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Regulatory Affairs

Your Device Is Ready. Getting It Approved Should Not Take Two Years.

Most CDSCO timelines slip not because the device fails, but because the dossier invites questions. We build submissions that anticipate the query before the reviewer raises it, then carry you through licensing, audits and post-approval obligations.

India / CDSCO Services Discuss Your Submission
Correct Classification
from Day One
Query-Resistant
Dossiers
Predictable
Approval Timelines
India First,
Global Ready
The Reality on the Ground

Where Indian Regulatory Submissions Lose Time

CDSCO approval is rarely refused outright. It is delayed, one query at a time, until a six-month plan becomes an eighteen-month one. These are the causes we see most often.

1

The device is classified wrong at the outset

Classification drives the licence type, the authority, the fee, the evidence burden and the timeline. Get it wrong and every downstream document is built on a false foundation. Reclassification mid-process means starting again.

⚠ Full resubmission, months lost
2

The dossier invites queries it could have prevented

Reviewers raise questions where documentation is thin, inconsistent or silent. Each query cycle adds weeks. A dossier assembled to satisfy a checklist behaves very differently from one assembled to answer a reviewer's likely objections.

⚠ Repeated query cycles
3

The Authorised Indian Agent is chosen commercially

Foreign manufacturers frequently appoint their distributor as agent. The licence then sits in the distributor's name. Changing distributors later means surrendering and reapplying, with all the delay that implies.

⚠ Market access tied to one partner
4

Central and State authority routing is confused

Class A and B manufacturing sits with the State Licensing Authority. Class C and D sits with the Central Licensing Authority. Imports are always central. Filing to the wrong authority costs the entire submission window.

⚠ Application returned unprocessed
5

Plant and Device Master Files are treated as formality

The PMF and DMF are the substance of the submission, not covering paperwork. Weak master files are the single most common trigger for extended query cycles and for adverse findings during the licensing audit.

⚠ Audit findings and rework
6

The QMS is not audit-ready when the audit arrives

Licensing for Class C and D includes an inspection. Organizations often prepare the dossier thoroughly and the quality system barely at all, then face findings on a system that was never built to be examined.

⚠ Licence withheld pending CAPA
7

Test licence requirements are discovered late

Import for demonstration, evaluation, clinical investigation or training requires its own permission. Teams frequently learn this after shipment has been arranged, stranding consignments at port.

⚠ Consignments held at customs
8

Post-approval obligations lapse quietly

Licence renewal windows, change notifications, adverse event reporting and post-market surveillance carry no reminder. Non-compliance surfaces at renewal or inspection, when the remedy is expensive.

⚠ Licence suspension risk
India · Our Primary Focus

CDSCO and the Medical Devices Rules, 2017

Every medical device and IVD placed on the Indian market falls under the Medical Devices Rules, 2017, administered by the Central Drugs Standard Control Organisation under the Drug Controller General of India. Classification determines the licensing authority, the evidence required and the time it takes.

A
Low Risk

Non-sterile, non-measuring Class A follows a simplified registration route. Sterile or measuring Class A requires a manufacturing licence.

State Authority
B
Low-Moderate Risk

Manufacturing licence required, granted by the State Licensing Authority following documentation review and inspection.

State Authority
C
Moderate-High Risk

Central licensing with a fuller evidence burden, mandatory audit and typically longer review cycles.

Central Authority
D
High Risk

Highest evidence threshold. Clinical data expectations, rigorous master files and central inspection apply.

Central Authority

Import licensing is administered centrally for all classes, regardless of device risk category.

India · Licensing

Which Licence Applies to You

The right pathway depends on whether you manufacture, import, distribute or need product for evaluation. We identify the correct route before any application is drafted.

