The Workbench · Craft

New Zealand's WAND entry was never a device approval

This blog has already covered how Mexico lets an accredited private reviewer clear a device's file before COFEPRIS ever sees it, and how South Africa's device registration is still arriving in phases behind an establishment licence that came first. Both of those systems still have someone, eventually, checking something before a device reaches the market. New Zealand's Medsafe checks nothing. Under the Medicines Act 1981, there is no premarket approval, licence, or registration for a medical device sold in New Zealand — not a faster version of one, not a cheaper one. None.

The Act never built a gate

Medsafe administers the Medicines Act 1981 and the Medicines Regulations 1984, the pair of instruments that still govern how a medical device reaches the New Zealand market. The Medicines Amendment Act 2013 modernized the Act's own definitions of medicine, medical device, and therapeutic purpose, bringing them closer to international norms — but the amendment updated what counts as a device without adding a premarket clearance step alongside it. A product that meets the Act's definition can be supplied the moment it's notified. No application sits in front of Medsafe waiting for approval or denial.

WAND is a database, not a decision

The Medicines (Database of Medical Devices) Regulations 2003 established WAND, the Web Assisted Notification of Devices — the system importers, exporters, and local manufacturers use to notify New Zealand's Director-General of Health of the devices they supply. The sponsor, the New Zealand-based entity legally answerable for the device, lists it in WAND within 30 days of taking on that role, at no fee, and has to correct or remove outdated information within 10 working days after it changes. What WAND doesn't do is evaluate the listing: no file is reviewed for merit, no certificate is issued, nothing is rejected on its own contents. Medsafe's own guidance says plainly that a WAND entry isn't evidence of approval, and warns sponsors against promotional language that implies otherwise.

Overseas evidence sits behind the notification, not in front of it

Most sponsors still hold a CE mark, an FDA clearance, or a TGA inclusion behind the device they notify — not because WAND requires it, but because Medsafe can ask a sponsor to produce documentation proving a device's safety and effectiveness after the fact, and a sponsor with nothing to show is exposed the moment that request lands. That's a structurally different position from a system that makes the overseas credential a precondition of the filing itself: in New Zealand, the foreign approval is evidence held in reserve, not a gate the notification has to clear before it's accepted.

The enforcement sits entirely on the back end

Removing a premarket gate doesn't remove oversight; it moves all of it downstream. Medsafe runs an active post-market monitoring program, and a device that turns out not to perform safely against its own stated purpose can still be recalled from the New Zealand market, however uneventfully it was notified going in. The discipline the WAND system carries lives almost entirely in adverse-event reporting and recall response, because there's no earlier point left in the process to catch a problem before it reaches a patient.

Where this meets the file

A cross-border registration tracker that stores a flat “approved” status for New Zealand has recorded an event that never happened. The field that belongs there is “notified,” carrying the WAND date the sponsor's own 30-day clock ran against, tracked separately from whichever overseas approval the sponsor is actually holding in reserve to answer a Medsafe evidence request if one arrives. A device-registration tracker built around that distinction, alongside the launch catalog's other cross-border templates, is previewed there now. If your program has recorded New Zealand's notification differently, the shelf takes that correction directly.

The Regulatory Toolkit launches soon — a free shelf of source-mapped templates, checklists and browser-only tools for regulatory teams. Get one email when it opens, or contribute a template.

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