Medical devices · NAFDAC

Nigeria promised to take UKCA

In February 2024 Nigeria and the United Kingdom signed a partnership in which Nigeria said it would recognise the UKCA mark for medical devices. Article 7 of the same document says it creates no legally binding rights or obligations — and no Nigerian instrument has implemented it since. This page is about the gap between those two facts.

UKCA mark what you hold ETIP promise 13 February 2024 NON-BINDING NOT IMPLEMENTED NAFDAC registration, 5 years SONCAP if it is equipment
Even on its own terms the promise was conditional on holding NAFDAC and SONCAP licences. It removes nothing from the route below it.
A–Dfour risk classes, assigned by the Agency itself
120working days published in the guideline — and 90 days in the service charter
$750per imported device, priced in dollars rather than naira
5 yearsvalidity of a registration certificate
The question everyone asks first

Does your CE, UKCA or FDA approval help?

Nigeria is the only country that has promised to take UKCA. It has not done it.

The Enhanced Trade and Investment Partnership signed on 13 February 2024 says, under health and life sciences, that "Nigeria will recognise the UK conformity assessed (UKCA) mark for medical devices in so far as all the medical devices to be exported from the United Kingdom to Nigeria will comply with the SONCAP and NAFDAC Licenses."

Two things about that sentence. First, Article 7(a) of the same arrangement states that it "does not create legally binding rights or obligations under domestic or international law". Second, read it again: the recognition is conditional on complying with SONCAP and NAFDAC licensing anyway — so even taken at face value it removes no step from the route.

We then looked for the Nigerian instrument that would give it effect, and there is none. NAFDAC's gazetted Medical Devices Regulations of 2024 and its three device guidelines of November 2024 name no foreign regulator and no foreign mark at all — not UKCA, not the MHRA, not CE, not the US FDA, not Health Canada, not the TGA. The only reliance provision, regulation 14, is anchored to World Health Organization listed-authority status and expressly preserves NAFDAC's right to its own national decision.

The ministerial dialogue of March 2026 did not report the commitment as delivered. It covered standards cooperation between BSI and the Standards Organisation of Nigeria, accreditation, health technology assessment and pharmaceutical reliance — medical devices are not addressed as a category and the MHRA is not mentioned.

What this is worth to you anyway. Not nothing. A UK manufacturer needs a Certificate of Free Sale from its own authority, and the MHRA issues one for devices registered on its system bearing UKCA, CE or CE UKNI marking. That certificate is a mandatory part of the Nigerian file. So the mark gets you the document you need — it just does not shorten the assessment, because nothing does.

An unusual structure

Half of what you must do is not in the law

This is the finding that surprised us most, and it changes how you should read any Nigerian advice you are given. The gazetted statutory instrument is short on applicant requirements. Almost every obligation a foreign manufacturer actually meets sits in NAFDAC's guidelines instead — enforceable as practice, but resting on softer footing than a gazetted regulation.

In the gazetted regulations

S.I. 42 of 2024 · gazette no. 176 · 16 October 2024
  • Four risk classes, A to D, assigned by the Agency under the Schedules
  • Registration valid five years and renewable
  • Nothing may be imported, distributed, advertised, sold or used unless registered
  • A certificate may not be lent, hired, sold or transferred without the Agency's approval
  • Post-market surveillance duties on the manufacturer
  • Labelling in English, carrying the NAFDAC registration number; batch, lot, serial number and a barcode on the packaging
  • Penalties to ₦800,000 for individuals and ₦5,000,000 for companies

Only in the guidelines

VBM-R&RA-GDL-001-00 · effective 4 November 2024
  • The local agent, and evidence of its incorporation with the Corporate Affairs Commission
  • A notarised power of attorney from the manufacturer, valid at least five years, naming ownership of the brand
  • The Certificate of Manufacture and Free Sale, authenticated by the Nigerian High Commission
  • Registration of the brand name with the Nigerian trademark registry, in the name of the trademark owner
  • The invitation letter for inspection of the overseas manufacturing site
  • The 120 working day timeline

Nothing in the gazetted instrument says the applicant must be Nigerian. The requirement arrives sideways: the guidelines want a power of attorney running from you to somebody else and evidence of that somebody's Nigerian incorporation, and the import mechanics want a Nigerian company with a tax identification number and an authorised dealer bank. The effect is the same. The legal basis is not.

