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Malaysia MDA Distribution Records Guide (2nd Edition): Consultation Draft Extends Traceability to Patients

Nov 6, 2026 Regulatory Info 0 views

The Malaysian Medical Device Authority (MDA) has released the second edition of its Guidance Document on Distribution Records (MDA/GD/0012) for public consultation.

This revision updates the first edition issued in 2020, focusing on the scope of distribution records, product identification, storage and delivery records, record retention periods, traceability of implantable medical devices, and the allocation of responsibilities among manufacturers, authorised representatives, importers and distributors.

Notable changes include further refinement of distribution record requirements, new installation, configuration and delivery record requirements for SaMD, and an extension of implantable medical device traceability down to the patient level.

Official source: https://portal.mda.gov.my/index.php/announcement/1874-announcement-public-comment-second-edition-guidance-document-distribution-records

1. Key facts about the document

ItemDetails
Issuing authorityMalaysian Medical Device Authority (MDA)
Document titleDistribution Records
Document numberMDA/GD/0012
EditionSecond Edition
Document dateOctober 2026
First edition dateJune 2020
Document statusDraft for public consultation
Consultation period3-18 November 2026

This guidance should be read together with the following Malaysian regulations currently in force:

RegulationReference number
Medical Device Act 2012Act 737
Medical Device Regulations 2012–
Medical Device (Duties and Obligations of Establishments) Regulations 2019–

2. Main revisions in the second edition

According to the revision history, the second edition makes comprehensive adjustments to the original chapters, as summarised below:

Revised sectionKey changes in the second edition
1. IntroductionAdds explanations of risks in the distribution phase, Good Distribution Practice for Medical Devices (GDPMD), and prevention of non-conforming and counterfeit medical devices from entering the supply chain
2. ScopeClarifies that distribution records must be established, maintained and retained for all medical devices placed on the market
3. Terms and definitionsAdds definitions of distributor, establishment, field corrective action (FCA), implantable medical device, UDI and licence holder
4. General requirementsFurther clarifies requirements for distribution records, supply chain traceability and record control
4.1 Content of distribution recordsDetails requirements for product identification, receipt, delivery, SaMD, product disposition and supporting documents
4.2 Record maintenanceClarifies requirements for record review, updating, identifiability and retrieval
4.3 Record retentionSpecifies retention periods for distribution records and aligns them with the 2019 establishment duties regulations
4.4 Record controlAdds requirements for record security, integrity, retention and provision to the regulatory authority
4.5 Implantable device traceabilityFurther clarifies requirements for traceability to healthcare facilities and to the patient level
5. Establishment responsibilitiesAdds responsibilities for establishing and implementing distribution record systems across all types of establishments in the supply chain
Appendix ANew minimum content checklist for distribution records

The core of this revision is to further clarify record management requirements for medical devices as they move through the supply chain, and the responsibilities of each participant in that chain.

3. Scope: covering the entire medical device supply chain

The second edition makes clear that the guidance applies to all medical devices placed on the Malaysian market.

EstablishmentEnglish nameMain activities involved
ManufacturerManufacturerProduct supply and distribution management
Authorised representativeAuthorised Representative (AR)Supply chain product information and related management
ImporterImporterImport, storage and delivery of medical devices
DistributorDistributorStorage, sale and delivery of medical devices

Establishments need to establish a record management mechanism covering the entire distribution process:

Distribution stageMain records
Product receiptQuantity received, source and related documentation
Product storageWarehouse information, storage conditions
Product deliveryDispatch date, customer information, quantity delivered
Final supplyThe location where the product is finally supplied for use by the patient or user
Product dispositionDisposition records for expired, damaged or recalled products

The guidance requires distribution records to support tracing of products from the manufacturer or authorised representative to the end user, and to support field corrective actions (FCA) or product recalls where necessary.

4. Further detail on distribution record content

This is one of the most important revisions in the second edition.

Under Section 4.1 and Appendix A, the distribution records establishments need to maintain mainly cover the following:

4.1 Customer and warehouse information

Record categorySpecific requirements
Consignee informationConsignee name, address, contact telephone number and email address
Storage facility informationWarehouse name, address, contact telephone number and email address (where applicable)
Final place of useThe location where the medical device is finally supplied for use by the patient or user

It is particularly important to note that warehouses used by importers and distributors before delivering products to customers must also be brought within the relevant record management.

4.2 Medical device product information

Record itemSpecific requirements
Medical device nameProduct name
Brand nameTrade name or brand name
UDIRecord the UDI where applicable
Product quantityQuantity received and quantity distributed
Product categoryMedical device classification information
MDA registration informationRegistration number and validity period of the registration
Model or version numberRequired for products without a UDI
Lot number or batch numberRecorded for products without a UDI where applicable

For medical devices without a UDI, product traceability must still be achieved through model, version number and lot or batch information.