Form
Licence
Who It Is For
Authority
MD-5
Manufacturing Licence, Class A & B
Indian manufacturers of low and low-moderate risk devices
State
MD-9
Manufacturing Licence, Class C & D
Indian manufacturers of moderate-high and high risk devices
Central
MD-6 / MD-10
Loan Licence
Organizations manufacturing at a third-party facility
State / Central
MD-15
Import Licence
Foreign manufacturers importing through an Authorised Indian Agent
Central
MD-13
Test Licence
Import for evaluation, demonstration, training or examination
Central
MD-42
Wholesale Licence
Distributors and stockists selling or stocking devices
State
MD-23
Clinical Investigation Permission
Sponsors conducting clinical investigation in India
Central
MD-26
Investigational Device Permission
Import or manufacture of an investigational medical device
Central
Registration
Class A Non-Sterile, Non-Measuring
Simplified online registration route
Central Portal
ICMR Product Approvals BIS Certification Non-Conviction Certificate Market Standing Certificate Free Sale Certificate
Who We Work With

Support Scaled to Your Organization

A start-up filing its first submission and a multi-site manufacturer managing a licence portfolio need very different things from a regulatory partner.

Your Situation

First Submission, No Regulatory Function

The device works. The funding is time-bound. Nobody in the building has taken a product through CDSCO before, and every month of delay is a month of runway.

  • No in-house regulatory or quality personnel
  • Classification and pathway still uncertain
  • QMS either absent or documented on paper only
  • Investor or tender timelines driving urgency
  • Limited budget for a full-time regulatory hire

How We Engage

  • Classification determination and written pathway opinion before spend commits
  • Realistic timeline and cost map so funding can be planned against it
  • Lean ISO 13485 QMS sized to a small team, not a corporate template
  • Full dossier authoring, submission and query handling on your behalf
  • Audit preparation and on-site support through the licensing inspection
  • Handover briefing so your first regulatory hire inherits a working system
Typical EngagementEnd-to-end, single point of accountability

Your Situation

Growing Portfolio, Stretched Team

You hold licences already. One or two people carry regulatory alongside other duties, and each new product or market stretches capacity that is already fully committed.

  • Regulatory shared with quality, production or business development
  • Existing licences requiring renewal and change management
  • New product introductions competing for the same attention
  • Export markets opening faster than the team can respond
  • Audit readiness slipping between inspection cycles

How We Engage

  • Overflow capacity for submissions your team cannot absorb this quarter
  • Licence portfolio register with renewal and change-notification tracking
  • Dossier review before filing, to intercept queries in advance
  • QMS gap assessment and remediation ahead of inspection
  • Export pathway planning for EU, US and other target markets
  • Training to lift internal capability rather than create dependence
Typical EngagementRetainer or project-based, working alongside your team

Your Situation

Multi-Site, Multi-Market, Multi-Licence

An established regulatory function exists. The challenge is consistency across sites, visibility across a large licence portfolio, and specialist depth for the submissions that fall outside routine.

  • Multiple manufacturing sites with divergent practices
  • Large licence portfolio with staggered renewal obligations
  • Simultaneous submissions across India, EU, US and other markets
  • Post-market surveillance and vigilance obligations at scale
  • Internal capability strong in some areas, thin in others

How We Engage

  • Specialist support for complex or first-of-kind submissions
  • Harmonisation of regulatory practice across sites and business units
  • Independent dossier and master file review before filing
  • Notified body and regulatory audit preparation across locations
  • Post-market surveillance and PSUR system design at portfolio scale
  • Structured capability building for internal regulatory teams
Typical EngagementSpecialist partner supplementing an established function
Coverage

Manufacturing, Imports and Exports

Whether you manufacture in India, import into India, or manufacture in India for global markets, the regulatory pathway differs materially. We work across all three.

🏭

Manufacturing

Site licensing, plant and device master files, QMS build, licensing inspection support across Class A to D.

📥

Imports

Authorised Indian Agent structuring, import licensing, test licences and consignment clearance support.

📤

Exports

CE marking, US FDA pathways, WHO PQ, free sale and market standing certificates for outbound markets.

🔄

Post-Approval

Renewals, change notification, vigilance reporting, PSUR and ongoing compliance maintenance.

