Medical devices · SAHPRA

There is no product registration

South Africa is the only market on this site where you cannot register your device, because the regulator has not started registering devices. What exists instead is an establishment licence — and it is issued in the name of one named individual who must live in South Africa.

Product registration REGULATION 8 · NOT COMMENCED UK manufacturer no standing of its own Authorised Representative a natural person, not a company resident in South Africa Establishment licence issued in their name Nothing may be manufactured, imported, distributed or sold without it.
Everywhere else the asset you create is a product authorisation. Here it is a licence in somebody's name, and that somebody is a person rather than a company.
Nonedevice product registrations — the scheme has not commenced
1named individual holds the licence, and must live there
6jurisdictions SAHPRA recognises for devices. The UK is not one
R26,200manufacturer licence, new application
The thing nobody tells you first

You cannot register a device in South Africa

SAHPRA said so itself, in September 2025.

In a communication to industry the regulator states that it "has not commenced with product registration of medical devices and IVDs as per regulation 8", and that anyone intending to import, manufacture or market such a product "shall apply to the Authority for a medical device establishment licence". Its own devices page puts it more plainly still: "The registration process for medical devices is still in development."

The regulations that would create registration were gazetted in December 2016. Regulation 8 provides for it. But registration only bites when SAHPRA issues a call-up notice, and none has been gazetted. A call-up plan was published in 2018 proposing phases from July 2018 to June 2020; those dates have passed without the declaration that would have triggered them.

What has happened since is a voluntary feasibility study, opened in May 2024 and limited to Class C and D devices used against HIV and tuberculosis — with no fee and, expressly, no certificate of registration issued. Its report was published on 31 March 2026. We could not read it: SAHPRA has moved its 2026 documents to a host that refuses automated access, and we are not going to summarise a document we have not opened.

Why this matters commercially, and not just as trivia. Half the market-access industry sells "SAHPRA registration" for medical devices. There is no such thing to sell. What there is, is an establishment licence held by your South African partner — which means the money and the attention belong on who holds it, not on a dossier.

Structure

The licence belongs to a person, not a company

The 2016 regulations define the Authorised Representative as "a natural person, resident in the Republic of South Africa, who has the written mandate to represent a manufacturer, importer, distributor, wholesaler, retailer or service provider". SAHPRA's guidance sharpens it: that individual is the person "in whose name the manufacturer Licence, distributor licence, wholesaler licence and or certificate of registration is issued".

Read that twice if you have entered the other five markets on this site. In Saudi Arabia the licence sits with a licensed company. In the UAE, with a licensed establishment. In Egypt, with one of three corporate applicant types. In Nigeria, with a company holding your power of attorney. In South Africa it sits with a human being, who can resign, emigrate, fall out with your distributor, or be poached by your competitor.

The representative is responsible for all aspects of the device — performance, quality, safety and compliance. SAHPRA publishes no minimum qualification for the role: it requires a curriculum vitae and expresses the standard functionally, as knowledge sufficient to ensure the correct procedures are followed through importation, transport, storage, distribution, marketing and sale.

How we would handle it. Name the individual in your distribution agreement, agree in writing what happens if they leave, and know in advance who the replacement would be. This is the cheapest clause you will ever negotiate and the most expensive one to be without.

The question everyone asks first

Does your CE, UKCA or FDA approval help?

CE does. UKCA does not. And the reason is precise enough to be worth stating carefully, because it is exactly the kind of detail a provider working from memory will get wrong.

Recognised for medicines

SAHPRA reliance guideline · v5 · 6 August 2025
  • European Union, centralised and decentralised
  • Health Canada
  • MHRA, United Kingdom
  • Japan
  • Swissmedic
  • TGA, Australia
  • US FDA

Scope is expressly human medicines, biologicals, veterinary medicines and variations. Devices are not in it.

Recognised for devices

SAHPRA licensing guideline MD-07 · v4 · 21 May 2025
  • Australia
  • Brazil
  • Canada
  • European Union
  • Japan
  • United States
  • The United Kingdom is absent

The licence application wants evidence of pre-market approval from at least one of those six. UKCA is named nowhere in any SAHPRA device document we read.

So the MHRA is a recognised regulator in South Africa — for medicines. For devices the list is a different list, it is shorter, and Britain is not on it. A UK manufacturer routes its evidence through an EU MDR or IVDR certificate, or through approval in one of the other five.

One open question, and it is the important one.

