2008, the SFDA and AQSIQ jointly agreed on CCC marking and SFDA medical device registration will now share a single testing process, with no duplication of tests or fees. This strategy greatly released manufacturers burden and make utility of inspection resources more efficient.

SFDA- Department of Medical Device Supervision
As part of SFDA, department of Medical Device Supervision plays a significant role in HTA during registration and post-market phases. The main responsibility of Department of Medical Device Supervision is to register medical device, draw up good practices for clinical trials, production and distribution of medical devices, supervise these practice and organize the adverse events monitoring, and medical device reevaluation.

SFDA- Ten Medical Device Quality Surveillance and Test Institutes
There are ten core medical device quality surveillance and test institutes located in different cities. They are directly administrated by SFDA and provide HTA service of medical device in different dimension.

(1) Medical Device Quality Surveillance and Test Institute: biological materials, artificial organs and tissue engineering.
(2) Tianjin Medical Device Quality Surveillance and Test Institute: orthopedic materials and equipment, medical equipment of physical therapy;
(3) Shenyang Medical Device Quality Surveillance and Test Institute: X-ray diagnostic equipment (including CT) and accessories, medical refrigerated products;
(4) Hangzhou Medical Device Quality Surveillance and Test Institute: optical equipment, medical laser equipment, medical equipment of deep hypothermia therapy;
(5) Beijing Medical Device Quality Surveillance and Test Institute: IVD, radiotherapy equipment;
(6) Jinan Medical Device Quality Surveillance and Test Institute: medical polymer materials, sanitary materials;
(7)Guangzhou Medical Device Quality Surveillance and Test Institute: Dental equipment, disinfection equipment etc;
(8) Dental Materials Quality Surveillance and Test Institute in Peking University: Dental materials;
(9) Shanghai Medical Device Quality Surveillance and Test Institute: anesthesia and respiratory equipment, surgical instruments etc.
(10) Wuhan Medical Device Quality Surveillance and Test Institute: ultrasonic diagnostic equipment.


Regulatory Pathway/Market Approval Process

Registration procedures differ for domestic and imported medical device and registration certificate or license of medical device is only effective for four years; when it expires manufacturers must register it again. Some experts argued the same procedure and requirement for re-registration is inefficient and costly. In 2008, the number of medical devices successfully registered in Class I, II, III was 2117, 2172, 1485 respectively, the successful re-registered number of class I and II is 1583 and 2234 respectively. In addition, the number of imported medical devices approved is 3683, this number kept increasing in past three years. (SFDA Annual Report)


A: Class III (license for manufacturing trial)    
B: Class I (license for manufacturing or re-registration)
C: Class II (license for manufacturing trial) and Class II, III (license for manufacturing or re-registration)


Resource: Xianqiang Mi (2008), Management of Medical Device Supervision in China (in Chinese)


In late 2008, the SFDA issued new rules and procedures for determination of effective coverage of IVD Quality System Audit ((SFDAM [2007]229). IVDs are divided into 23 categories and IVDs in different categories must process quality system audits that are designed and implemented separately. In addition, IVDs with different risk classifications have different audits applied to them.
Source: www.sfda.gov.cn


Reimbursement and Coverage/Payment Flow Map and Procurement Process

Since 1999, China has adopted a tendering method as a significant part of medical device procurement process because this method could bring more transparency and safeguards to ensure access for patients and quality of the medical technology.
Since 2005, in order to reduce the corruption, the Ministry of Health (MOH) and the State council set up a procurement restriction on large scale equipments which are priced over 5 million RMB ($730,000). Under the restriction, individual hospitals and other private medical organizations are strictly forbidden to purchase any large scale equipment if it is a used and imported product. Government  also interferes in  the procurement process by collective purchasing and tendering of large scale medical equipment, and then reallocating  the medical device to the hospitals or organizations. In 2005, MOH implemented a pilot program in eight areas (Beijing, Shanghai, Zhejiang, Tianjin, Hubei, Guangdong, Chongqing, and Liaoning) which targeted orthopedic and cardiac implants for the major hospitals.  This program was designed to favor companies which are operating without distributors (a process which was facilitated by China’s accession to the WTO), because Chinese officials believe that distributors contribute to high prices and corruption. In 2007, a system of comprehensive centralized tendering was adopted in all provinces.


Pricing and reimbursement of medical device is regulated by the National Development and Reform Commission (NDRC) and the Ministry of Health (MOH). Reimbursement mechanisms and pricing is complicated since it is designed to meet different requirements at provincial/ municipal level.  In general, reimbursement schemes treat the medical device differently by classifying them into two types: implantable or disposables. Only medical devices which are approved and put in the pricing formulary regulated by government could get reimbursed under the medical insurance coverage. Because of variety, we take Shanghai for example to explain pricing and reimbursement process.

Shanghai pricing process
In 2003, Shanghai government promotes its new pricing system and set the price ceiling for registered medical devices.  To be included in an application for a local retail price, distributors need to provide import prices and other supporting data directly to the Shanghai Medical Device Association which is responsible for coding medical device. After that, the application is transferred to the Shanghai Pricing Bureau, which is in charge for setting the highest allowable price for medical device, making final decision and making the highest allowable price to public.
It is worth mentioning that, once the highest allowable price is set, the medical device would be put into the “Pricing management formula” and qualified to get reimbursement, otherwise the medical device is  excluded from  the insurance coverage.

