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ToggleImport Class C and D Medical Devices into Vietnam requires what procedures to stay compliant and avoid unnecessary delays? This is a question many businesses are facing as regulations continue to tighten in 2026. In this article, Green NRJ walks you through each key step, from preparing documentation and obtaining registration to navigating importation and market entry, so you can approach the process with clarity and confidence.
Vietnam has a high demand for medical equipment, especially products for advanced diagnosis and treatment. However, alongside this development is an increasingly stringent management system aimed at controlling quality and ensuring user safety.
For Class C and D equipment, the regulatory authorities apply stricter control mechanisms compared to other groups. Notably, regulations allowing temporary circulation or import without registration numbers ended at the end of 2024, making the completion of procedures before import a mandatory requirement in most cases.
Medical devices in Vietnam are divided into four groups based on risk level. Category C represents medium-high risk, while Category D represents the highest risk, typically applied to devices that can directly affect the life or serious health condition of patients, such as implants or life support devices.
The classification is not pre-determined by the Ministry of Health but is the responsibility of the organization registering the device for marketing authorization, usually an authorized representative of the manufacturer in Vietnam. This approach shortens processing time but requires businesses to take responsibility for the accuracy of the classification results.
In practice, the regulatory authority still has the right to re-examine the classification when necessary. If the classification is found to be inconsistent with the prescribed risk assessment rules, the application may be required to be adjusted, potentially affecting the validity of the granted marketing authorization. Therefore, correctly identifying whether a vehicle belongs to group C or D from the outset is not only a technical requirement, but also a crucial factor determining the progress and legality of the entire registration process.
For Class C and D medical devices, obtaining a marketing authorization number is a mandatory requirement before importing and marketing the product. To obtain a registration number, the entity named in the application in Vietnam needs to prepare a complete set of documents as required.
The large volume of documents and the high level of expertise required necessitate thorough preparation from the outset.
| No | Document | Requirements | Remarks |
| 1 | Application form for new Marketing Authorization (per Ministry of Health template) | Signed & stamped by the company, color scan | Prepared by Green NRJ based on information provided by the client |
| 2 | CFS (Certificate of Free sales) | Consular legalized, color scan | Provided by the client |
| 3 | ISO 13485 | Color scan | Provided by the client (Note the manufacturing scope) |
| 4 | Letter of Authorization (LOA) from the owner to the registrant | Per Ministry of Health template, consular legalized | After receiving the CFS, ISO, and product list, Green NRJ will draft the LOA for the client to get from the Manufacturer |
| 5 | A warranty eligibility certificate issued by the medical device owner, except for single-use medical devices as specified by the owner of the medical device. | Per Ministry of Health template, consular legalized | After receiving the CFS, ISO, and product list, Green NRJ will draft the WA for the client to get from the Manufacturer |
| 6 | CSDT Dossier for submissions from Jan 1st, 2024 (Applied to priority processing) | Handled by the client or Green NRJ upon receipt of documents | |
| 6.1 | Technical assessment results of the ASEAN CSDT by a Ministry of Health-designated body (Applied to standard processing) | Client submits CSDT to the designated body for assessment (additional fees apply) | Client sends assessment results to Green NRJ |
| 7 | Instructions for Use (IFU) (Original English from Manufacturer + Vietnamese translation) | Signed & stamped by the company, color scan | Client provides both original and translated IFU |
| 8 | Client provides both original and translated IFU | Signed & stamped by the company, color scan | Client provides original labels; Green NRJ prepares secondary labels for client’s signature |
| 9 | Product Catalog | Signed & stamped by the company, color scan | Provided by the client |
Source: Adapted from Green NRJ. For more details, see the original article: Vietnam Medical Device Registration Guide (2026)
Regarding processing time, provided the application is complete and no additional documents are required, the review process typically takes about 2 to 3 months. However, in practice, requests for revisions or additions are quite common. Each revision can extend the process by another 2 to 3 months, or even longer if the required adjustments involve technical documents or paperwork from abroad. Therefore, preparing a complete and consistent application from the outset not only shortens the review time but also minimizes disruptions to import and business plans.
Once a valid marketing authorization is obtained, businesses can begin importing goods into Vietnam without needing to apply for additional import licenses in most cases. However, at the customs stage, everything still needs to be very carefully prepared, as even a small discrepancy can cause the shipment to be detained.

In reality, customs clearance documents are not overly complicated but require consistency. From bills of lading and commercial invoices to cargo manifests and certificates of origin, all must match the previously registered information. Many delays are not due to missing documents, but rather to inconsistencies in information between documents, such as product names, models, or manufacturers.
Furthermore, for some sensitive or high-value equipment, authorities may request physical inspections to compare with the documentation. In such cases, if the documentation is complete from the start, processing is usually quick; otherwise, it will take more time for explanations.
Therefore, the experience of many businesses is to not wait until the goods arrive to review the documents, but to prepare and check all documents in advance from the planning stage of import. This approach significantly reduces the risks arising during the customs clearance process.
Many businesses often think that simply importing goods is enough to sell them on the market. However, with Class C and D medical equipment, things are not that simple. To distribute legally, businesses are required to declare their eligibility for buying and selling according to current regulations.
In reality, regulatory agencies not only look at paperwork but also consider the operational capacity of the business. The distribution unit needs to have personnel in charge with expertise in the relevant field and a thorough understanding of the products they are selling. At the same time, storage conditions must be ensured, from warehousing to the arrangement and monitoring of goods, to avoid affecting the quality of the equipment.
One point that many businesses easily overlook is the establishment of procedures for handling incidents and product recalls. This is not just a requirement on paper, but a factor demonstrating the ability to control risks once the equipment has been put into use.
If inspected and found to be non-compliant with its stated standards, the business may be required to cease operations to rectify the issues. Therefore, instead of merely going through the motions, many experienced businesses invest systematically from the outset to avoid future problems and build trust when working with hospitals and domestic partners.
During implementation, many businesses encounter difficulties not due to complex regulations but due to a lack of coordinated preparation between steps. A mistake at the beginning can affect the entire subsequent process. Furthermore, transitional regulations only apply to specific cases and have clear deadlines. Therefore, proactively completing the registration process remains a safer and more stable approach. Developing a clear plan from the outset will help businesses save time and costs and minimize legal risks.
Importing Class C and D medical equipment into Vietnam is a process requiring thorough preparation and strict adherence to current regulations. By understanding each step and implementing it correctly from the start, businesses can avoid many obstacles in bringing their products to market.
Green NRJ is ready to support you from consultation and document preparation to procedural implementation, ensuring a smooth and compliant import process. Contact Green NRJ to partner with us and build a suitable roadmap for your business.