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CDSCO License for Reactive-gel heating pad

Medical Device Information

Device Class
Class B

Intended Use

An underlay intended to produce heat through chemical reaction typically used to warm and/or maintain the body temperature of neonates or infants. It is typically designed with a soft outer casing (e.g., a soft plastic) that contains a chemically-reactive-gel activated by the user (e.g., by breaking its inner enclosure) to provide a heat of approximately normal body temperature (e.g., 38° Celsius) for a limited period. This device is typically used to maintain the body temperature of infant patients during transportation and may be x-ray translucent and  magnetic resonance imaging (MRI) compatible. This is a single-use device.

Manufacturing License
MD5
Import License
MD15
CDSCO License for Reactive-gel heating pad

Comprehensive Guide to CDSCO Licensing for Reactive-Gel Heating Pads (Class B Medical Device)

Reactive-gel heating pads serve a critical role in pediatric and neonatology care by maintaining body temperature for neonates and infants during transport. As a single-use device designed to provide consistent warmth through a chemical reaction, it demands stringent regulatory compliance to ensure safety and efficacy. With over 25 years of regulatory consulting experience and having supported 500+ companies, we provide a detailed roadmap for obtaining your CDSCO manufacturing or import license for this Class B medical device.


CDSCO Regulatory Framework for Reactive-Gel Heating Pads

In India, the Central Drugs Standard Control Organization (CDSCO) regulates medical devices under the Medical Device Rules, 2017. Reactive-gel heating pads fall under Class B (Low Moderate Risk) devices due to their intended use in vulnerable populations such as neonates. This classification requires compliance with manufacturing quality standards and licensing by the State Licensing Authority through the MD5 license pathway.

The regulatory framework mandates that manufacturers obtain a Test License (Form MD13), complete product testing at CDSCO-approved laboratories, undergo audits by notified bodies, and submit comprehensive documentation before the final license grant.

Risk Classification and License Requirements for Reactive-Gel Heating Pads

  • Risk Class: B (Low Moderate Risk)
  • License Type: MD5 Manufacturing License (Form MD3)
  • Licensing Authority: State Licensing Authority of the manufacturing site
  • Application Portal: CDSCO MD Online Portal

The MD5 license process ensures manufacturers meet the required technical and quality standards essential for pediatric devices that directly impact infant health.

Manufacturing License Process (MD5) for Reactive-Gel Heating Pads

  1. Obtain Test License (Form MD13): Apply for a test license to legally manufacture the device sample for testing. This process typically takes 1.5 to 2 months.
  2. Product Testing: Send samples to one of the CDSCO-approved testing laboratories for performance, safety, and biocompatibility testing. This step is critical for validating the reactive gel's safety and heat generation consistency.
  3. Documentation Preparation: Compile detailed technical files including Device Master File (DMF), Plant Master File (PMF), Risk Management File, Essential Principles Checklist, and Quality Management System (QMS) documents.
  4. Submit MD5 License Application (Form MD3): Apply via the CDSCO MD Online Portal.
  5. Audit by Notified Body: Coordinate with an authorized notified body for facility inspection and QMS audit.
  6. Query Resolution: Address any queries raised by CDSCO or the notified body promptly.
  7. License Grant: Upon successful completion, receive the MD5 license (Form MD5) allowing commercial manufacturing.

For an in-depth understanding, refer to our MD5 License Guide.

Manufacturing License Documents Required

Specific to reactive-gel heating pads, the documentation package must include:

  • Company Constitution (Incorporation Certificate, Memorandum, and Articles of Association)
  • Proof of ownership or lease of manufacturing premises
  • Details and qualifications of technical staff
  • Fire and Pollution NOCs from relevant authorities
  • Device Master File (DMF) detailing chemical composition, design, manufacturing process, and packaging (Device Master File Guide)
  • Plant Master File (PMF) describing manufacturing infrastructure and quality control systems (Plant Master File Guide)
  • Essential Principles Compliance Checklist demonstrating adherence to Indian Medical Device Rules
  • Risk Management File addressing potential hazards and mitigation strategies (Risk Management)
  • Test Reports from CDSCO-approved labs confirming safety and performance
  • Product labels, Instructions for Use (IFU), and packaging details
  • Quality Management System documentation, preferably ISO 13485:2016 certified

Completeness and accuracy of these documents significantly influence the speed and success of your application.

