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Across more than 2000 registrations we have supported since 2009, the pattern behind Izin Edar rejections almost always falls into the same five areas. Here is what we see most often, and how to avoid it.
- Incomplete technical dossier or wrong local format
Documentation from a manufacturer's home country, even if complete under FDA or CE standards, often gets rejected because it is not formatted the way the Ministry of Health requires. Inconsistent translations or clinical data not mapped to local requirements are the most common causes.
How to avoid it:map your technical dossier to the Ministry of Health's checklist format from the start, rather than translating raw home-country documents. - Incorrect product risk classification
Manufacturers sometimes submit a product under the wrong risk class, usually by assuming Indonesia's classification criteria match their home country's. This mistake does not just slow the process down; it can lead to outright rejection, since the required documents differ by class.
How to avoid it: confirm your product's classification with someone who understands Indonesia's Class A through D criteria before submitting. - Labeling and instructions for use not localized
Product labels still entirely in a foreign language, or instructions for use not adapted to Indonesian regulatory context, are a rejection reason that internal manufacturer teams often overlook.
How to avoid it:prepare compliant Indonesian-language labeling at the planning stage, not in the final minutes before submission. - The license-holding entity does not meet requirements
If the appointed Local Authorized Representative does not have active CDAKB certification, or has an issue with their status in the OSS RBA system, the Izin Edar application can be held up or rejected even if the product's own dossier is complete.
How to avoid it: verify your LAR's compliance status before submitting any product registration. - Insufficient clinical evidence for the product's risk class
For higher risk class products, clinical evidence sufficient for another market is not automatically considered sufficient by Ministry of Health evaluators. The evidence bar can vary depending on the claimed intended use.
How to avoid it: discuss the sufficiency of your clinical evidence with a local regulatory consultant before finalizing the dossier, not after a rejection.
What to do if your Izin Edar has already been rejected
A rejection is not the end of the process. We usually help clients review the rejection letter in detail, identify the root cause, and resubmit with targeted fixes, rather than restarting the entire process from scratch.
Conclusion
Most Izin Edar rejections are actually preventable with the right preparation upfront. What separates a smooth submission from one that gets rejected repeatedly usually is not product quality, but how well the dossier and structure were prepared before filing.
If your Izin Edar has been rejected before, or you want to make sure your first submission goes smoothly, we can help review your dossier. Reach us at info@derayglobalutama.com.
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Our Services
- License Representative
- Product Registration
- Medical Device Company Establishment Service
- Renewal and License Amendment
- Miscellaneous Certificates
- Post-Marketing Surveillance
- E- Catalogue
- Medical Device Trademark Management
- GDPMD (Good Distribution Practice for Medical Device)
- Regulatory Intelligence
- IDAK (Izin Distributor Alat Kesehatan)