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IndiaLicensing Guide

# CDSCO Medical Device Import License

Importing medical devices into India requires a CDSCO Import License for each device. The process involves extensive documentation, quality system certification, and often notified body assessment. Understanding the pathway before you start saves months of delays.

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At a glance

Application steps

6

Required documents

16

Timeline

45-180 days

## Import license application process

01

### Appoint Authorized Agent in India

Foreign manufacturers must appoint an Authorized Agent (AA) with permanent establishment in India. The AA submits the license application and acts as regulatory correspondent. Indian manufacturers/importers can apply directly.

02

### Determine device class and applicable form

Class A/B devices use Form MD-14. Class C/D devices use Form MD-15. The form selection determines documentation requirements and review timeline. Misclassification causes application delays.

03

### Obtain notified body certification (if required)

Class A sterile/measuring devices and all Class B/C/D devices require notified body conformity assessment. For Class A non-sterile/non-measuring, self-certification (MDS-1) may suffice.

04

### Prepare device dossier

Compile technical documentation: device description, design files, risk management, clinical evaluation, quality system certification, labeling, and post-market surveillance plan. Higher classes require more extensive dossiers.

05

### Submit application through CDSCO Sugam portal

Create account on CDSCO's online portal, complete application form, upload all documents, pay government fees. Incomplete applications are returned without review.

06

### Respond to queries and obtain license

CDSCO reviews application and may request clarifications or additional documents. Timely response is critical. Upon approval, CDSCO issues Import License with device-specific conditions.

## Required documents checklist

01Cover letter and application form (MD-14 or MD-15)

02Power of Attorney appointing Authorized Agent

03Device description and specifications

04Classification rationale document

05Essential principles conformity checklist

06Risk management file (ISO 14971)

07Quality management system certificate (ISO 13485)

08Notified body conformity certificate (if applicable)

09Clinical evaluation report

10Biocompatibility and sterilization test reports

11Software documentation (for software-enabled devices)

12Labeling and IFU (English + local language if required)

13Post-market surveillance plan

14Free Sale Certificate from country of origin

15Plant Master File (manufacturing facility details)

16Device Master File (technical specifications)

## Government fees structure

License TypeApplicationLicense FeeRenewal

MD-14 (Class A/B)₹1,000₹5,000 per device (3 years)₹5,000

MD-15 (Class C/D)₹1,000₹50,000 per device (3 years)₹50,000

MDS-1 (Self-registration)₹1,000₹1,000 per device₹1,000

## Post-license compliance obligations

Import only through licensed premises stated in the Import License

Maintain batch records and distribution records for traceability

Report adverse events to CDSCO within specified timelines

Conduct post-market surveillance and periodic safety updates

Notify CDSCO of any changes to device design, manufacturing, or labeling

Renew license before expiry (apply 6 months prior)

Cooperate with CDSCO inspections and sample requests

Maintain complaint handling and recall procedures

## Frequently asked questions

### How long does CDSCO import license approval take?

Timelines vary significantly by device class and application completeness. Class A/B (MD-14): 45-90 days after complete submission. Class C/D (MD-15): 90-180 days. First-time applicants and novel devices take longer. Delays typically occur due to incomplete dossiers, query responses taking time, or CDSCO requesting additional clinical data. Premium processing is not available.

### Can I import medical devices before obtaining the Import License?

Absolutely not. Importing medical devices without a valid Import License is a criminal offense under the Drugs and Cosmetics Act 1940. Customs will detain the shipment, CDSCO may prosecute, and products cannot be released even after license is later obtained. Always secure your Import License before shipping any medical devices to India.

### What is the role of the Authorized Agent?

The Authorized Agent is your legal representative in India for regulatory purposes. Their responsibilities include: submitting applications, receiving regulatory communications, maintaining import and distribution records, reporting adverse events, facilitating CDSCO inspections, and coordinating recalls if needed. The AA must have a permanent establishment in India and be available during business hours.

### Is one Import License valid for multiple device models?

Generally no — each device model or significant variant requires its own Import License. However, 'family' approvals may be possible for closely related devices with identical intended use, design principles, and manufacturing processes. CDSCO determines family approval eligibility on a case-by-case basis. Always consult CDSCO guidance or seek regulatory advice for family approval possibilities.

### What happens if my Import License expires?

You must stop importing immediately upon license expiry. Renewal applications should be submitted at least 6 months before expiry to avoid gaps. If your license expires before renewal is granted, you cannot import during the gap period. Products imported before expiry can still be distributed if within shelf life, but no new imports until license is renewed.

**Disclaimer:** This guide reflects the Medical Device Rules 2017 and current CDSCO procedures. Fees and requirements are subject to change through government notifications. Always verify current requirements on the CDSCO Sugam portal before submitting applications.

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