India Approval Process for Medical Devices & IVD

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Before manufacturers of certain medical devices can sell within India, they need to be in compliance with India’s medical devices and IVD. Indian authorities overhauled the medical device regulatory process in 2017 with the publication of the Medical Device Rules. The rules came into force in January 2018 and devices are regulated by the Central Drugs Standard Control Organization (CDSCO), an agency of the Ministry of Health and Family Welfare. For an overview of the regulatory process, see or download the approval chart below.

Medical devices and IVDs are regulated by the Drug Controller General of India (DCGI) within the Central Drugs Standard Control Organization (CDSCO), part of the Ministry of Health and Family Welfare. The regulatory framework for medical devices is based on the Medical Device Rules, 2017. Only a limited number of medical devices and IVD require registration in India. A full list can be found in the CDSCO’s Notice on the classification of medical devices and IVD. This is not an exhaustive list. CDSCO does not maintain a single list of regulated devices, but rather subjects devices to regulation through the Drugs and Cosmetics Rules, the Medical Device Rules 2017, and subsequent Gazette Notifications, which should be reviewed prior to making a final determination of a device’s regulatory status.

Appoint an India Authorized Agent to interact with the CDSCO on your behalf. Your Agent must have a valid wholesale license (Forms 20B and 21B/21C), and be granted Power of Attorney to manage your registration and device importation in India.

Class B, C, and D IVD require in-country performance testing through the National Institute of Biologicals (NIB) or an accredited lab. Class D IVDs require performance testing through the National Institute of Biologicals (NIB). Class B and C IVDs require performance testing through an accredited Indian lab, though CDSCO may instead accept existing reports for such products with approval in a major regulatory market.

Compile device application (Form MD-14), including manufacturing facility information, device technical information, ISO 13485 certificate, IFU, testing results (if applicable), clinical data (if applicable), proof of approval in the US, EU, Australia, Canada, or Japan, plus proof of approval in your home country (satisfied by CFS/CFG). File application for registration/Import License with the CDSCO and pay fees. The CDSCO reviews applications and may require a Technical Presentation. Approximately 25% of applications require a formal Technical Presentation. The Technical Presentation is an in-person meeting with the CDSCO to discuss the product in more detail. A representative from the manufacturer (such as an engineer) is expected to attend this meeting along with the India Authorized Agent.

Novel devices will also undergo a Subject Expert Committee (SEC) review. Devices novel to the Indian market (new technology, material, intended use) may face additional regulatory hurdles. CDSCO may require clinical studies conducted in India prior to regulatory approval, or the agency may issue a restricted approval. A restricted approval could include a requirement to actively collect and submit post-market data. The SEC meeting will include local clinicians and other experts who will weigh in on the acceptability of the existing clinical data.

The CDSCO issues an Import License in Form MD-15. Following the implementation of the Medical Device Rules, 2017, the processes for obtaining device registration and import licensing were combined in India. Accordingly, the CDSCO does not issue Registration Certificates under the Medical Device Rules, instead issuing market authorization for foreign devices through the Import License (Form MD-15).

The License does not expire; however, license retention fees are due every five years.Once approved, only your India Authorized Agent may import products. However, you can obtain multiple registrations for the same device through different Authorized Agents.This is a simplified overview of the process. The CDSCO may choose to audit your submission and request more documents, which will add time to your approval.

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