Same kind and unchanged manufacturer responsibility
An ARTG variation must preserve the same kind of device: sponsor, manufacturer, GMDN, class and the applicable prescribed characteristics/UPI. For manufacturer name or address changes, TGA checks whether responsibility for design, production, packaging and labelling and the QMS remain the same. A same-entity office/name update with unchanged QMS can be accepted; changed control or QMS can require a new inclusion. A sponsor transfer is a different legal event.
- Map a brand or REF to actual public and dossier-held information; do not equate a commercial order code with UPI, model or UDI.
- Retain the actual class and UPI criteria; the guidance allows selected UPI variations but does not remove the statutory same-kind test.
- Unchanged QMS alone does not establish that a different responsible legal manufacturer is the same manufacturer for the statutory kind test. If that same-manufacturer criterion is no longer met, an ARTG variation cannot be used to bypass a new inclusion.