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CDSCO License for Eye sphere implant

Medical Device Information

Device Class
Class D

Intended Use

An eye sphere implant is a device intended to be implanted in the eyeball to occupy space following the removal of the contents of the eyeball with the  sclera left intact.

Manufacturing License
MD9
Import License
MD15
CDSCO License for Eye sphere implant

Comprehensive Guide to CDSCO Licensing for Eye Sphere Implant (Class D Medical Device)

As a trusted regulatory consultancy with over 25 years of experience supporting more than 500 medical device companies, we understand the complexities involved in obtaining CDSCO licenses—especially for high-risk devices like the Eye Sphere Implant. This internal prosthetic replacement, classified under Class D, requires meticulous compliance with the Central Drugs Standard Control Organization (CDSCO) regulations to legally manufacture or import in India.

Understanding the Eye Sphere Implant and Its Regulatory Importance

The Eye Sphere Implant is designed to be surgically implanted within the eyeball after the removal of its contents, maintaining the sclera intact. Being an internal prosthetic replacement, it addresses critical ophthalmic needs but also carries significant risk, mandating strict regulatory oversight.

Given its placement inside the body and potential impact on patient safety, the CDSCO classifies this device as Class D—denoting the highest risk category. Hence, manufacturers and importers must navigate the rigorous licensing process carefully to ensure compliance and market access.

CDSCO Regulatory Framework for Eye Sphere Implant (Class D Device)

The CDSCO regulates medical devices through a risk-based classification system, and Class D devices like the Eye Sphere Implant require a central license known as the MD9 Manufacturing License (for domestic manufacturers) or the MD15 Import License (for importers). These licenses ensure adherence to quality, safety, and efficacy standards aligned with the Medical Device Rules, 2017.

Risk Classification and License Requirements for Eye Sphere Implant

  • Device Risk Class: D (High risk)
  • Applicable License: MD9 for manufacturing; MD15 for importing
  • Governing Authority: Central Licensing Authority (CDSCO, New Delhi)
  • Relevant Notifications: 29/Misc/3/2017-DC (292) dated 06.06.2018

MD9 Manufacturing License Process for Eye Sphere Implant

For manufacturers intending to produce the Eye Sphere Implant in India, the MD9 license process involves several critical steps:

  1. Obtain Test License (Form MD13): This preliminary license allows for product testing and takes approximately 1.5 to 2 months to process.
  2. Product Testing: Conduct mandatory product testing at CDSCO-approved laboratories. For Eye Sphere Implants, testing includes biocompatibility, mechanical integrity, and sterility analysis.
  3. Document Preparation: Assemble comprehensive documentation, including Device Master File (DMF), Plant Master File (PMF), Essential Principles Checklist, Risk Management File, and Quality Management System (QMS) documents.
  4. Application Submission: Submit the MD9 manufacturing license application via the CDSCO MD Online Portal using Form MD7.
  5. Audit by CDSCO Inspectors: Post application, the CDSCO conducts a detailed audit of manufacturing facilities and quality systems.
  6. Query Resolution: Address any queries raised by the CDSCO during document review or audit.
  7. Grant of License: Upon satisfactory compliance, the MD9 license is issued on Form MD9.

Manufacturing License Documents Required

To streamline your application for the Eye Sphere Implant, ensure the following documents are meticulously prepared:

  • Company Constitution: Incorporation certificates, partnership deeds, or LLP agreements
  • Proof of Premises Ownership or Lease Agreement
  • Details and Qualifications of Technical Staff: Qualified personnel responsible for manufacturing and quality
  • Fire NOC and Pollution Control NOC: Valid clearances from local authorities
  • Device Master File (DMF): Detailed technical specifications, drawings, and manufacturing processes (learn more)
  • Plant Master File (PMF): Description of manufacturing facilities, equipment, and quality control (guide here)
  • Essential Principles Checklist: Compliance with safety and performance requirements
  • Risk Management File: Documentation per ISO 14971 standards (risk management overview)
  • Test Reports: From CDSCO-approved labs (list of testing laboratories)
  • Labels and Instructions for Use (IFU): Compliant with Indian regulations
  • Quality Management System (QMS) Documents: ISO 13485:2016 certification and SOPs