Import License Process (MD15) for Reactive-Gel Heating Pads

If you are an importer, the MD15 import license is mandatory, granted by the Central Licensing Authority. The typical process involves:

  • Preparing comprehensive documentation including a valid foreign manufacturing license, Free Sale Certificate, ISO 13485:2016 certification, CE marking (if applicable), Device and Plant Master Files, and wholesale license.
  • Application submission on the CDSCO MD Online Portal.
  • Query resolution with CDSCO.

The MD15 process for Class B devices usually takes 5 to 6 months. For detailed procedural guidance, see our Import License Guide.

Import License Documents Required

Key documents include:

  • Manufacturing License issued by the foreign regulatory authority
  • Free Sale Certificate from the country of origin
  • ISO 13485:2016 Quality Management System Certificate
  • CE Certificate (if marketed in Europe)
  • Device Master File
  • Plant Master File
  • Wholesale License in India
  • Company Constitution Documents

Ensuring these documents are authentic, translated (if necessary), and notarized expedites the approval.

Timeline and Processing Duration

License TypeProcess StepsApproximate Duration
Test License (MD13)Application, Testing1.5 to 2 months
MD5 LicenseDocument prep, Audit, Approval3 to 4 months (including test license)
MD15 Import LicenseDocument prep, Query resolution5 to 6 months

Plan your regulatory milestones accordingly to avoid delays in market entry.

Government Fees and Costs

License TypeApplication FeePer Product Fee
MD5 (Class B)Rs 5,000Rs 500 per product
MD15 Import (Class B)USD 2,000 (approx Rs 1.5 lakh)USD 1,000 per product

Additional costs include testing fees at government-approved labs, notified body audit charges, and consultancy fees if you engage expert support.

Common Challenges and Solutions

Challenge: Delays due to incomplete documentation or insufficient testing data.

Solution: Engage regulatory consultants early to prepare a robust Device Master File and ensure comprehensive testing protocols. Verify the testing laboratory's accreditation status.

Challenge: Audit non-conformities affecting QMS and manufacturing practices.

Solution: Conduct pre-audit readiness assessments and implement corrective actions proactively.

Challenge: Complex coordination between multiple stakeholders (testing labs, notified bodies, CDSCO).

Solution: Assign a dedicated regulatory project manager and maintain transparent communication channels.

Expert Consultation and Support

Navigating CDSCO licensing for reactive-gel heating pads requires domain expertise and practical insights. We offer end-to-end support including:

  • Compliance gap analysis
  • Documentation drafting and review
  • Coordination with CDSCO and notified bodies
  • Training on quality management and risk mitigation

Our successful track record with 500+ companies means you benefit from proven strategies and accelerated approvals.

Getting Started with Your CDSCO License Application

  1. Assess Device Classification: Confirm Class B status via the Medical Device Classification guide.
  2. Initiate Test License Application: Submit Form MD13 through the CDSCO MD Online Portal.
  3. Select Testing Laboratory: Choose an appropriate CDSCO-approved testing lab familiar with pediatric thermal devices.
  4. Prepare Documentation: Develop DMF, PMF, Risk Management File, and other required documents with expert assistance.
  5. Schedule Notified Body Audit: Contact a suitable auditor from the Notified Bodies List to plan your facility inspection.
  6. Submit MD5 Application: Once test reports and audit are complete, apply for the MD5 license via the online portal.
  7. Monitor and Respond: Address queries promptly to avoid delays.

By following these practical steps and leveraging expert guidance, manufacturers of reactive-gel heating pads can successfully navigate the CDSCO regulatory landscape, ensuring timely market entry and compliance with Indian medical device standards.

For personalized consultation and assistance, feel free to reach out to our regulatory experts who specialize in pediatric medical devices and have extensive experience with CDSCO licensing.

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About the Author

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Tails Azimuth
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