Why we are telling you this rather than smoothing it over. Because it predicts the failure mode. A requirement that lives in a guideline can be revised without a gazette, and the guideline in force was issued in November 2024 with a review date of November 2029. Draft replacement regulations for 2025 and for 2026 sit in NAFDAC's own folders, apparently folding in-vitro diagnostics into the same instrument. We could not open either and we will not describe their contents — but a market whose rules are being rewritten is one where the date on your advice matters.

The route

Six steps, and two of them are outside NAFDAC

  1. 01

    Register the brand name in Nigeria

    NAFDAC wants evidence that the brand is registered with the trademark registry at the Ministry of Industry, Trade and Investment, in the name of the trademark owner. This is a separate proceeding with its own queue, it is not NAFDAC's, and it is the step most often discovered late. Start it first.

    You, with Nigerian counsel
  2. 02

    Appoint the local agent, carefully

    Incorporated in Nigeria, holding a notarised power of attorney from you that runs at least five years and states who owns the brand. Read the structure section below before you sign this, because the certificate and the agent are harder to separate here than anywhere else on this site.

    Us, with you
  3. 03

    Get the free sale certificate legalised

    The MHRA issues it for devices on its register carrying UKCA, CE or CE UKNI. Nigeria is not a party to the Hague Apostille Convention, so an apostille will not do: the certificate must be authenticated by the Nigerian High Commission — or, where there is no Nigerian mission, by any Commonwealth or ECOWAS country's.

    You, tracked by us
  4. 04

    File through the portal and import the samples

    The application and dossier go in electronically. On successful screening NAFDAC issues a permit to import registration samples, which then go for laboratory analysis. The file also has to carry an invitation letter for inspection of your manufacturing site.

    Agent, managed by us
  5. 05

    Analysis, committee, certificate

    Samples are analysed, the product is presented to the registration committee, and an electronic certificate of registration issues with five years' validity. The published timeline is 120 working days from acceptance of the submission, and the clock stops whenever a compliance query is raised.

    Us
  6. 06

    Then the trade documents, and possibly SONCAP

    Each shipment needs a Form M on the national trade platform and a clearance report from Customs. If your device is equipment or a machine, it also needs SONCAP — see the next section, because this is where most people are caught out.

    Shared — we run the calendar
The second regulator

SONCAP is not displaced by NAFDAC

The exemption reads: "Medicals, other than equipment and machines."

The Standards Organisation of Nigeria exempts food, medicines and medical items from its offshore conformity scheme — but the exemption expressly carves out equipment and machines. Read literally, a medical device that is a machine sits inside SONCAP scope and needs a SONCAP certificate as a customs clearance document, in addition to its NAFDAC registration. SON adds that exemption from the offshore scheme does not mean a product is unregulated by SON.

We could find no document from either agency that reconciles the two regimes or draws the line between a medical "medical" and a medical "machine". That boundary is worth establishing in writing before you build a landed-cost model, because a SONCAP certificate is what permits the Form M to be opened in the first place.

And since July 2026 there is a third document for tenders. Federal procurement now requires an attestation certificate against the relevant Nigerian Industrial Standard as a mandatory bid document, where such a standard applies, under a policy prioritising goods made in Nigeria. Separately, the Public Procurement Act allows a margin of preference for domestic bidders in international competitive bidding — discretionary, and set by regulation rather than fixed in the Act.

Structure

The certificate, and who ends up holding it

The gazetted regulation says a certificate of registration may not be lent, hired, sold, transferred or otherwise disposed of to another person without the Agency's approval. So transfer is possible. What does not exist is a published procedure for it.

