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GuidelinesImport & customs2026.10.11

Importing Medical Device Accessories and Consumables: What Does the Main Device Registration Cover?

Products used with a registered main device are not automatically within its registration. Connect function, registered configuration, separate packaging and sales, and compatibility evidence before importing replacements.

The main device's registration number is not a common number for every surrounding product. Establish which component was assessed with which model before deciding the scope for separately packaged replacements.

1. Start with function rather than commercial labels

Overseas catalogues mix accessories, spare parts and refills. These are commercial descriptions rather than Korean regulatory conclusions. Explain whether the product has an independent medical purpose, performs part of the main device's function, affects a measurement, or serves only storage and transport.

A carrying case and a measuring sensor may both appear under accessories but raise different questions. Storage protection may matter for the case, while measurement performance and patient contact matter for the sensor. These examples do not assign legal status: the actual intended use and configuration must support the device-status and registration assessment.

2. Connect three parts of the main registration

A model name on the certificate cover is insufficient. Trace the accessory through the model list, description of structure and configuration, and instructions. Where codes differ, obtain a controlled code history or cross-reference to establish identity. Changes that affect performance or intended use also need a change assessment.

Evidence Value to check Easily missed difference
Main model list Compatible main models Another series under the same brand
Components and bill of materials Code, material, specification Same appearance, different supplier or material
Verification reports Tested combination Same main unit, different sensor or cable
Instructions Connection, replacement, cleaning, reuse Sales instructions expand permitted use
Packaging and labels Model and traceable identifiers Bundle name without component identification

This table supports comparison. Completing it does not automatically exempt a component from separate registration or establish import eligibility.

3. Review separate import and separate sale

When a consumable originally supplied with the device later arrives in individual boxes, invoices, packaging, labelling and inventory controls change. Establish whether it is within the main registration or managed separately, and identify requirements for that import arrangement before preparing clearance documents. Merely describing it as an accessory on the invoice does not resolve the issue.

Disclose plans to repackage locally or combine consumables into kits from the outset. Distribution in original packaging and changes to configuration or labelling raise different questions. Use the import and customs guide for the general sequence, then assess the actual item and transaction.

4. Compatibility is more than a fitting connector

A connector that fits or a device that powers on does not establish the combination's medical performance. For sensors, review signal interpretation by the main device. For cables, consider relevant length and shielding characteristics. For patient-contact consumables, review materials and exposure duration. The product's risks determine the evaluation topics.

Ask for the compatibility list together with verification document numbers and applicable versions. For third-party components, identify who validated the combination and who supplies change information. If a consumable supplier changes specifications without informing the main manufacturer, subsequent change control and complaint investigations can have gaps.

5. Do not copy reuse and shelf-life instructions from the main device

A reusable main device may use single-use contact components. Do not copy its cleaning or disinfection instructions into the accessory instructions. Review the accessory's material, structure, specified use conditions and supporting validation. For sterile products, confirm that packaging and sterilization evidence represent the actual code and package unit.

Shelf life is also distinct from the main device's service life. Check whether the assumptions supporting the date remain valid after changes in unopened storage, restrictions after opening or repackaging. Consult the labelling guide after identifying which requirements apply to the particular accessory.

6. Complete a configuration decision table before ordering

Use one row per component code, with connected models, registration scope, verification evidence, import and sales units, and unresolved questions. Record all main devices served by a shared code. Keep unresolved components separate from confirmed orders so quantities and shipping dates are not fixed before scope is understood.

Bring the main registration, accessory catalogue and proposed invoice configuration to request an accessory import review. Clare Partners can separate product classification questions from compatibility evidence gaps.

Official references: Korean Regulation on Medical Device Approval, Notification and Review · MFDS consumer safe-use guidance. Checked 2026-09-28. Legal status and application scope require product-specific assessment. Tables and ordering workflow are practical recommendations.

Frequently asked questions

Q. Can we import replacement consumables because the main device is registered?
That alone is insufficient. Check whether the consumable is a medical device, its relationship to the main registration, any separate item treatment and the planned import arrangement.
Q. Is a manufacturer's compatibility statement enough?
A statement is different from evidence supporting safety and performance. Check interfaces, conditions of use and the model combinations actually verified.
Q. How should an accessory list be organized?
Use component codes, models, function, body contact, packaging units and connected main device models rather than only commercial bundle names or invoice descriptions.

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