Our Services

Six Areas of Regulatory Support

From the first classification decision through to post-market obligations that continue for the life of the product.

01
🧭

Regulatory Strategy & Approval Pathways

  • Product classification and risk assessment
  • Market entry strategy: import, manufacturing, contract manufacturing, private labelling
  • Approvals across CDSCO, EU MDR 745 and IVDR 746, US FDA 510(k) and PMA, WHO PQ, PMDA, ANVISA, China and Canada
  • Regulatory roadmap and timeline planning
02
🔬

Clinical Investigation & Performance Evaluation

  • Clinical investigation and performance evaluation plans
  • Ethics committee coordination and regulatory submissions
  • Clinical data analysis and report compilation
  • Regulatory approvals for clinical and performance studies
03
📁

Technical Documentation & Compliance

  • Technical file and dossier preparation
  • Site master file and design dossier development
  • Performance Evaluation Report support
  • Risk assessment documentation
  • General Safety and Performance Requirements
  • Regulatory labelling compliance
04
📋

Licence Applications & Approvals

  • Manufacturing, import and test licences
  • Loan and wholesale licences
  • Clinical investigation and performance evaluation approvals
  • Query responses and follow-through
  • Regulatory certificates: NCC, MSC, FSC
  • ICMR product approvals and BIS certification
05
🛡️

QMS Compliance & Audit Support

  • QMS development and gap analysis: ISO 13485, FDA 21 CFR 820, EHS compliance
  • GxP compliance covering GMP, GLP and GDP
  • Risk management as per ISO 14971
  • Regulatory and notified body audit preparation and support
  • Post-audit CAPA support
06
🔁

Post-Market Compliance

  • Post-market surveillance and vigilance system implementation
  • Adverse event reporting and Periodic Safety Update Reports
  • Post-market clinical follow-up
  • Change management and licence renewals
  • Ongoing compliance support
Beyond India

Global Market Access

Indian manufacturers exporting, and global manufacturers entering India, both need pathways that work in more than one jurisdiction. We plan submissions so that work done for one market carries into the next.

🇪🇺

European Union

EU MDR 745 · IVDR 746

Technical file and design dossier preparation, CE marking strategy, notified body coordination, Clinical Evaluation Report and Performance Evaluation Report, EU authorised representative guidance.

🇺🇸

United States

US FDA

510(k) premarket notification, PMA support, De Novo pathway, QMSR and 21 CFR 820 compliance, establishment registration and device listing, US agent guidance.

🌐

Other Markets

WHO PQ · PMDA · ANVISA · Health Canada · China

WHO prequalification dossiers, Japan PMDA submissions, Brazil ANVISA registration, Health Canada licensing and China NMPA pathway assessment.

Why Choose Us

What You Get That You Would Not Otherwise

India Depth, Not India Coverage

CDSCO is our primary practice rather than one line on a global service list. We know how the authorities read a dossier, where queries originate, and what a licensing inspection actually examines.

Regulatory and Quality Together

Submissions fail at the QMS as often as at the dossier. We build both, so the quality system that supports your application is the same one that survives the audit.

Query Anticipation

Dossiers are assembled against likely reviewer objections rather than against a submission checklist. Fewer query cycles is the difference between six months and eighteen.

Senior Attention Throughout

A boutique practice means the person who scoped your submission is the person who writes it. Nothing is delegated down to a junior team after the proposal is signed.

Multi-Market Planning

Work done for CDSCO is structured so it carries into EU MDR, US FDA and WHO PQ submissions rather than being rebuilt from scratch for each market.

Beyond the Approval

Licences require renewal, changes require notification, and vigilance obligations continue for the product life. We build the system that keeps those obligations from lapsing.

Not Sure Which Pathway Applies?

Send us the device and its intended use. We will tell you the likely classification, the licence you need, the authority you file with and a realistic timeline, at no cost.

Request a Pathway Assessment Call: +91 9082657529