We searched the gazetted regulations, both registration guidelines and NAFDAC's application forms page. There is no change-of-agent form, no transfer-of-certificate form, no fee line and no timeline. The only description of how it works in practice comes from a Nigerian law firm, which describes writing to NAFDAC to revoke the previous power of attorney and introduce the new agent, supported by notarised instruments — and which cites no NAFDAC authority for that procedure. We are reporting it as what it is: unpublished practice.

The same source states that for a foreign manufacturer the registration certificate is issued in the local agent's name. We could not confirm that from any NAFDAC document, and we are not going to assert it. But if it is right, it matters more than anything else on this page, because it means the asset you are paying to create is registered to somebody else and can only be moved with a regulator's discretionary consent.

How we would handle it. Establish in writing, with NAFDAC, whose name goes on the certificate and what a change of agent actually requires — before the power of attorney is signed, not after the relationship sours. That question is the first item in an assessment for this market, and it is the reason we would not let a client sign a five-year power of attorney on a distributor's template.

After approval

The vigilance clocks are short, and they bind your importer too

A post-market surveillance and reporting guideline for devices and in-vitro diagnostics took effect on 19 August 2025. It puts duties on manufacturers, marketing authorisation holders, importers and distributors, which makes it a contract question with your Nigerian partner rather than purely a regulatory one.

48 hoursfastest
Serious public health threat
2 days
Death or serious deterioration
10 days
Serious incidents
30 dayslongest
Potential serious harm

Calendar days, from the post-market surveillance guideline effective 19 August 2025. Field safety corrective actions are reportable immediately upon identification. Bars are proportional to the deadline — the two shortest are barely visible, which is the point.

There is no unique device identification requirement in Nigeria. The gazetted regulation asks only for a batch number, lot number, serial number and a barcode on the packaging, and neither the vigilance guideline nor the two conformity assessment guidelines mention UDI. That is a confirmed absence, not a gap in our reading — and it is one of the few places where Nigeria asks less than the markets around it.

Time and money

Priced in dollars, on a tariff from 2020

NAFDAC prices imported product registration in United States dollars, payable at the naira equivalent on the day. Given what the naira has done since, that is a deliberate and rather sensible piece of drafting — and it means the figure below has not been eroded the way a naira figure would have been.

ItemFee
Registration, imported medical deviceUS$750
Registration, imported diapers and sanitary padsUS$874
Registration, locally manufactured device₦20,000
Renewal80% of the registration fee
Change in variants50% of the registration fee
Permit to import, per product₦11,000
Laboratory analysis, imported device₦67,500
Port inspection, medical devices₦27,000
Certificate of free sale issued by NAFDAC₦25,000

From the NAFDAC tariff stated to take effect in January 2020, which is the only tariff document we were able to open — the tariff index page did not respond on repeated attempts, so we cannot tell you whether a newer edition exists, and we re-confirm the figures with NAFDAC before they enter a quote. All amounts are exclusive of value added tax. Two structural notes: the tariff still uses the old "medical devices 1 and 2" split and carries no fees by risk class, because it predates the four-class regime; and there is no fee line at all for registering an agent.

Two NAFDAC documents give two different timelines.

The registration guideline effective 4 November 2024 states 120 working days from acceptance of the submission to issuance of the registration number, with the clock stopping whenever a compliance query is raised. NAFDAC's service charter promises registration within 90 days. Those do not reconcile — 120 working days is roughly twenty-four weeks. The charter carries no date or version; the guideline does. We quote the guideline and we tell you about the charter, rather than quoting whichever number suits the conversation.

The question a board will ask

Will you get paid?

Nigeria's foreign exchange picture is materially different from the one most UK boards still carry in their heads, and the UK government's own risk page has not been updated since July 2023 — it still describes the shortages and delayed payments of that era.