In addition, the guidance clarifies the UDI: ‘unique’ in UDI does not mean that every individually produced unit must be serialised.

4.3 Software as a Medical Device (SaMD) records

The second edition further clarifies the distribution record requirements for Software as a Medical Device (SaMD).

Record itemSpecific requirements
Installation managementInstallation information
Configuration managementSoftware configuration management information
Product identificationSaMD identification information
Delivery methodHow the product is delivered
Target usersThe intended user group for the product

This means that SaMD distribution records need to cover not only product delivery but also information relating to installation, configuration and delivery.

4.4 Delivery and receipt records

Record categorySpecific requirements
Dispatch dateDate the product was dispatched or delivered
Purchase orderPO number
Delivery orderDO number
Customer informationCustomer details such as healthcare facility, distributor or retailer
Customer contact detailsMost up-to-date customer contact information
Quantity deliveredQuantity actually delivered
Receipt dateDate the consignee received the product
Quantity receivedQuantity actually received
RemarksRemarks relating to delivery or receipt (where applicable)

These records should be capable of being matched against transport and delivery documentation.

4.5 Product disposition records

Record itemSpecific requirements
Whether disposedYes/No
Reason for dispositionFor example, product expired, damaged, etc.
Date of dispositionActual date of disposition
Method of dispositionHow the product was disposed of

For medical devices with a short shelf life, the guidance recommends that establishments consider the additional disposition situations that product expiry may cause.

4.6 Supporting documents

Document typeSpecific content
InvoicesInvoices relating to product receipt and supply
Purchase documentsPurchase orders
Sales documentsSales orders
Supply chain listList of establishments in the supply chain
Product supply informationThe relevant medical devices supplied by each establishment
Authorisation documentsLetter of Authorisation (LoA)
Other documentsOther supporting materials required by the MDA

5. Further clarity on record maintenance and retention periods

The second edition further details how establishments must maintain, update and retain distribution records.

5.1 Record maintenance requirements

Management itemSpecific requirements
Record verificationVerify the adequacy of records
Record updatingUpdate records promptly as circumstances change
Change managementMake it possible to identify what was changed after any modification
Record legibilityKeep records clear and identifiable
Record retrievalEnsure records can be retrieved without delay
Obsolete recordsPrevent obsolete records from being used in error and mark them appropriately when retained

Establishments need documented procedures for distribution record management to ensure these requirements are implemented.

5.2 Retention periods for distribution records

Section 4.3 of the second edition specifies the retention periods for distribution records:

Product situationRetention period
Medical devices supplied on the Malaysian market2 years from the date of supply of the product
Exported medical devices2 years from the date the product is shipped out of Malaysia
Medical devices with an expected lifetimeRetain for the expected lifetime determined by the manufacturer

For medical devices with an expected lifetime, records should be retained for the longer of the applicable periods.

For example, if a medical device has an expected lifetime of 5 years, its distribution records should be kept for 5 years, not just 2 years.

5.3 Regulatory access and record control

Management requirementSpecific content
Regulatory accessEstablishments must provide distribution records when requested by the MDA
Record securityEstablish controls for record security and integrity
Record retentionDefine retention periods for records
Record retrievalEnsure records can be accessed without delay
Record dispositionEstablish procedures for record disposition
CAB auditsCABs may inspect or audit the distribution records maintained by establishments

6. Implantable medical devices: traceability extended to the patient level

This is a revision that deserves particular attention in the second edition.

Section 4.5 of the second edition makes clear that, in addition to meeting the general distribution record requirements, implantable medical devices require the following additional information:

Record categorySpecific requirements
Healthcare facility informationThe healthcare facility where the implantation procedure was performed
Surgical departmentThe specific department where the implantation procedure was performed
Patient informationInformation on the patient in whom the medical device was implanted or who uses the device
Date of implantationThe actual date the medical device was implanted
Explant informationInformation relating to removal of the medical device
Date of permanent explantThe date the medical device was permanently removed from the patient (where applicable)

At the same time, establishments must ensure that the distribution and traceability records for implantable medical devices are accurate and complete, and can be retrieved without delay.

Traceability requirements in different scenarios:

Party or scenarioTraceability requirement
Routine record management by establishmentsEnsure traceability down to the patient level
CAB assessmentAssess whether the establishment’s traceability system can trace to the healthcare facility level
MDA regulatory inspectionProvide the relevant traceability records as required
Post-market event investigationProvide patient-level information
Field corrective action (FCA)Support patient-level traceability
Product recallSupport patient-level traceability

This means that, for implantable medical devices, merely recording which hospital a product was sold to may not be sufficient to meet the traceability requirements set out in the second edition.