SAHPRA published a Medical Devices Reliance Guideline — document SAHPGL-MD-22, version 1, dated 25 February 2026. We have its number, version and date from SAHPRA's own index. We could not read it. SAHPRA has migrated its 2026 documents to a host that blocks automated retrieval, and every 2026 guideline, form and communication is in the same position.

That guideline is where the device recognition list could have been aligned with the medicines list — which would put the MHRA on it. Until somebody opens the document, the honest answer is that we do not know, and we would obtain it from SAHPRA directly before advising you to rely on either outcome.

The route

Five steps, and none of them is a dossier

  1. 01

    Classify the device

    Classes A to D, on rules built from the international harmonisation model. You classify; SAHPRA arbitrates where the rules are disputed. Class A is currently exempt from establishment licensing altogether by gazetted exemption — a genuine and unusual relief, though its conditions and duration are in a scanned notice we could not read in full.

    You, with us
  2. 02

    Choose the licence, and the person

    Three licences: manufacturer, distributor, wholesaler. A manufacturer licence covers manufacture, import, distribution and export. A distributor licence covers import, export and distribution. A wholesaler licence covers neither import nor export — a distinction that catches people who assume "wholesaler" is the safe generic choice.

    Us, with you
  3. 03

    Assemble the pack

    Covering letter, the application form in both spreadsheet and PDF, the representative's curriculum vitae, a quality manual for manufacturers and distributors or a site master file for wholesalers, proof of payment, the product list with international nomenclature codes, and evidence of pre-market approval from one of the six recognised jurisdictions.

    You, assembled by us
  4. 04

    Submit by email, and answer fast

    Applications go to SAHPRA electronically. Deficiencies come back as an observation letter with ten working days to respond, and a maximum of two cycles. Miss the second and the application ends — you start again, and pay again.

    Representative, managed by us
  5. 05

    Hold it, renew it, and do not lapse

    Five years, conditional on the annual retention fee each June. The regulation requires renewal at least 180 days before expiry; SAHPRA's own guidance says 90. A licence allowed to lapse is not renewed — you apply for a new one.

    Shared — we run the calendar

If your device emits radiation, there is a second regulator inside the same building. X-ray equipment, linear accelerators, MRI and Class 3B and 4 lasers are licensed separately under the Hazardous Substances Act of 1973, by SAHPRA's own Radiation Control unit, on their own forms. SAHPRA's guidance on importing new X-ray equipment says in terms: refer also to the Medical Devices unit. Both regimes apply, and they do not share an application.

Time and money

Published in rand, and two documents give two deadlines

Fees are set by ministerial regulation rather than by the regulator, gazetted in February 2025 and effective the day after. SAHPRA republishes the device figures in its own licensing guidance, which is where these come from.

ItemFee, ZAR
Manufacturer licence — new application26,200
Distributor licence — new application15,600
Wholesaler licence — new application15,600
Manufacturer licence — renewal22,900
Distributor or wholesaler licence — renewal13,100
Amendment application5,500
Licence issuing3,500
Annual retention, every June4,400
Certificate of free sale, issued by SAHPRA1,460
Notification, such as a product-list update0

From SAHPRA's licensing guidance version 4, dated 21 May 2025, which reproduces the schedule gazetted on 12 February 2025 and effective from 13 February 2025. The gazette itself is a scanned image without a text layer, so we cite SAHPRA's own restatement rather than claim to have read the annexure. There is no product registration fee, because there is no registration. Radiation licence fees are not published; a draft fee instrument for that regime went out for comment in August 2026.

180 days or 90? The regulation and the regulator disagree.

The General Regulations require a renewal application at least 180 days before expiry. SAHPRA's own licensing guidance and its published questions and answers both say 90 days, and warn that a late application is not accepted at all — you must apply for a new licence. We would work to 180 and treat 90 as the administrative floor, because the cost of being wrong is a lapsed licence rather than a late one.

On turnaround, the same split. The guidance promises six to eight weeks. The performance target SAHPRA is actually held to, and reports against to Parliament, is eighty per cent of device establishment licence applications finalised within ninety working days. Budget the second number.

The moving requirement

ISO 13485 is becoming compulsory, in stages, to 2028

SAHPRA is phasing in a requirement that establishment licence holders hold ISO 13485:2016 certification from a conformity assessment body that SAHPRA itself recognises. From 1 June 2025 it has been required with renewals. SAHPRA aims to have verified every licence-holder's certificate by 1 April 2028.