On official sources: the naira was floated in June 2023 and the market segments were consolidated into a single willing-buyer, willing-seller market. In October 2023 the central bank lifted the restriction on foreign exchange access for the forty-three previously restricted import categories. The verified backlog of foreign exchange obligations, of the order of seven billion dollars, is stated as cleared. An electronic matching system followed in November 2024 and a foreign exchange code in January 2025. The International Monetary Fund classifies the regime as floating.

What remains, on the Fund's own account, is a set of unenumerated legacy exchange restrictions that it recommends eliminating, and capital flow measures that touch foreign securities, card payments abroad and oil company proceeds — none of which restricts an ordinary trade payment for imported goods. No medical device appears on the current import prohibition list, which covers certain medicaments and waste pharmaceuticals but no devices.

How we would put it to a board. The risk here has changed shape rather than disappeared. It is no longer rationing — it is regime and residual-restriction risk, plus the ordinary volatility of a floating currency. That is a smaller and more manageable exposure than the one your last briefing note probably describes, and it is worth re-checking rather than assuming.

Honest gaps

What we could not confirm

  • Whether the tariff is current

    The January 2020 tariff is the only one we could open. NAFDAC's tariff index page did not respond. We cannot say whether a newer edition exists, so we treat every figure as requiring confirmation.

  • Whose name is on the certificate

    A Nigerian law firm states it is issued to the local agent. No NAFDAC document we read says so. This is the most commercially important unresolved question on the page.

  • How a change of agent actually works

    The regulation makes transfer conditional on NAFDAC approval and publishes no procedure, form, fee or timeline for obtaining it.

  • What triggers an overseas factory inspection

    The invitation letter is a mandatory dossier item, but the device guidelines state neither the trigger criteria nor who bears the cost.

  • Where SONCAP stops and NAFDAC starts

    No document from either agency draws the line between a medical item and medical equipment or machinery.

  • The draft replacement regulations

    Drafts dated 2025 and 2026 sit in NAFDAC's own folders and we could not open either. We are not describing their contents and neither should anyone else.

One further note on method. NAFDAC's website refused automated access for roughly three requests in four during our checks, so several documents we know exist — including a guideline on registration under the World Health Organization collaborative procedure — are named here as unread rather than summarised. Everything stated as fact above was read from the document itself.

Our role

What we do here, and what we do not

We do

  • Sequence the trademark registration first, because it sits outside NAFDAC and has its own queue
  • Establish in writing whose name the certificate issues in, before a power of attorney is signed
  • Vet the local agent and negotiate a power of attorney that is not the distributor's template
  • Determine whether your device falls inside SONCAP as equipment, and price that separately
  • Allocate the vigilance reporting clocks between you and your importer, in the contract

We do not

  • Act as your local agent — that must be a Nigerian incorporated entity
  • Sell or distribute your product, or take margin on it
  • Tell you the trade partnership means UKCA is accepted. It is non-binding and unimplemented
  • Quote the 2020 tariff as current without re-confirming it with NAFDAC
  • Describe the content of draft regulations we have not been able to read
Before we start

What we will ask you for

  • Device description, intended purpose and variants in scope
  • Your proposed class under the A to D scheme, and your rationale
  • Whether the device is, in ordinary language, equipment or a machine
  • MHRA certificate of free sale, and your device registration status on the MHRA system
  • Declaration of conformity against the essential principles of safety and performance
  • ISO 13485 certificate and any certificate of compliance with recognised standards
  • Comprehensive certificate of analysis
  • Who owns the brand name, and whether it is registered as a trademark anywhere
  • Any existing Nigerian agent, distributor or power of attorney — and its expiry
  • Whether a NAFDAC registration already exists for your product in somebody else's name
  • Whether you intend to sell into federal tenders

The last two questions are not routine. An existing registration held by a former partner, and a five-year power of attorney you have forgotten about, are the two ways this market goes wrong before it starts.

