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CDSCO License for Electroencephalo graph electrode/lead tester.

Medical Device Information

Device Class
Class B

Intended Use

An electroencephalograph electrode/lead tester is a device used for testing the impedance (resistance to alternating current) of the electrode and lead system of an electroencephalograph to assure that an adequate contact  is made between the electrode and the skin

Manufacturing License
MD5
Import License
MD15
CDSCO License for Electroencephalo graph electrode/lead tester.

Comprehensive Guide to CDSCO Licensing for Electroencephalograph Electrode/Lead Tester (Class B Device)

Electroencephalograph electrode/lead testers are indispensable neurological diagnostic tools used to verify the impedance of electrodes and leads in EEG systems, ensuring reliable skin contact and accurate brain activity measurements. Given their critical role in neurodiagnostics, regulatory compliance through the Central Drugs Standard Control Organization (CDSCO) is mandatory for manufacturers and importers aiming to market these devices in India.

With over 25 years of experience helping 500+ companies successfully navigate the CDSCO licensing landscape, we provide you with an expert roadmap for securing your license efficiently, minimizing delays and compliance risks.


CDSCO Regulatory Framework for Electroencephalograph Electrode/Lead Tester

This device falls under the neurological category and is classified as a Class B medical device according to the notified CDSCO classification Notification 29/Misc/03/2020-DC (201) dated 27.09.2021. The regulatory pathway involves obtaining a manufacturing license (MD5) from the State Licensing Authority, as Class B devices require adherence to moderate risk controls.

Key regulatory steps include:

  • Securing a Test License (Form MD13)
  • Product testing at CDSCO-approved laboratories
  • Documentation and audit by a CDSCO Notified Body
  • Application and issuance of the Manufacturing License (Form MD5)

All applications and submissions are managed online through the CDSCO MD Online Portal.

Risk Classification and License Requirements for Class B Devices

Class B devices like the EEG electrode/lead tester have a moderate risk profile, necessitating a robust quality management system and compliance with essential principles of safety and performance. The license required is an MD5 Manufacturing License, which is granted by the State Licensing Authority.

License Summary for Class B Devices:

License TypeAuthorityApplication FormTimeline (approx.)Fees (INR)
MD5 ManufacturingState Licensing AuthorityMD33-4 monthsRs 5,000 + Rs 500 per product
Test License (MD13)State Licensing AuthorityMD131.5-2 monthsIncluded in MD5 process

Manufacturing License Process (MD5) for Electroencephalograph Electrode/Lead Tester

Step 1: Obtain Test License (Form MD13)

Before manufacturing, you must secure a Test License allowing product testing. This typically takes 1.5 to 2 months. During this period, you prepare and submit initial documentation and pay requisite fees.

Step 2: Product Testing

The device must be tested at CDSCO-approved testing laboratories to validate compliance with Indian standards. Refer to the official Testing Laboratories list for authorized centers.

Step 3: Documentation Preparation

Compile comprehensive technical documentation, including Device Master File (DMF), Plant Master File (PMF), risk management files, and quality management system (QMS) documents. Our Device Master File guide and Plant Master File guide provide detailed insights into preparing these critical documents.

Step 4: Application Submission (Form MD3)

Submit the manufacturing license application via the CDSCO MD Online Portal, attaching all required documents and paying application fees.

Step 5: Audit by Notified Body

A CDSCO-recognized notified body will conduct a thorough audit of your manufacturing unit and documentation. You can check the list of notified bodies authorized for Class B audits.

Step 6: Query Resolution

Respond promptly and comprehensively to any queries raised by the CDSCO or notified body during the review process to avoid delays.

Step 7: License Grant (Form MD5)

Upon satisfactory audit and document review, the State Licensing Authority will issue the MD5 manufacturing license allowing commercial production.

