DMAH: Designated Marketing Authorization Holder-Summary Ver.
Why DMAH is the Best Route for Foreign Manufacturers
Foreign manufacturers have three ways to enter the Japanese market.
The killer advantage of DMAH: You retain control of your product approval while outsourcing the complex Japanese regulatory work — and you can change your sales distributor anytime without touching your approval.
What Is a DMAH?
A DMAH (Designated Marketing Authorization Holder) is a licensed Japanese company that acts as your legal representative in Japan under the Foreign Special Approval System.
- References
- "Designated Marketing Authorization Holder (DMAH), 「選任外国製造医療機器等製造販売業者」" (https://www.japaneselawtranslation.go.jp/en/laws/view/3213#je_ch5sc2at3, PMD Act, Article 23-2-17. *shown as "designated holder of marketing authorization for foreign-manufactured medical devices" )
- Foreign Manufacturer Approval https://www.pmda.go.jp/review-services/drug-reviews/foreign-mfr/0008.html
- You (the foreign manufacturer) are the Foreign Special Approval Holder — the official owner of the product approval.
- The DMAH is your in-country agent, legally responsible for:
- Filing the marketing approval / certification application
- Managing QMS quality compliance and GVP post-market safety
- Acting as the official liaison with PMDA and MHLW
- Incoming inspection, release testing, labeling, adverse-event reporting
Four Core Advantages
- No Japanese subsidiary required Skip the cost and time of establishing a company, office, and hiring the three statutory controllers ("San-yaku") required by the PMD Act.
- You keep the approval in your name Unlike the "distributor-as-MAH" model, your product license is never "held hostage" by a local partner.
- Full flexibility over sales channels Because regulatory responsibility (DMAH) and commercial distribution are decoupled, you can appoint, change, or run multiple distributors freely — without any impact on your approval.
- Faster, expert-driven market entry A specialized DMAH firm with PMDA experience handles filings, QMS audits, and FMER registration far faster than an in-house team would.
What a DMAH Does for You
A DMAH handles the full regulatory lifecycle in Japan on your behalf:
- Regulatory filings — Marketing approval and certification applications, STED preparation, QMS conformity assessment, and Foreign Manufacturer Establishment Registration (FMER)
- Quality control (QMS) — Incoming inspection, release testing, and domestic quality oversight
- Post-market safety (GVP) — Adverse event collection and reporting, recall management, and periodic safety reports
- Labeling & promotion — Package insert updates, statutory Japanese labeling, and review of promotional materials
- Authority liaison — Direct communication with PMDA, MHLW, and certification bodies