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Health Sciences Authority

Import and supply of unregistered medical devices by request of qualified practitioners

The import and supply of unregistered devices at the request of a qualified practitioner for use on his patient will require approval from us.

Last updated 26 March 2026

Conditions for using this special access route (SAR)

In an emergency or when all available medical therapies fail, a doctor or dentist may request for dealers to import unregistered medical devices for his patient. Approval from HSA is needed for such scenarios.

The qualified practitioner needs to provide clinical justification that the unregistered medical devices are required to meet special clinical needs arising in the course of his practice, which includes the following:

Compassionate use

This includes:

  • Absence of alternative treatment option; or

  • Available alternative treatments failed or deemed ineffective or unsuitable for the patient according to the doctor’s or the dentist’s clinical judgement; and

  • Patient’s health will be clinically compromised without the requested treatment

Preventing out-of-stock situation

The unregistered medical device is needed to minimise disruption to the continued supply of a similar registered medical device

Novel or established medical device

  • Absence of registered alternatives or lack of a specific feature in registered medical device; or

  • Available registered medical devices or models are deemed ineffective or unsuitable for the patient according to the doctor’s or the dentist’s clinical judgement; or

  • User’s (doctor or dentist) familiarity or expertise in terms of device technology, design and/or operation that is likely to support or enhance the safety outcomes of the procedure or treatment for the patient; and

  • Patient’s health will be clinically compromised without the requested medical device

The dealer and the qualified practitioner needs to ensure that the unregistered medical device complies with other regulatory requirements such as the Radiation Protection Act governed by the National Environment Agency.

Capital equipment (e.g. X-ray machines, CT scanners, MRI machines) would not qualify for this SAR. Product registration is required for such devices.

Note: The safety and performance of the device is not assessed by us during application review.

We will consider and allow the supply of an unregistered medical device only on a case by case basis. You can only import the device after your application is approved.

Import, supply and manufacture of drug of abuse test kits needs additional controlled drug licences under the Misuse of Drugs Act besides licences under Health Products (Medical Devices) Regulations. For more information on controlled drug licence application, please contact the Licensing and Certification Branch at Email: hsa_certification@hsa.gov.sg.

You should register your medical device if you intend to supply it on a long-term basis.

Eligibility

You must have a certified quality management system e.g. to the requirements of Good Distribution Practice for Medical Devices (GDPMDS).

Documents required

You need to submit the following documents for our review: 

  1. SAR Device List (Downloadable from SHARE)

  2. Request form [PDF, 1.9 MB] for unregistered medical device for use on patients by qualified practitioner and licensed healthcare facility

  3. MOH Clinical Justification Review Form For Unregistered Class D Medical Device30 KB1

  4. Instructions for Use, Product Insert, or Operations Manual by the product owner

  5. Primary medical device label

  6. A copy of the qualified practitioner’s registration under the Medical Registration Act (Cap. 174) or Dentists Act (Cap. 76) with the Medical Council Registration (MCR) Number or Dental Council Registration (DCR) Number clearly legible

  7. A copy of quality management system certificate (e.g. Good Distribution Practice for Medical Devices (GDPMDS) if a valid Importer licence with GDPMDS is unavailable

  8. Declaration on Distribution Records (to be submitted within 30 days after expiry of authorisation) 

1 Applicable only to requests from Public Healthcare Institutions (PHIs), for these specific categories of Class D medical devices - (i) new technologies and state-of-the-art medical devices for clinical use on patients, including novel indications for exisitng medical devices or technologies; and (ii) unregistered implants

Fees and turn-around-time

Refer to medical device fees and turn-around-time for more information.

How to apply

Submit your application through SHARE. Ensure you have the following before you access the e-service:

If you encounter technical issues with SHARE (e.g. unable to upload documents), please e-mail HSA SHARE Support with the screenshot of the error message including the address bar and system time for assistance.