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CDSCO License for Electric pad whole- body heating system

Medical Device Information

Device Class
Class B

Intended Use

An assembly of mains electricity (AC-powered) devices designed to heat a patient's whole body, to compensate for the loss of normal body heat, with heat generated from an externally applied pad typically containing electrical heating elements or cables. The system includes the pad designed to heat under or over the patient, and a control unit to regulate and monitor the heat. The pads are available in a variety of lengths, widths, and thicknesses to accommodate body size and applications (e.g., adult/paediatric, full-/partial-body).  The system is typically used in the operating room (OR), the intensive care unit (ICU), or in neonatal and recovery units.

Manufacturing License
MD5
Import License
MD15
CDSCO License for Electric pad whole- body heating system

Introduction to Electric Pad Whole-Body Heating System and its Regulatory Importance

Electric pad whole-body heating systems are critical medical devices used predominantly in pediatric and neonatal care to prevent hypothermia during surgical and recovery procedures. These AC-powered devices, featuring electrically heated pads and control units, help maintain patient body temperature in sensitive environments such as operating rooms and intensive care units. Given their direct impact on patient safety, ensuring compliance with India's CDSCO regulatory requirements is essential for manufacturers and importers aiming to market these devices in India.

CDSCO Regulatory Framework for Electric Pad Whole-Body Heating Systems

The Central Drugs Standard Control Organization (CDSCO) governs the import, manufacture, and sale of medical devices in India. As per the notification File No. 29/MiscJ03/2020-DC (150) dated 23.8.2021, Electric Pad Whole-Body Heating Systems are classified under Risk Class B, which mandates obtaining an MD5 manufacturing license from the State Licensing Authority before production can commence.

Risk Classification and License Requirements

Our extensive experience working with over 500 companies confirms that Class B devices such as electric heating pads require an MD5 license (application on Form MD3). This classification reflects a moderate risk level, necessitating thorough testing, documentation, and compliance audits. The State Licensing Authority grants this license after successful completion of all regulatory steps.

Manufacturing License Process (MD5) for Electric Pad Whole-Body Heating Systems

The MD5 license process involves multiple sequential steps:

  1. Test License Application (Form MD13): Initially, you apply for a test license which allows prototype production and testing. This step typically takes 1.5 to 2 months.

  2. Product Testing: Conduct mandatory testing at CDSCO-approved government laboratories to validate device safety and performance. Check the Testing Laboratories list for approved facilities.

  3. Document Preparation: Prepare comprehensive documentation including Device Master File (DMF), Plant Master File (PMF), Essential Principles Checklist, and Risk Management File.

  4. License Application Submission (Form MD3): Apply for the MD5 manufacturing license through the CDSCO MD Online Portal.

  5. Audit by Notified Body: A CDSCO recognized notified body will perform a detailed audit of your manufacturing premises and quality management system. Refer to the Notified Bodies list for authorized auditors.

  6. Query Resolution: Address any queries raised by the CDSCO or the notified body promptly.

  7. Grant of MD5 License: Upon satisfactory compliance, the State Licensing Authority issues the license on Form MD5.

For a detailed walkthrough, see our MD5 License Guide.

Manufacturing License Documents Required

To ensure a smooth application process for your Electric Pad Whole-Body Heating System, prepare the following documents meticulously:

  • Company Constitution (Incorporation Certificate, Partnership Deed, etc.)
  • Proof of ownership or lawful possession of manufacturing premises
  • Qualifications and experience certificates of technical staff
  • Fire NOC and Pollution Control Board NOC
  • Device Master File (DMF) detailing design, materials, and manufacturing process (DMF Guide)
  • Plant Master File (PMF) describing the manufacturing environment and equipment (PMF Guide)
  • Essential Principles Checklist confirming compliance with Indian Medical Device Rules
  • Risk Management File documenting hazard analysis and mitigation strategies (Risk Management Guide)
  • Test Reports from government-approved laboratories
  • Labels and Instructions for Use (IFU) compliant with CDSCO requirements
  • Quality Management System (QMS) documentation, usually ISO 13485:2016 certified

Import License Process (MD15) for Electric Pad Whole-Body Heating Systems

If you are an importer rather than a manufacturer, an MD15 import license issued by the Central Licensing Authority is mandatory. The process is as follows:

  1. Document Preparation: Assemble documents including existing manufacturing license, Free Sale Certificate, ISO 13485:2016 certification, CE Certificate, DMF, PMF, wholesale license, and company constitution.

  2. Application Submission: File Form MD14 through the CDSCO MD Online Portal.

  3. Query Resolution: Respond to any CDSCO queries.

  4. Grant of License: After evaluation, the MD15 import license is granted.

We provide specialized support for import license applications; see the Import License Guide for further details.

Import License Documents Required

  • Manufacturing License from the country of origin
  • Free Sale Certificate from the regulatory authority of the exporting country
  • ISO 13485:2016 Certification
  • CE Certificate or equivalent
  • Device Master File and Plant Master File
  • Wholesale Drug License
  • Company Constitution and Authorized Signatory Details

Timeline and Processing Duration

For an Electric Pad Whole-Body Heating System (Risk Class B), anticipate the following timelines:

  • Test License (Form MD13): 1.5 to 2 months
  • Product Testing: 1 to 1.5 months
  • MD5 License Application & Audit: 1.5 to 2 months

Total duration: Approximately 3 to 4 months from start to finish.

For import licenses (MD15), expect 5 to 6 months due to central authority processing.

Government Fees and Costs

  • MD5 Manufacturing License: Rs 5,000 per application plus Rs 500 per product
  • Test License (MD13): Included in overall process costs

These fees are payable online via the CDSCO MD Online Portal.

Common Challenges and Solutions

  • Documentation Gaps: Incomplete or inconsistent Device Master Files and Risk Management Files are frequent causes of delays. We recommend early preparation and expert review.

  • Testing Delays: Selecting government-approved labs and scheduling tests in advance can mitigate bottlenecks.

  • Audit Findings: Pre-audit readiness assessments often prevent non-compliance observations.

  • Query Response Delays: Prompt and precise replies to CDSCO queries expedite approvals.

Our consultancy offers tailored audit readiness and documentation support to overcome these hurdles efficiently.

Expert Consultation and Support

With over 25 years of experience facilitating CDSCO licensing, we have helped 500+ companies successfully launch medical devices including electric whole-body heating pads. Our services include:

  • Regulatory pathway analysis
  • Documentation preparation and review
  • Coordination with notified bodies and testing labs
  • Application filing and follow-up
  • Training on Indian Medical Device Rules compliance

Leveraging our expertise minimizes risk and accelerates your time to market.

Getting Started with Your CDSCO License Application

  1. Conduct an internal assessment of your product against CDSCO classification and requirements.
  2. Compile and organize essential documents such as DMF, PMF, QMS, and test data.
  3. Apply for the test license (Form MD13) through the CDSCO MD Online Portal.
  4. Simultaneously, schedule product testing at an approved laboratory.
  5. Prepare for notified body audit by reviewing your manufacturing premises and quality systems.
  6. Engage a regulatory consultant experienced in MD5 licensing to guide you through the process.
  7. Submit the manufacturing license application (Form MD3) once test license and testing are complete.

Starting early and maintaining proactive communication with CDSCO and notified bodies will ensure a successful licensing journey for your electric pad whole-body heating system. For personalized assistance, contact us to leverage our proven expertise in medical device regulatory compliance.

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About the Author

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Tails Azimuth
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