Armenia medical device registration timeline
Source-linked clocksMinistry of Health of the Republic of Armenia (Ministry of Health) review clocks and end-to-end planning ranges, using the EAEU four-class axis (1, 2a, 2b, 3) set by EEC Board Decision No. 173 of 22 December 2015; the Armenian state-duty schedule prices classes 1, 2 and 3 with a separate line for in vitro diagnostic means classification system.
| Class / pathway | Review clock | Planning total | With prior approval | Provenance |
|---|---|---|---|---|
| Class 1 and class 2a — EAEU unified registration (reference Member State route)(EAEU unified procedure under EEC Council Decision No. 46 of 12 February 2016, with Armenia as a Member State concerned; national state registration is the alternative for a device not registered in the Union) Paragraph 50 of the Rules (Annex No. 2 to EEC Council Decision No. 46 of 12 February 2016, as restated by EEC Council Decision No. 144 of 24 December 2021): 'The authorized authority (expert organization) of the Member State concerned shall consider the expert report within 30 business days, calculated from one of the following dates: when the procedures of marketing authorization and expert examination of a medical device are carried out – from the date of receipt of a notice on payment for the approval procedures by the authorized bodies (expert organizations) of the reference Member State and the Member State(s) concerned'. Recorded in working-days, the same measure as the text's 'business days'. This replaces the earlier note on this row that no published clock had been found: the Rules do fix a clock for Armenia's own market-access decision, and paragraph 50 is it. It is the tail of the procedure rather than the whole of it — paragraphs 28, 29, 30, 31, 32, 35, 36 and 40 clock the applicant, the reference Member State and its inspecting organisation on the earlier stages. The start trigger is not the application date: the 30 business days runs from receipt of the payment notice and of the applicant's funds in the Member State concerned's account, so an unpaid approval fee stops the period. The applicant's own 60-business-day response window (paragraph 28) and 30-calendar-day payment window (paragraph 36) sit outside it. The class split matters for the duty, not for the clock: the Law on State Duty prices these devices at AMD 10,000 and AMD 20,000 respectively. | 30 working days | 6-10 months | — | Verified |
| Class 2b and class 3 — EAEU unified registration (reference Member State route)(EAEU unified procedure under EEC Council Decision No. 46 of 12 February 2016, with Armenia as a Member State concerned; national state registration is the alternative for a device not registered in the Union) Same paragraph 50 clock as the lower classes — 30 business days for the authorised authority of the Member State concerned to consider the expert report — because paragraph 50 is class-neutral. The class distinction in Chapter II operates on whether a production-facility audit is required, not on the consideration period. The class-dependent stage is the audit, which paragraph 30 puts at not more than 90 business days from the reference Member State's decision to start it, with the audit report due within 15 business days of completion (paragraph 31) and the expert report within 15 business days of the audit report (paragraph 32). All of those bind the reference Member State or its inspecting organisation, not Armenia, so a class 2b or class 3 file reaches Armenia's 30-business-day consideration later than a class 1 or class 2a file, but the consideration itself is the same period. State-duty rates for these devices are AMD 20,000 (class 2b, priced in the class 2 band) and AMD 30,000 (class 3). | 30 working days | 9-18 months | — | Verified |
| Any class — EAEU unified registration with Armenia acting as the reference Member State(Unified EAEU procedure under the Rules approved by EEC Council Decision No. 46 of 12 February 2016 as restated by Decision No. 144 of 24 December 2021, with Armenia's authorised authority (expert organisation) acting as the reference Member State: it draws up the expert report on the marketing-authorisation and expert-examination application and decides whether a production-facility audit is required.) Paragraph 29 of the Rules, Chapter II: 'The authorized authority (expert organization) of the reference Member State shall, within 45 business days from the date of its decision to start the marketing authorization and expert examination procedures in respect of the medical device, draw up an expert report in accordance with Annex 5 or, if required, makes a decision to start the audit of the production facilities ... and notify the applicant of its decision'. Recorded as a separate row because it is a different authority role with a different clock, and it must not be added to paragraph 50's 30 business days — the reference-side stage and the Member-State-concerned stage run in sequence, not in parallel. The rest of the reference-side sequence is also clocked by the Rules: audit not more than 90 business days from the decision to start it (paragraph 30); audit report within 15 business days of completion, or of the applicant's notice of nonconformity elimination (paragraph 31); expert report within 15 business days of the audit report (paragraph 32); refusal decision within 10 business days of a negative expert report (paragraph 35); placement in the information system and notice of payment within 5 business days of a positive expert report (paragraph 36); decision on registration and issue of the marketing authorisation each within 10 business days (paragraphs 40(a) and 40(b)). All of those bind the authority side, not the applicant. The realistic range adds the applicant-side gaps between the staged clocks — the 60-business-day response window under paragraph 28 and the 30-calendar-day payment round-trip under paragraph 36 — which is why the row is in months while the published clock is in days. | 45 working days | 6-12 months | — | Verified |