Two consequences for a UK manufacturer, and the second is not obvious.

  • The certificate has to come from the right body. SAHPRA publishes a list of recognised conformity assessment bodies. We could not read the current roster — the page would not render for us — so whether any UK body is on it is unverified, and that is worth establishing before you assume your existing certificate transfers.
  • SAHPRA joined the Medical Device Single Audit Programme as an affiliate member in April 2025, saying it expects this to improve its ability to monitor manufacturing beyond South Africa's borders and potentially to speed up review. If you already hold an MDSAP certificate, say so early — it is the kind of thing that is worth more here than it was two years ago.

There is no unique device identification requirement in South Africa, and no device labelling guideline beyond the essential principles, which require information in English and permit any other South African language. A dedicated post-market surveillance and clinical follow-up guideline appeared for the first time in September 2025.

Honest gaps

What we could not confirm

More than on any other page here, and for one reason: during 2026 SAHPRA moved its document library to a host that refuses automated access. We have the index — titles, document numbers, versions and dates — for everything below. We do not have the text.

  • The device reliance guideline

    SAHPGL-MD-22, version 1, 25 February 2026. Whether it adds the MHRA to the device recognition list is the single most important open question for a UK manufacturer on this page.

  • The recognised conformity assessment bodies

    The roster would not render. Whether a UK body can issue the ISO 13485 certificate SAHPRA will accept is unverified, and the phase-in makes it material.

  • The registration feasibility report

    Published 31 March 2026. It is the nearest thing to a roadmap for whether and when device registration begins.

  • The exemption notices

    Both February 2025 gazettes are scanned images without a text layer. We can confirm the Class A exemption exists; we cannot state its conditions or whether it expires.

  • The fee annexure itself

    Same problem. Our figures come from SAHPRA's restatement of the schedule, not from the gazette.

  • Radiation licence fees

    Not published anywhere we could find. A draft instrument for that regime was out for comment in August 2026.

The question a board will ask

Getting paid, and getting into a tender

Two answers that are better than the reputation suggests, and one that is a diligence burden rather than a barrier.

Payment. South Africa operates exchange control through authorised dealer banks, and it does not stand between you and a bona fide payment for imported goods. The practical trap is documentary: an advance payment above R100,000 requires the bank to see the customs declaration within four months, confirming the goods actually arrived. Write your contract so your South African buyer can produce it.

Local content. Medical devices are not a designated sector with a minimum local content threshold — pharmaceuticals are, devices are not. But since January 2023 the national schedule no longer sets those goals: each buying entity sets its own specific goals in its own procurement policy. So the question moved from one national rule to every individual tender document. The Public Procurement Act of 2024 is enacted but not commenced, and its draft regulations were still out for comment in mid-2026.

Used equipment. If you are shipping refurbished or second-hand devices, an import permit is required — the control exists specifically to stop poor-quality used medical equipment, and used X-ray machines are named as the example. New devices are not generally subject to it.

On national health insurance, which will come up if your buyer is public sector: the Act was signed in May 2024, government agreed in February 2026 to delay proclamation of sections of it pending a Constitutional Court ruling, and no judgment had been delivered when we checked. Nothing official has been published about its effect on device procurement. Be careful with press coverage here — a Constitutional Court judgment of May 2026 that was widely reported as "the NHI judgment" in fact concerned certificates of need under a different Act.

Our role

What we do here, and what we do not

We do

  • Find and vet the individual who will hold the licence, and contract for what happens when they leave
  • Establish with SAHPRA whether your ISO 13485 certificate comes from a body it recognises
  • Choose the right licence — the wholesaler licence cannot import, and that catches people
  • Run the two observation-letter cycles inside ten working days each, because there is no third
  • Hold the calendar: retention every June, renewal at 180 days, not 90

We do not

  • Sell you a "SAHPRA device registration". It does not exist and anyone offering one is not reading the regulator
  • Act as your authorised representative — that must be a natural person resident in South Africa
  • Assert that UKCA is accepted. It is named in no SAHPRA device document we could read
  • Summarise the 2026 guidelines we have not been able to open
  • Promise a date. The published target is ninety working days for eight files in ten
Before we start

What we will ask you for

  • Device description, intended purpose and variants in scope
  • Your class under the A to D rules, and your rationale
  • Whether the device emits ionising or non-ionising radiation
  • Your EU MDR or IVDR certificate, or approval from Australia, Brazil, Canada, Japan or the United States
  • ISO 13485 certificate — and which body issued it
  • Whether you hold an MDSAP certificate
  • Your quality manual, or a site master file if the partner is a wholesaler
  • Product list with international nomenclature codes
  • Who your intended South African partner is, and who inside it would be the representative
  • Whether that individual already holds licences for other manufacturers
  • Whether you are selling into public tenders, and which

The second-to-last question is the one nobody asks. An individual who already represents four other manufacturers is not necessarily wrong for you — but you should know it before you depend on them, not after.

