A UK MHRA Certificate of Free Sale (CFS) for fetal monitors supports overseas dossiers for registered cardiotocography equipment. Its schedule connects selected monitor configurations to the manufacturer’s product descriptions, technical specifications and conformity documentation.
The issued certificate can then be prepared for overseas use through verification, professional certification, an apostille and any required embassy legalisation.
Product category and MHRA registration: Fetal Monitors
Fetal monitors for cardiotocography, or CTG, are general medical devices intended to monitor fetal heart rate and uterine activity for the clinical applications specified by their manufacturer. Systems may use external ultrasound and uterine-activity transducers with recording or display functions. The documented intended purpose identifies users, operating environments, monitoring channels and any additional maternal parameters provided by the particular model.
The MHRA’s Device Online Registration System, or DORS, holds manufacturer, device and product records. Registration includes the relevant conformity information, such as CE or UKCA documentation, together with the details identifying the products. For manufacturers based outside the UK, a UK Responsible Person represents the manufacturer for the Great Britain registration process.
The MHRA’s medical device registration guidance explains the registration framework. The April 2026 reference guide describes how these records are entered and maintained in the online system.
For Great Britain, the manufacturer’s records sit within the UK medical device framework. A CFS order is submitted by an eligible UK-based manufacturer or UK Responsible Person, using registered products and the relevant CE or UKCA conformity evidence.
Documents and product information
The registration process brings together information about the manufacturer, the product and its conformity documentation. The main records include:
- Manufacturer details: the legal manufacturer’s name, registered address and contact information.
- UK Responsible Person documentation: representative details and the designation agreement, where applicable.
- Product details: monitor name, model, catalogue reference, legal manufacturer, channel configuration, transducer types, recorder arrangement and relevant software version. Labels, instructions, conformity documents and technical-file records describe signal acquisition, displayed measurements, recording functions, applicable alarms and electrical safety. Component records identify supported probes, connections, supplied mounting arrangements and cleaning instructions for relevant patient-contact parts.
- Registration identifiers: the GMDN code and term, with Basic UDI-DI and UDI-DI where applicable.
- Conformity documentation: the Declaration of Conformity and applicable conformity assessment certificates, including their references, validity and product schedules.
- Supporting product records: labels, instructions for use and the technical and performance documentation held by the manufacturer.
The online registration links the relevant conformity documents to the device record and identifies the individual products beneath it. The wider technical documentation supports the manufacturer’s compliance records; it is not a separate standard upload package for each CFS order.
From MHRA registration to an electronic CFS
- Accepted registration establishes the manufacturer, device and individual product records in DORS. Current conformity documents are linked to the relevant entries.
- The applicant selects the products marked CFS Ready and reviews the certificate and schedule preview. Model names and catalogue references come from the registered product data.
- After the order is submitted and paid for, the MHRA issues an electronically signed PDF. The complete certificate and every schedule page form the document set for subsequent verification and legalisation.
The MHRA CFS Reference Guide describes these stages. The published CFS service information gives an issuance aim of ten working days, with longer processing possible during busy periods.
Product coverage in the CFS schedule
A CTG platform may have single-fetus or multiple-fetus configurations, different transducer packages and optional maternal-monitoring functions. The registered product descriptions distinguish the supplied models and the entries selected for the CFS. Separately marketed probes, telemetry modules and central-monitoring software can have their own references and applicable records. A common brand name does not itself identify every connected component. The complete schedule and configuration documentation allow the overseas recipient to match the certificate to the precise fetal-monitoring equipment in its dossier.
Direct verification of the CFS with the MHRA
For an overseas submission, the authenticity of the issued certificate is an important part of document preparation. Ginkgo Advisory can arrange for a solicitor to seek direct confirmation of the CFS with the MHRA and review the certificate together with its schedule.
Solicitor certification and express UK FCDO apostille
Where the solicitor-certified route is accepted for the intended submission, Ginkgo Advisory can arrange solicitor certification followed by a UK FCDO paper apostille. The certification format is matched to the receiving authority’s requirements. MHRA’s published guidance describes a notarial route, and notarisation is arranged where that route is required.
Our express UK FCDO apostille service normally takes two working days once verification and the required certification are complete and the document is accepted for submission. The apostille stage has its own timetable, separate from MHRA certificate issuance, verification responses, any embassy processing and delivery. Further FCDO checks can affect completion.
Embassy legalisation for Egypt, the UAE, Kuwait and Qatar
Ginkgo Advisory can arrange embassy legalisation where required, bringing the verification, certification, apostille and relevant embassy submission into one coordinated service. The destination and intended use determine the required document format and any additional stages.
Preparing an issued MHRA CFS for overseas use
For a quotation, the starting documents are the MHRA-issued electronic PDF and all accompanying schedule pages. The issuance email, destination country, receiving authority’s instructions and required completion date help establish the appropriate preparation and delivery arrangements.
Contact Ginkgo Advisory with the issued CFS for a quotation covering direct MHRA verification, solicitor certification where accepted, express FCDO apostille and any required embassy legalisation.
Product questions
Does a fetal monitor CFS cover every probe and telemetry option?
The manufacturer’s component lists and compatibility records describe the available arrangements. Coverage follows the selected registered entries and their documented product presentations. The issued schedule establishes which monitor models and separately identified components are represented, including any selected telemetry equipment.