| Any class — import (conformity) certificate for a device already state-registered in Armenia(Ministry of Health import (conformity) certificate on the expert conclusion of the expert organisation, for a device with an Armenian or EAEU registration) Decree No. 429-Ն paragraph 19 caps the whole run from registration of the application and the required documents in the authorised body to the result at five working days for registered medical devices; paragraph 16 gives the expert organisation four working days of that for a registered device, paragraph 17 gives the authorised body one working day for the decision, and paragraph 20 allows two more working days if a paper copy of the certificate is also requested. Paragraph 19 allows the authorised body to extend the cap by up to 10 working days for clarifications on quality and safety issues; the paragraph 14 cure time is excluded. The clock is keyed to registration status, not to risk class, which is why this row and the next are not class rows. The realistic range adds the applicant's own document-preparation time, which the decree does not clock. | 5 working days | 7-15 months | — | Verified |
| Any class — import (conformity) certificate for a device without Armenian state registration(Ministry of Health import (conformity) certificate on the expert conclusion of the expert organisation, for a device that is not registered in Armenia and relies on foreign authorisation evidence) Decree No. 429-Ն paragraph 19 caps the same run at nine working days for unregistered medical devices; paragraph 16 gives the expert organisation eight working days in that case, and paragraph 17 the same single working day for the decision. Paragraph 19 allows the authorised body to extend the cap by up to 10 working days for clarifications on quality and safety issues. Paragraph 14 allows the body to stop the clock for up to seven working days to let the applicant cure a defect, and paragraph 13 spends up to three working days on the initial screening of the application — neither is included in the nine-day cap. An unregistered device must be supported by evidence of authorisation for use in the country of manufacture or in a member country of the International Medical Device Regulators Forum (Annex No. 2, paragraph 2(2)(a) of the decree). | 9 working days | 1-2.1 years | — | Verified |
Planning steps and estimates; these are not regulator deadlines.
Armenia Medical Device Registration Process
Step-by-step Ministry of Health registration process. Total estimated timeline: 6-10 months.
Step 1: Pre-Submission Preparation
1-3 monthsGather technical documentation, quality management system (QMS) records, and clinical data required by Ministry of Health. Appoint a Authorised representative of the manufacturer resident in an EAEU Member State for the registration route; for an unregistered device imported for use in Armenia, the importer or the manufacturer's official representative identified on the pack or in the instructions for use.
Step 2: Application Submission
1-2 weeksSubmit complete registration dossier to Ministry of Health including device description, risk analysis, and testing reports.
Step 3: Administrative Review
2-4 weeksMinistry of Health reviews application for completeness. May request additional documents or clarifications.
Step 4: Technical Evaluation
30 working daysIn-depth technical assessment of device safety and performance. Ministry of Health may issue questions.
Step 5: Registration Approval
1-2 weeksUpon successful review, Ministry of Health issues Armenia market authorization certificate.
- Register the device before placing it in circulation: either through the EAEU unified procedure with a reference Member State and at least one Member State concerned, or through Armenian state registration under Articles 45 and 46 of the Law on Medical Care and Services to the Population.
- Obtain a separate import (conformity) certificate from the Ministry of Health for every consignment, and do not sell, distribute, release or use the imported devices before it is issued (Decree No. 429-Ն, paragraphs 1.1 and 2).
- File the import application electronically through the National Single Window for Foreign Trade; a paper filing is accepted only if the electronic system fails (Decree No. 429-Ն, paragraphs 9 and 12).
- Present the state-duty payment receipt before the import (conformity) certificate is issued (Decree No. 429-Ն, paragraph 18).
- File an Armenian translation, certified in the prescribed manner, of any attached document that is not in Russian or English (Decree No. 429-Ն, paragraph 10).
- For an unregistered device, file evidence of authorisation for use — state registration or free circulation — in the country of manufacture or in an IMDRF member country (Decree No. 429-Ն, Annex No. 2, paragraph 2(2)(a)).
- Implement and maintain a quality-management system in line with EEC Council Decision No. 106 of 10 November 2017, as the EAEU registration Rules require of the manufacturer.
- Appoint an authorised representative of the manufacturer resident in an EAEU Member State, and keep that information current in the marketing-authorisation file.
- Check the labelling and the instructions for use against the EAEU general safety and labelling requirements before sale, including the circulation mark (EEC Council Decisions No. 26 and No. 27 of 12 February 2016), as Decree No. 429-Ն paragraphs 23 and 24 require of the importer.
- On a refusal of the import (conformity) certificate, notify the authorised body in writing within ninety days of the destruction or re-export of the refused devices (Decree No. 429-Ն, paragraph 21).
- Hold the separate use-site authorisations where the device has the relevant feature: a PSRC radio-frequency permit, legal-metrology type approval and verification, or the atomic-energy activity licence and per-source registration.
Reviewed 2026-09-16. End-to-end totals remain planning estimates.