7. Further clarity on the responsibilities of manufacturers, ARs, importers and distributors

Section 5 of the second edition sets out the responsibilities of the different parties in the supply chain in Table 1.

ResponsibilityManufacturerARImporterDistributor
Product registrationResponsible for registering medical devices with the MDA–––
Product import––Import only registered or explicitly exempted medical devices–
Product distribution–––Distribute only registered or explicitly exempted medical devices
Storage and transport requirementsEstablish the relevant requirementsCommunicate the manufacturer’s requirements to importers and distributorsComply with the manufacturer’s requirementsComply with the manufacturer’s requirements
Product traceabilityParticipate in and support the establishment of traceability mechanismsParticipate in and support the establishment of traceability mechanismsParticipate in and support the establishment of traceability mechanismsParticipate in and support the establishment of traceability mechanisms
Complaint investigationObtain relevant information and support the investigationCooperate with the relevant investigationProvide distribution records to the manufacturer or ARProvide distribution records to the manufacturer or AR

In addition, all establishments in the supply chain must implement the following:

Shared responsibilitySpecific requirements
Supply chain traceabilityEstablish traceability measures from the manufacturer or AR and importer through to customers and patients
Information cooperationCooperate with other establishments in the supply chain to maintain product traceability
Provision of recordsWithin the applicable retention period, be able to provide the MDA with information on product supply and consignees
Product identificationRecord the date of activity, product name, supplier and customer information
Lot managementRecord product serial numbers or lot numbers and expiry dates
Complaint investigationCooperate with the manufacturer or AR in complaint investigations and other post-market activities

For complaint investigations, manufacturers should obtain the necessary information from importers, distributors, healthcare facilities or other relevant parties; importers and distributors in turn need to provide the corresponding distribution records to the manufacturer or AR to support post-market surveillance activities.

8. Regulatory consequences of failing to maintain distribution records

Regulatory matterSpecific requirement
MDA regulatory powersThe MDA has the power to require establishments to provide distribution records
CAB auditsCABs may inspect or audit the distribution records maintained by establishments
Non-complianceFailure to maintain distribution records as required under Section 37 of Act 737 may constitute an offence
Basis for enforcementMedical Device (Compounding of Offences) Regulations 2024

Distribution records are not merely internal warehouse and sales management materials; they are also a key basis for regulatory inspections, complaint investigations, field corrective actions and product recalls.

9. Implications and recommendations for medical device companies

In light of this revision, companies that already hold Malaysian registrations or are doing business in the Malaysian market should focus on reviewing the following:

Company concernedRecommended focus areas
Medical device manufacturers in ChinaEstablish records of product lot numbers, dispatch, customers and sales, and ensure they can provide the relevant distribution information to their Malaysian AR
Malaysian ARsClarify the information transfer mechanisms with manufacturers, importers and distributors
Malaysian importersStrengthen records of import documentation, product receipt, warehousing and downstream delivery
Malaysian distributorsEstablish customer files, sales records, product lot records and final delivery records
Implantable device companiesEstablish a traceability mechanism covering healthcare facility, surgical department, patient and implantation date information
SaMD companiesStrengthen records of software version identification, installation and configuration, and product delivery

For manufacturers in China working with third-party ARs, importers or distributors in Malaysia, it is advisable to clarify each party’s record retention and information provision responsibilities in advance, to avoid gaps in traceability information as products move through the supply chain.

10. Consultation arrangements

The second edition of the Distribution Records guidance is currently open for public consultation.

ItemDetails
Consultation start date3 November 2026
Consultation deadline18 November 2026
Submission emailguidancedocument@mda.gov.my
Submission methodUsing the Public Comment Form provided by the MDA

Industry stakeholders wishing to submit comments may do so within the specified period using the feedback form provided by the MDA.

Conclusion

The MDA’s revision of the Distribution Records guidance further clarifies the record management requirements for medical devices circulating in the Malaysian market.

From product identification, UDI and lot number management, through warehousing, delivery and record retention, to patient-level traceability for implantable medical devices, the second edition places greater emphasis on the completeness and traceability of information across the entire supply chain.

For medical device companies already in the Malaysian market, attention should go beyond product registration and certificate maintenance to post-market distribution record management, with mechanisms for information management with local ARs, importers and distributors put in place early.

Note: This article is based on the second edition of the ‘Distribution Records’ guidance document published for public consultation by the Malaysian Medical Device Authority (MDA) in October 2026. The document is currently a consultation draft, and the final requirements are subject to the official version subsequently published by the MDA.

Grzan

Author:Grzan

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