Shanghai Pricing

Source: Shanghai Health Bureau http://www.hs.sh.cn/website/b/32071.shtml

Shanghai  Reimbursement Approval Process 

  1. Shanghai Urban Basic Medical Insurance (UBMI)
    Medical device reimbursement must follow the basic requirement for UBMI. There are different eligibility and basic package for UBEMI and UBRMI. Following illustrates how UBRMI reimbursement service of medical technology.

    Emergency room
    Free checkout

    1000, 700, and 500 RMB for
    tertiary, secondary, and primary
    medical institutes, respectively


    (1) Residents over 70:70%
    (2) Residents aged 60-70: 60%
    (3) Residents aged 18-60:50% (1000 RMB deductible, if in 1-tired hospital 60%)
    (4)Students and
    residents under 18
    and not attending
    school: 50%


    (1) Adults:
    80 000
    (2) Student
    and resident
    18 and not attending
    100 000


    (1) Residents over 70:60%
    (2) Residents aged 60-70: 60%
    (3) Residents aged 18-60:50 %( if in 1-tired hospital 60%)
    (4)Students and
    residents under 18 and not attending school: 50%


    services reimbursement
    for10 chronic or

    fatal diseases

    Residents aged 60-70: 50%


    Source: Shanghai Medical Insurance Bureau http://ybj.sh.gov.cn/xxcx/zgdy.jsp?lm=3

  2. Medical device reimbursement under UBMI




    Bone Fixation

    Inside of Spine


    20,000 RMB

    Outside of Spine


    10,000 RMB

    Implantable medical devices for Congenital heart disease treatment



    25,000 RMB

    Implantable medical devices for Peripheral vascular, Neurovascular disease treatment

    Domestic product



    Imported product



    * means coinsurance rate is according to UBMI requirements

    Shanghai Health Bureau http://www.hs.sh.cn/website/b/32071.shtml
    Shanghai municipal labor and social security bureau   http://www.12333sh.gov.cn/07zcfg/gfxwj/200912/t20091209_1104092.shtml



According to general registration process, each phase have specific data requirement:
1. Application preparation:

  • To Compile a Product Standard;
  • Laboratory Test data (based on your chosen standard) for the Product at a SFDA recognized Testing Lab (applicable for class II and III products);
  • Data of Clinical Trial in 2 Hospitals in China (applicable only for implantable products manufactured by a foreign company which has never registered a medical device in China), or to collect Clinical Data for Product (applicable for all other class II and III products).

2. Application (application dossier (12 items))

  • Application Form for the registration;
  • Qualification certificate(s) (Business License, etc.) of the applicant (manufacturer);
  • Copy of Business License of the Application Agent and the authorization letter written by the applicant to the agent;
  • Marketing authorization certificate issued by a foreign competent authority to allow the product to be marketed in that country (or Region) as a medical device.
  • Adapted product standard;
  • Instruction Manual of the device;
  • Product Testing Report issued by a SFDA recognized testing lab (applicable for class II and III products);
  • Clinical Test Report or clinical data;
  • Product quality guarantee letter of the applicant;
  • Authorization letter written by the applicant to a Representing Agent in China, letter of promise written by the Representing Agent, and Business License or Organization Registration Certificate of the Agent;
  • Authorization letter written by the applicant to a responsible Post-marketing Service Agent in China, letter of promise written by the agent, and qualification Certificate of the Agent;
  • Self-Declaration for the authenticity.

3. Audit and Assessment:

  • Clarify technical issues or finds the application dossier is insufficient in technical data

4. Disclose final decision


  1. Application form
  2. Evidence supporting clinical application
  3. Evidence supporting specific clinical application in detail
  4. Medical device certificates or license for allocation
  5. Medical device certificates or license for registration by SFDA or Medical device certificates or license for registration by Municipal Department
  6. Other data municipal health insurance bureau required 
  1. 、《上海市基本医疗保险部分诊疗项目约定服务申报表》;
  2. 、纳入国家和本市医疗技术临床应用准入管理制度的诊疗项目,应提供国家或本市卫生行政管理部门相应的批准文件复印件;
  3. 、本市卫生行政管理部门批准的相应诊疗科目批复复印件;
  4. 、应用大型医用设备的,应提供国家或本市卫生行政管理部门核发的《大型医用设备配置许可证》或《上海市装备贵重医疗设备许可证》等相关批准文件复印件;
  5. 、应用一次性使用和植入型医疗器械开展的诊疗项目,应提供国家或本市食品和药品监督管理部门、卫生行政管理部门核发的《医疗器械产品注册证》、《上海市消毒产品生产企业卫生许可证》等相关批准文件复印件。
  6. 、市医疗保险办公室要求的其他相关材料。 



AQSIQ: General Administration of Quality Supervision, Inspection and Quarantine of People’s Republic of China
CIOs: Entry-Exit Inspection and Quarantine Bureaus
IVD: In-vitro Diagnostic
NDRC: National Development and Reform Commission
SFDA: State Food and Drug Administration
UBMI: Urban Basic Medical Insurance





Lizheng Shi PhD, MsPharm, Tulane University School of Public Health and Tropical Medicine, New Orleans, LA, USA
Xi Cheng
Laura Liu


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