Moving parts

What changed, and what was promised

  1. Feb 2024The UK–Nigeria Enhanced Trade and Investment Partnership is signed, including an intention to recognise the UKCA mark for medical devices — in a document that disclaims legal effect
  2. Oct 2024New Medical Devices Regulations gazetted, introducing the four risk classes, five-year validity and the transfer-consent rule
  3. Nov 2024Three guidelines issued: registration, and conformity assessment for in-vitro and non-in-vitro devices, both adopting the international harmonisation model
  4. Aug 2025Post-market surveillance and vigilance reporting guideline takes effect, binding importers and distributors as well as manufacturers
  5. Jul 2026A standards attestation certificate becomes a mandatory bid document in federal procurement where a Nigerian Industrial Standard applies
  6. Still openNothing has implemented the UKCA commitment. The March 2026 ministerial dialogue did not report it as delivered, and no Nigerian instrument names the mark

The other half of this market

Do you also make medicines?

The medicines answer is harder and more urgent. Nigeria publishes two lists — 36 actives and 29 products — and for anything on them NAFDAC states it will not entertain a new application or a renewal for an imported product. Before a Nigerian pharmaceutical project is worth planning, the molecule has to clear both lists.

The medicines page for Nigeria, with a molecule check →

Start with the trademark and the power of attorney

Everything expensive about Nigeria is decided in those two documents, and both are signed before NAFDAC sees anything. Send us the device and we will tell you what to sign and in whose name.

Or reach us directly — mail@bcabusiness.co.uk · +44 7342 901002 · WhatsApp

Checked against NAFDAC, SON, CBN,
the IMF and GOV.UK · 11 September 2026

Sources

  1. NAFDAC Medical Devices and Related Products (Registration, Labelling, Advertisement) Regulations, 2024 — statutory instrument no. 42 of 2024, Federal Republic of Nigeria Official Gazette no. 176, volume 111, 16 October 2024. Regulations cited: 3 and the Schedules for classification, 4(7) five-year validity, 12 post-market surveillance, 14 regulatory reliance, 16 and 19 labelling and packaging, 47 the prohibition and the transfer-consent rule, 48 penalties.
  2. Guidelines for Registration of Medical Devices in Nigeria, document reference VBM-R&RA-GDL-001-00, effective 4 November 2024, review November 2029 — the local agent, power of attorney, free sale certificate, trademark evidence, inspection invitation and the 120 working day timeline.
  3. NAFDAC Guidelines for Conformity Assessment of in-vitro diagnostic and of non-in-vitro diagnostic medical devices, both effective 19 November 2024, adopting the international harmonisation model.
  4. Guidelines for Post-Market Surveillance and Reporting of Medical Devices and In Vitro Diagnostics, document reference PMS-GDL-024-00, effective 19 August 2025 — the reporting clocks.
  5. NAFDAC tariff, stated effective January 2020 — all fee figures, with the caveat stated in the fees section.
  6. NAFDAC service charter, undated — the ninety-day registration promise.
  7. Standards Organisation of Nigeria, SONCAP scope and exemptions.
  8. Enhanced Trade and Investment Partnership arrangement between Nigeria and the United Kingdom, signed 13 February 2024, published on GOV.UK 26 April 2024 — the UKCA passage and article 7(a). And the ministerial dialogue communiqué of 16 March 2026.
  9. MHRA — certificates of free sale for medical devices, guidance updated 1 April 2026. HCCH status table for the Apostille Convention, current to 30 June 2026: Nigeria is not a contracting party.
  10. Central Bank of Nigeria reforms and foreign exchange management pages; International Monetary Fund country report 25/157, the 2025 Article IV consultation, and the June 2026 selected issues paper on the shift to a floating regime; the Nigerian trade portal's import prohibition list.

Re-checked quarterly, and specifically whenever a new NAFDAC tariff or a replacement set of device regulations appears. Two items on this page are on a watch list: the draft regulations for 2025 and 2026, and whether any Nigerian instrument gives effect to the UKCA commitment. If either moves, this page moves within the week and the change is dated.

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