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Japanese Designated Marketing Authorization Holder (D-MAH)


  • What is the difference between an MAH and a D-MAH?
  • How do I maintain control of my device registration in Japan?
  • Can I use my distributor as my MAH/D-MAH?

Japan's Pharmaceuticals and Medical Devices Act (PMD Act) requires all medical device and IVD companies with no location in Japan to appoint a licensed in-country representative known as a Marketing Authorization Holder (MAH). The MAH represents your company to Japanese regulatory authorities, and is responsible for ensuring the marketing, quality, and safety of products placed on the market.

Requirements for obtaining a Japan MAH License

The Marketing Authorization Holder (MAH) requirements are strict, much more so than a European Authorized Representative or US Agent. Your MAH must be based in Japan, formally licensed by the prefectural (regional) government, and employ a General Manager, Quality Manager, and a Safety Manager.

MAHs must also implement a quality management system based on MHLW Ordinance No. 169 and Good Vigilance Practices (GVP). Beyond having their name on your device labels, your MAH/D-MAH is responsible for the quality and safety of your products marketed in Japan so selecting a qualified partner is important.

Difference between an MAH and a D-MAH

Japan's Ministry of Health, Labour and Welfare (MHLW) permits manufacturers with no location in Japan to register their own Class II, III, and IV devices through the Foreign Special Approval System (FSAS). This registration route allows the manufacturers to own the registration of their product under their own name, instead of the MAH's name. In this case, the manufacturer bears full responsibility as MAH, and the appointed MAH is referred to as a Designated MAH, or D-MAH, as they do not own your device registration. Your D-MAH carries some of the same responsibilities that foreign manufacturers are deemed unable to adequately perform, such as final shipment release judgements and vigilance. This is a big decision so be sure to read the Frequently Asked Questions section below.

Japan MAH/D-MAH representation options available to foreign medical device manufacturers

If you have a subsidiary in Japan ...
Your subsidiary can obtain a MAH license and act as your MAH or D-MAH.

If you do NOT have a subsidiary in Japan ...

  1. You can engage a distributor with a MAH license and obtain marketing approval under their name. If you choose this option, your distributor will have complete control of your products in Japan.
  2. You can designate your distributor as your D-MAH and obtain marketing approval under your company name through the FSAS. However there are drawbacks to this option. Ask us for details.
  3. You can designate a third party or regulatory consulting firm like Emergo as your D-MAH. This option gives you the most flexibility.

Emergo is a professional, independent, D-MAH with offices in Tokyo

Emergo Japan holds a Type 1 MAH license from the Tokyo Metropolitan Government. Our goal is to help you maintain full control over your devices in the Japanese market. As your D-MAH, we will:

  1. Ensure the marketing, quality, and safety of your products.
  2. Act as your primary contact point for all Japanese regulatory authorities including the PMDA and MHLW.
  3. Assist in incident reporting in Japan as needed.
  4. Communicate with your distributor(s) to create your import procedures, prepare your import submissions, and clear products through Japanese customs.
  5. Communicate with your registered Japanese manufacturer in charge of warehousing of the final product to develop the Quality Agreement and prepare Medical Device File (Seihinhyojunsho) for receiving inspection, labeling and warehousing as applicable.
  6. Conduct audits of your facility, when applicable. (The MAH/DMAH may conduct QMS audit to your facility on the authority's request in the case of any serious adverse event due to a quality matter)
  7. Assist with regulatory amendment procedures for product design or manufacturing establishment changes as applicable.

The D-MAH is an important partner for your company in Japan, with significant regulatory responsibilities. Appointing Emergo as your independent D-MAH may make more sense than selecting your distributor to fulfill this role.

Please contact us for more information about Designated Marketing Authorization Holder (D-MAH) services for Japan.

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Listen to our 7 minute audio podcast interview discussing the role of the DMAH in Japan:

Interested in learning more about in-country representative requirements in Japan? Mic Miyahara, CEO of Emergo Japan, answers some of our most frequently asked questions in this podcast interview.

Frequently Asked Questions

Appointing our distributor as our MAH seems like the easiest option. Are there reasons not to do this?
Since the MAH submits and maintains your device approval and registration in its name, they have control over your device and commercialization. Appointing a distributor as your MAH could lead to challenges if you want to switch or add distributors in the future. Specifically, if you decide to change distributors, your device may have to go through the approval and registration process again unless your distributor fully cooperates with the transfer to another MAH.

Does my MAH/D-MAH need to be listed on the device labeling?
Yes, the MAH or D-MAH must be listed in the label and package insert.

We have a Class I device. Can we register through the FSAS system?
No. Class I devices are not eligible for registration through the FSAS system.