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Guidance briefChina

Hainan Issued a Trial Guideline on Lecheng Real-World Data for Product Registration in 2026

Hainan’s provincial medical products regulator has issued a trial guideline on using real-world data generated in the Boao Lecheng pilot zone to support registration of imported drugs and medical devices with the national regulator. It affects overseas manufacturers seeking NMPA approval through the Lecheng pathway. Secondary sources report that it was issued on 29 April 2026.

Pubrica InsightsWritten by the regulatory and market access teams Published9 November 2026 Last checked9 November 2026 Reading time5 minutes Sources6
  • Issued 29 April 2026 (reported)
  • Trial guideline
  • Imported drugs and devices
  • Supplementary evidence
  • Cross-border data limits

In force China

Instrument
Trial guideline on the use of Boao Lecheng pilot zone real-world data to support registration of imported drugs and medical devices
Issued by
Hainan Provincial Medical Products Administration (Hainan MPA)
Date
Reported as issued 29 April 2026
Applies to
Overseas-approved drugs and medical devices used in the Boao Lecheng International Medical Tourism Pilot Zone whose sponsors intend to use the resulting data in NMPA registration applications
What you must do
Design and conduct Lecheng real-world studies in line with the guideline and national real-world evidence guidance, and comply with Chinese data protection and cross-border data transfer requirements
Not covered
The guideline does not by itself guarantee NMPA acceptance; Lecheng data are generally described as supplementary to overseas evidence
Primary source
Hainan MPA Issues Trial Lecheng Real-World Data Guideline for Imported Drug and Medical Device Registration
Cisema (secondary report of Hainan MPA guideline), 2026 · read 9 November 2026

Read the Official Document

What the Guideline Covers

The Hainan Provincial Medical Products Administration (Hainan MPA) has issued a trial guideline on the use of real-world data (RWD) generated in the Boao Lecheng International Medical Tourism Pilot Zone to support registration of imported drugs and medical devices. Secondary reporting gives the issue date as 29 April 2026; one report is dated June 2026, but the April date is the better supported. The guideline aims to standardise how clinical RWD collected in the zone is used in applications to the National Medical Products Administration (NMPA).

Commentators describe the guideline as the most operationally detailed framework so far for designing and submitting Lecheng real-world studies. One secondary source reports that it sets out a five-stage framework for using Lecheng-generated real-world evidence as supplementary evidence in NMPA registration applications. The full Chinese text was not available for review for this brief, so readers should consult the original document from the Hainan MPA for the detailed requirements.

How the Lecheng Pathway Works

The Boao Lecheng pilot zone is the only region in China where drugs and medical devices approved overseas but not yet registered with the NMPA can be used in clinical practice. Once a product is approved for use in the zone, and with the consent of the Hainan MPA and the NMPA, real-world data on patients treated there can be collected and used as supplementary evidence in an NMPA registration application. Most products approved through this route have relied mainly on existing overseas data, supplemented by data from Chinese patients treated in Lecheng.

Reported results vary by source and date. One secondary source states that, as of January 2026, 47 licensed medical products had entered the programme, with the resulting evidence contributing to regulatory approvals for 22 products, 16 medical devices and six drugs. A later trade article reports Hainan figures of 27 drug and device products that had gained accelerated approval with support from Lecheng real-world evidence. These figures come from secondary reporting and could not be checked against official statistics for this brief.

The National Framework behind It

The Lecheng guideline operates within a national framework for real-world evidence. The NMPA published its trial guidelines on real-world evidence supporting drug development and review on 7 January 2020. The Center for Drug Evaluation (CDE) has since issued further guidance, including a trial guideline on the design and protocol of real-world studies and a guideline on communication about registration applications supported by real-world evidence, released on 16 February 2023. A review by CDE authors describes how the core guidelines were later extended to areas such as oncology, rare diseases, paediatric medicines and traditional Chinese medicine.

On 26 January 2026, the NMPA issued Announcement No. 16 of 2026, confirming that it will apply ICH guideline M14 on non-interventional safety studies using RWD. Commentators note that M14 is a methods and reporting standard and does not by itself authorise the acceptance of any particular external or overseas dataset.

Implications for Overseas Sponsors

For overseas manufacturers, the guideline offers a more predictable route for converting clinical use in Lecheng into evidence for national registration. Sponsors should plan the Lecheng study from the outset with registration in mind, including protocol design, data collection and quality control, rather than treating routine clinical use as an evidence source after the event.