MD15 Import License Process for Eye Sphere Implant

For companies importing Eye Sphere Implants into India, the MD15 import license process is governed centrally and follows this sequence:

  1. Document Preparation: Compile all mandatory documents, including manufacturing license from the country of origin, Free Sale Certificate, ISO 13485:2016, CE Certificate, DMF, PMF, wholesale license, and company constitution.
  2. Application Submission: File the application on the CDSCO MD Online Portal using Form MD14.
  3. Query Resolution: Respond promptly to any queries raised by CDSCO within stipulated timelines.
  4. Grant of License: Upon thorough evaluation, the MD15 license is granted on Form MD15.

Import License Documents Required

Key documents to prepare for MD15 include:

  • Valid Manufacturing License from country of origin
  • Free Sale Certificate
  • ISO 13485:2016 Certificate
  • CE Certificate or equivalent
  • Device Master File & Plant Master File
  • Wholesale License (if applicable)
  • Company Constitution/Registration Proof

Timeline and Processing Duration for Eye Sphere Implant Licensing

License TypeTypical Duration
Test License (MD13)1.5 – 2 months
MD9 Manufacturing4 – 5 months (including audit)
MD15 Import5 – 6 months

Please note that timely submission of complete documentation and prompt query resolution can significantly reduce processing times.

Government Fees and Costs

License TypeApplication Fee (INR)Per Product Fee (INR)
MD9 Manufacturing50,0001,000
MD15 ImportClass D: Approx. 225,000 INR per site112,500 INR per product

Note: Import fees are typically paid in USD as per current exchange rates (approx. 3,000/site+3,000/site + 1,500/product for Class D).

Common Challenges and Practical Solutions

  • Delayed Test Reports: Engage with CDSCO-approved labs early and schedule testing well in advance to avoid bottlenecks.
  • Incomplete Documentation: Utilize checklists and expert review to ensure all documents like DMF and PMF are robust and compliant.
  • Audit Non-Compliance: Conduct internal mock audits to prepare your facilities and teams for CDSCO inspections.
  • Query Delays: Assign dedicated regulatory personnel to promptly address queries and maintain communication with CDSCO.

Expert Consultation and Support for Eye Sphere Implant Licensing

Navigating the CDSCO licensing process for a Class D device can be daunting. Our team offers:

  • End-to-end dossier preparation
  • Coordination for test licenses and product testing
  • Liaison with CDSCO and notified bodies
  • Pre-audit facility assessments
  • Tailored regulatory strategy aligned with your business goals

Partnering with experienced consultants reduces risks of rejection and expedites market entry.

Getting Started with Your CDSCO License Application for Eye Sphere Implant

Ready to initiate your CDSCO licensing journey? Follow these practical next steps:

  1. Assess Device Classification: Confirm your device as Class D based on the Medical Device Classification guide.
  2. Register on the CDSCO MD Online Portal: Create your company profile and familiarize yourself with the application forms.
  3. Plan Testing Schedule: Contact notified testing laboratories early (list here) to book your product tests.
  4. Prepare Master Files: Begin compiling your Device Master File and Plant Master File using our comprehensive DMF and PMF guides.
  5. Engage Regulatory Experts: Consider consulting experienced professionals to audit your documents and processes before submission.

By adhering to these steps and leveraging expert guidance, you can efficiently secure your MD9 or MD15 license for the Eye Sphere Implant and confidently enter the Indian medical device market.

For detailed assistance and personalized support, feel free to contact our regulatory specialists who have successfully facilitated licensing for over 500 companies in India and abroad.

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About the Author

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Tails Azimuth
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