Moving parts

What changed, and what still has not

  1. May 2024A voluntary registration feasibility study opens for Class C and D devices used against HIV and tuberculosis — no fee, and expressly no certificate issued
  2. Feb 2025New fee regulation gazetted, effective the following day; Class A establishments exempted from licensing by separate notice
  3. Apr 2025SAHPRA joins the Medical Device Single Audit Programme as an affiliate member
  4. Sep 2025First dedicated guideline on post-market surveillance and post-market clinical follow-up; ISO 13485 phase-in confirmed through to 2028
  5. Feb 2026A medical devices reliance guideline is published — and moved, with everything else from 2026, to a host we cannot read
  6. Still nothingNo call-up notice for device registration has been gazetted. Ten years after the regulations, the scheme they provide for has not started

The other half of this market

Do you also make medicines?

The answer inverts entirely. For medicines SAHPRA names the MHRA as a recognised regulatory authority, accepts a UK GMP certificate on the papers, and runs a registration system the UK government records as having cleared its backlog. The barrier moves downstream to price: one single exit price, set once, moved only by the Minister's annual percentage.

The medicines page for South Africa →

Find the person before you find the distributor

Everything about this market turns on who holds the licence, and the answer is a named human being. Send us the device and we will tell you what to ask of them, and what to write into the agreement.

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

Checked against SAHPRA, the Government Gazette,
SARB and WHO · 11 September 2026

Sources

  1. Regulations relating to Medical Devices and IVDs — Government Notice R.1515, Government Gazette 40480, 9 December 2016, under the Medicines and Related Substances Act 101 of 1965. Regulation 1 for the definition of the Authorised Representative, regulation 5 for licensing, regulation 8 for registration, regulation 11 for classification.
  2. SAHPRA communication MD08-2025/2026, September 2025 — the statement that product registration has not commenced. And SAHPRA's medical devices page: "the registration process for medical devices is still in development".
  3. SAHPGL-MD-07, version 4, 21 May 2025 — licence types and what each permits, the fee figures, the ninety-day guidance, the list of six recognised jurisdictions, and the requirement for the representative's curriculum vitae.
  4. SAHPGL-MD-06 version 3 and SAHPGL-MD-04 version 5 — licence applications and classification. SAHPGL-MD-18 version 1, 9 September 2025 — post-market surveillance and clinical follow-up.
  5. SAHPGL-MD-22, Medical Devices Reliance Guideline, version 1, 25 February 2026 — cited by number, version and date only. We have not read it.
  6. General Regulations to Act 101 of 1965, regulation 24 — five-year validity and the 180-day renewal requirement.
  7. Regulations regarding fees payable — Government Notice 5856, Government Gazette 52106, 12 February 2025, effective 13 February 2025. Government Notice 5855, Gazette 52105 — the Class A exemption.
  8. SAHPRA communication MD01-2025/2026 version 2, 18 September 2025 — the ISO 13485 phase-in. SAHPRA media release, 4 April 2025 — affiliate membership of the Medical Device Single Audit Programme.
  9. SAHPRA annual report presentation to the Portfolio Committee on Health, October 2025 — the ninety working day performance target. Hazardous Substances Act 15 of 1973 and its regulations — the separate radiation regime.
  10. South African Reserve Bank currency and exchanges manual for authorised dealers — payment for imports and the four-month rule on advances. National Treasury preferential procurement regulations 2022 and the draft public procurement regulations 2026. the dtic designated sectors list. WHO list of national regulatory authorities at maturity levels 3 and 4, August 2026 — SAHPRA's designation is for vaccines.

This page carries more unread documents than any other on the site, and they are listed rather than glossed. The cause is a hosting change at SAHPRA during 2026 which blocks automated retrieval; the remedy is to request the documents directly, which is what we do for a client engagement. Re-checked quarterly, and immediately if a call-up notice for device registration is gazetted — which would change this page more than any other event we are watching.

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