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CDSCO License for Neonatal CPAP unit

Medical Device Information

Device Class
Class C

Intended Use

A mains electricity (AC-powered) device, which may include rechargeable batteries, intended to assist noninvasive ventilation (i.e., without use of an artificial airway) of a neonatal/infant patient via an attached nasal cannula or mask, using continuous positive airway pressure (CPAP) during spontaneous respiration. It is an electronic unit with controls, and may be used with compressed medical gas cylinders [e.g., air, oxygen (O2)] or include an O2 concentrator compartment; additional features (e.g., adjustable flow rates and O2 concentration, humidification) may be provided. It is primarily intended for use in a healthcare facility, especially in intensive and critical care settings.

Manufacturing License
MD9
Import License
MD15
CDSCO License for Neonatal CPAP unit

Comprehensive Guide to CDSCO Licensing for Neonatal CPAP Units (Class C Medical Device)

Manufacturing or importing a Neonatal CPAP unit in India requires compliance with the Central Drugs Standard Control Organization (CDSCO) regulatory framework. This device, classified as Class C due to its critical use in pediatrics and neonatology, demands a detailed approval process to ensure safety, efficacy, and quality standards are met. With over 25 years of experience and having supported more than 500 companies, we provide you with an expert roadmap to navigate the CDSCO licensing landscape efficiently.

Understanding the Neonatal CPAP Unit and Its Regulatory Importance

A Neonatal CPAP unit is an AC-powered electronic device designed to assist non-invasive ventilation for neonates and infants. It operates by delivering continuous positive airway pressure through nasal cannulas or masks, often incorporating oxygen concentration and humidification features. Given its critical role in intensive care settings, regulatory oversight ensures that the device meets stringent safety and performance criteria to protect vulnerable patients.

CDSCO Regulatory Framework for Neonatal CPAP Units

Under the Medical Devices Rules, 2017, the Neonatal CPAP unit falls under Class C due to its medium to high risk associated with life-supporting functions. This classification mandates compliance with the Central Licensing Authority (CLA) requirements, including obtaining an MD9 manufacturing license.

Risk Classification and License Requirements for Class C Devices

  • Risk Class: C (medium-high risk)
  • Regulatory Authority: Central Licensing Authority (CDSCO headquarters)
  • License Type: MD9 Manufacturing License (Application Form MD7)
  • Process Overview: Test license (MD13) → Product testing → Application for MD9 → Audit → License grant

For detailed device classification, refer to our Medical Device Classification guide.

The MD9 Manufacturing License Process for Neonatal CPAP Units

  1. Test License Application (Form MD13): Initiate with the test license for 1.5 to 2 months. This allows sample testing in government-approved labs.
  2. Product Testing: Conduct mandatory tests at CDSCO-recognized laboratories. See the Testing Laboratories list for approved facilities.
  3. Documentation Preparation: Compile comprehensive technical and quality documents, including Device Master File and Plant Master File.
  4. MD9 License Application (Form MD7): Submit the application through the CDSCO MD Online Portal.
  5. Regulatory Audit: CDSCO inspectors conduct a thorough audit of manufacturing facilities and QMS compliance.
  6. Query Resolution: Address any queries raised by CDSCO or auditors promptly.
  7. License Grant: Upon satisfactory review, the MD9 license is issued.

Essential Documents Required for MD9 License Application

  • Company Constitution and Registration Certificates
  • Proof of Ownership or Lease Agreement of Manufacturing Premises
  • Technical Staff Qualifications and Experience Documents
  • Fire and Pollution NOCs
  • Device Master File (DMF): Details device design and manufacturing processes. Learn how to prepare your DMF here.
  • Plant Master File (PMF): Details manufacturing site and quality systems. Guidance available here.
  • Essential Principles Checklist demonstrating compliance with Indian regulations
  • Risk Management File per ISO 14971 standards (critical for Class C devices). For implementation tips, visit our Risk Management guide.
  • Test Reports from CDSCO-approved labs
  • Product Labels and Instructions for Use (IFU)
  • Quality Management System (QMS) Documents, ideally ISO 13485:2016 certified

Import License Process (MD15) for Neonatal CPAP Units

If you intend to import Neonatal CPAP units into India, the process is managed centrally:

  • License Type: MD15 Import License (Form MD14)
  • Documents: Current MD9 manufacturing license from the country of origin, Free Sale Certificate, ISO 13485:2016, CE Certificate, Device Master File, Plant Master File, Wholesale License, Company Constitution
  • Timeline: Approximately 5 to 6 months
  • Fees: Vary by risk class; for Class C devices typically 3000persite+3000 per site + 1500 per product

Detailed import licensing steps and document requirements are outlined in our Import License Guide.

Timeline and Processing Duration

StageDuration
Test License (MD13)1.5 – 2 months
Product Testing1 – 1.5 months
MD9 License ApplicationSubmission & Audit
Audit & Inspection1 – 1.5 months
Query Resolution & Approval0.5 – 1 month
Total4 – 5 months

Planning ahead and preparing documentation meticulously can minimize delays.

Government Fees and Costs

  • MD13 Test License: Rs. 5000 per application
  • MD9 Manufacturing License: Rs. 50,000 per application plus Rs. 1000 per product
  • Product Testing: Varies by test scope and lab; budget approximately Rs. 1 to 2 lakhs

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

Common Challenges and Practical Solutions

  • Incomplete Documentation: Ensure all documents, especially Device and Plant Master Files, are comprehensive and up-to-date.
  • Delayed Testing Results: Coordinate early with government-approved labs to schedule testing.
  • Audit Non-Compliance: Conduct a pre-audit review and internal mock audits.
  • Query Management: Respond promptly and clearly to CDSCO queries to avoid processing delays.

Our experience shows that manufacturers who engage with notified bodies early and maintain open communication with CDSCO achieve faster approvals.

Check the list of notified bodies authorized for audits.

Expert Consultation and Support

Navigating the CDSCO process for Class C devices like Neonatal CPAP units requires expert knowledge. We offer tailored consulting services including:

  • Preparation of Device and Plant Master Files
  • Support for test license and product testing coordination
  • Comprehensive audit readiness and gap analysis
  • End-to-end application filing and follow-up

Our proven track record with 500+ clients ensures you minimize risks and accelerate your market entry.

Getting Started with Your CDSCO License Application

  1. Assess Your Device Classification: Confirm Class C status and related requirements.
  2. Gather and Prepare Documentation: Use our guides to develop your DMF and PMF.
  3. Apply for Test License (MD13): Submit your application via the CDSCO MD Online Portal.
  4. Schedule Product Testing: Coordinate with CDSCO-approved labs early.
  5. Plan for Audit: Engage a notified body and prepare your manufacturing site.
  6. Submit MD9 License Application: Once test reports and documentation are ready.
  7. Maintain Communication: Monitor application status and respond to queries swiftly.

Starting with a clear, detailed plan will help you efficiently obtain your MD9 license for Neonatal CPAP units and confidently enter the Indian healthcare market.

For personalized assistance and step-by-step support, contact our regulatory experts today.

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About the Author

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Tails Azimuth
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