Manufacturing License Documents Required

For the Electroencephalograph electrode/lead tester (Class B), the following documents must be meticulously prepared:

  • Company Constitution and Incorporation Documents
  • Proof of Premises Ownership or Lease Agreement
  • Technical Staff Qualifications and Experience
  • Fire NOC and Pollution Control NOC
  • Device Master File (DMF) detailing design, materials, and manufacturing process
  • Plant Master File (PMF) outlining manufacturing facilities and controls
  • Essential Principles Checklist demonstrating compliance with safety and performance
  • Risk Management File addressing potential hazards and mitigation measures
  • Product Test Reports from CDSCO-approved labs
  • Labels, Instructions for Use (IFU), and Packaging Details
  • Quality Management System Documents demonstrating compliance with ISO 13485:2016

Failing to provide complete and accurate documentation is one of the most common reasons for application delays.

Import License Process (MD15) for Electroencephalograph Electrode/Lead Tester

If you are an importer rather than a manufacturer, you will require an MD15 Import License granted by the Central Licensing Authority. The process differs as follows:

  • No test license is required upfront.
  • Detailed document preparation including manufacturing license from country of origin, Free Sale Certificate, ISO certification, CE marking, and the DMF/PMF.
  • Application submitted via the CDSCO MD Online Portal on Form MD14.
  • Timeline is approximately 5-6 months.
  • Fees vary based on risk class; for Class B devices, fees are Rs 2000 per site and Rs 1000 per product.

Our Import License guide offers detailed steps tailored for neurological devices.

Timeline and Processing Duration

Process StepDuration
Test License (MD13)1.5 - 2 months
Product Testing2 - 3 weeks
Documentation PreparationVariable (1-2 months recommended)
Audit by Notified Body3-4 weeks
Query Resolution2-4 weeks
License Grant (MD5)Total 3-4 months

Planning well in advance and maintaining proactive communication with regulatory bodies can help ensure these timelines are met.

Government Fees and Costs

  • Application Fee: Rs 5,000 (one-time per manufacturing site)
  • Product Fee: Rs 500 per product (applicable for each variation or model)
  • Testing and audit costs vary by notified body and laboratory, generally ranging from Rs 50,000 to Rs 1,00,000.

Budgeting for these costs upfront enables smoother financial planning and reduces surprises during the process.

Common Challenges and Solutions

  • Incomplete Documentation: Meticulously cross-check required documents against the checklist. Use expert consultation for DMF and PMF preparation.
  • Delays in Test Reports: Engage with CDSCO-approved labs early and confirm their testing turnaround times.
  • Audit Non-Compliance: Prepare thoroughly for audits by reviewing your QMS and manufacturing processes in line with ISO 13485.
  • Query Backlogs: Respond to CDSCO queries promptly with clear, evidence-backed answers.

Our hands-on experience allows us to anticipate and mitigate these pain points effectively.

Expert Consultation and Support

Navigating the CDSCO licensing process for devices like the Electroencephalograph electrode/lead tester requires specialized expertise. We offer:

  • Personalized regulatory strategy aligned with your product and business model
  • Preparation and review of all technical documentation
  • Coordination with notified bodies and testing laboratories
  • End-to-end application management on the CDSCO MD Online Portal
  • Post-approval compliance support

Our proven track record with over 500 successful approvals underscores our commitment to your regulatory success.

Getting Started with Your CDSCO License Application

  1. Assess Your Eligibility: Confirm your device’s classification and applicable license type.
  2. Gather Core Documents: Start collecting company registration, premises proofs, and technical staff details.
  3. Initiate Test License Application: Apply for Form MD13 via the CDSCO portal to start product testing.
  4. Engage a Notified Body Early: Select and coordinate with an appropriate notified body from the official list.
  5. Prepare DMF and PMF: Use expert guides and templates to create comprehensive master files.
  6. Plan Your Audit and QMS Compliance: Conduct internal audits and gap assessments before the official inspection.

Starting the process early and partnering with experienced consultants ensures a smooth journey from application to license grant.

For further assistance, reach out to our expert regulatory team to tailor a licensing plan specifically for your Electroencephalograph electrode/lead tester.

Let us help you bring your neurological device to the Indian market compliantly and confidently.

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About the Author

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Tails Azimuth
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