Data governance is a practical constraint. Real-world data generated in China generally cannot be transferred outside the country unless the applicable cross-border data requirements are met, which affects where analyses are performed and how global teams access results. Sponsors should also expect the NMPA to judge Lecheng data as one part of the evidence package, alongside overseas trial and post-marketing data, and should use the CDE communication procedures to agree the role of Lecheng evidence before submission.

Medical writers supporting such applications should make sure that study reports describe the Lecheng data source in enough detail for reviewers to assess it: the participating institutions, the period of data collection, how patients were identified, how outcomes were recorded and verified, and how the Lecheng population compares with the populations studied overseas. Clear cross-referencing between the Lecheng study report and the overseas clinical data will help reviewers see how the two sources fit together. Where the guideline’s staged process requires interim submissions or regulatory review points, teams should build these into project timelines from the outset.

What to Do

Five steps for sponsors considering the Lecheng real-world data route

Obtain the original textReview the Hainan MPA guideline in Chinese, as secondary summaries may omit operational detail.
Plan for registration earlyDesign the Lecheng study protocol and data collection with the intended NMPA application in mind.
Use CDE communicationAgree the role of Lecheng evidence with the CDE through its real-world evidence communication procedures.
Address data transfer rulesPlan analyses so that cross-border data requirements are met before any data leave China.
Combine with overseas dataPresent Lecheng data as supplementary to overseas clinical and post-marketing evidence.

The guideline is issued on a trial basis and may be revised. Sponsors should confirm current requirements with the Hainan MPA and the NMPA before committing to a study.

Who It Applies To

Subjects

Imported drugs and devices

Products approved overseas and used in the Lecheng pilot zone before NMPA registration.

Population

Patients in Lecheng

Patients treated with these products in designated Lecheng medical institutions.

Countries

China

The data support applications to the national regulator; overseas sponsors are the main users.

Frequently Asked Questions

The Hainan Provincial Medical Products Administration issued the trial guideline. Secondary sources report the issue date as 29 April 2026.

Lecheng real-world data are generally described as supplementary evidence. Most products approved through the route have relied mainly on overseas data, supplemented by data from Chinese patients treated in the zone.

Real-world data generated in China generally cannot be transferred abroad unless the applicable cross-border data requirements are met. Sponsors should plan analyses accordingly.

The guideline operates alongside the NMPA’s 2020 real-world evidence guideline and later CDE guidance on study design and communication, and the NMPA’s 2026 decision to apply ICH M14.

Sources

Each source was checked on the date shown. Requirements may change after that date; confirm the current version with the issuing body.

  1. 1Cisema. (2026). Hainan MPA issues trial Lecheng real-world data guideline for imported drug and medical device registration. Regulatory news (secondary source).
    https://cisema.com/news/lecheng-real-world-data-guideline Read 9 November 2026.
  2. 2Becaris Publishing. (2026). China’s Lecheng pilot zone publishes new guidance on real-world evidence for drug and device registration. Blog post (secondary source).
    https://becarispublishing.com/digital-content/blog-post/china-s-lecheng-pilot-zone-publishes-new-guidance-real-world-evidence-drug-and-device Read 9 November 2026.
  3. 3Cisema. (2026). NMPA to apply ICH M14 on real-world data safety studies. Regulatory news (secondary source).
    https://cisema.com/news/nmpa-ich-m14-rwe Read 9 November 2026.
  4. 4BaiPharm ChemLinked. (n.d.). Guidelines on Real-world Evidence Supporting Drug R&D and Review (Trial). Regulatory database entry.
    https://baipharm.chemlinked.com/regulatorydb/view/81 Read 9 November 2026.
  5. 5BaiPharm ChemLinked. (2023). Guidelines on Communication About Drug Registration Application Supported by Real-world Evidence. Regulatory database entry.
    https://baipharm.chemlinked.com/regulatorydb/view/82 Read 9 November 2026.
  6. 6Cisema. (n.d.). Hainan Pilot Zone (Boao Lecheng). Regulatory overview (secondary source).
    https://cisema.com/news/hainan-pilot-zone-boao-lecheng Read 9 November 2026.

Boao LechengChina real-world dataNMPA registrationHainan MPAreal-world evidence

Hainan Issued a Trial Guideline on Lecheng Real-World Data for Product Registration in 2026Regulatory intelligence

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