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CDSCO License for Zinc phosphate dental cement

Medical Device Information

Device Class
Class B

Intended Use

A non-sterile substance intended for professional use as a dental cement and/or direct dental restorative material whereby the majority of the setting reaction is based on the hardening reaction between an oxide  powder [the principal constituent of which is zinc oxide (ZnO)] and an aqueous solution of phosphoric acid.

Manufacturing License
MD5
Import License
MD15
CDSCO License for Zinc phosphate dental cement

Comprehensive Guide to CDSCO Licensing for Zinc Phosphate Dental Cement

Zinc phosphate dental cement is a vital dental material widely used by professionals for restorative procedures. Classified as a Class B medical device by the CDSCO, this non-sterile dental cement functions through a chemical hardening reaction primarily between zinc oxide powder and phosphoric acid solution. For manufacturers and importers aiming to enter the Indian market, understanding the regulatory landscape is crucial to ensure compliance and timely market access.

CDSCO Regulatory Framework for Zinc Phosphate Dental Cement

The Central Drugs Standard Control Organization (CDSCO) regulates medical devices in India under the Medical Device Rules (MDR) 2017. Zinc phosphate dental cement falls under the dental category and is notified under the notification number 29/Misc./03/2020-DC (140) Part-5, dated 10.10.2022. This notification aligns the product with the defined regulatory requirements applicable to Class B devices, emphasizing safety, efficacy, and quality.

Risk Classification and License Requirements for Class B Devices

Zinc phosphate dental cement is categorized as a Class B medical device, which is considered low to moderate risk. According to CDSCO regulations, manufacturing licenses for Class B devices are granted by State Licensing Authorities under the MD5 license scheme (application form MD3). This process involves strict adherence to quality management systems, testing, and regulatory audits.

Manufacturing License Process (MD5) for Zinc Phosphate Dental Cement

Our extensive experience with over 500 companies highlights the following stepwise approach for obtaining an MD5 manufacturing license:

  1. Test License Application (Form MD13): Begin with obtaining a test license, valid for 6 months, which allows you to manufacture and test your product. This phase takes approximately 1.5 to 2 months.

  2. Product Testing: Conduct mandatory product testing at government-approved laboratories listed on the CDSCO Testing Laboratories portal. Testing ensures compliance with Indian standards and essential principles.

  3. Document Preparation: Prepare critical documents, including Device Master File and Plant Master File, which detail technical specifications and manufacturing processes. Our Device Master File guide provides a practical approach to this step.

  4. License Application Submission: Apply for the MD5 manufacturing license using Form MD3 on the CDSCO MD Online Portal.

  5. Audit by Notified Body: An audit by a notified body is mandatory for Class B devices. Refer to the list of notified bodies to select an appropriate auditor.

  6. Query Resolution: Address any queries raised by the licensing authority or the notified body promptly to avoid delays.

  7. Grant of License: Upon successful audit and query resolution, the State Licensing Authority grants the MD5 license on Form MD5.

Manufacturing License Documents Required for Zinc Phosphate Dental Cement

To streamline your application, prepare the following comprehensive documentation:

  • Company Constitution (e.g., MOA, AOA)
  • Proof of Ownership or Lease of Manufacturing Premises
  • Details and qualifications of Technical Staff
  • Fire and Pollution NOCs
  • Device Master File (DMF)
  • Plant Master File (PMF)
  • Essential Principles Checklist
  • Risk Management File (as per ISO 14971 guidelines)
  • Product Test Reports from CDSCO-approved labs
  • Product Labels and Instructions for Use (IFU)
  • Quality Management System Documents compliant with ISO 13485

Import License Process (MD15) for Zinc Phosphate Dental Cement

If you are importing this dental cement into India, you must obtain an MD15 import license granted by the Central Licensing Authority. The process involves:

  • Preparation of detailed documentation including manufacturing license from the country of origin, Free Sale Certificate, ISO 13485 certificate, CE certification (if applicable), Device Master File, Plant Master File, and Wholesale License.

  • Applying through Form MD14 on the CDSCO MD Online Portal.

  • Responding to any queries raised by CDSCO.

  • License issuance typically takes 5-6 months.

For detailed guidance, refer to our Import License Guide.

Import License Documents Required

  • Valid Manufacturing License of the product in the country of origin
  • Free Sale Certificate
  • ISO 13485:2016 Certification
  • CE Certificate (if applicable)
  • Device Master File and Plant Master File
  • Wholesale License in India
  • Company Constitution Documents

Timeline and Processing Duration

License TypeProcessing TimeKey Milestones
MD5 Manufacturing3-4 monthsTest license (1.5-2 months), testing, audit, queries resolution
MD15 Import5-6 monthsDocument preparation, application, queries resolution

Planning your regulatory timeline with built-in buffers for audit scheduling and query responses can help avoid unforeseen delays.

Government Fees and Costs

For Zinc phosphate dental cement as a Class B device, the fee structure is as follows:

  • MD5 Manufacturing License:

    • Rs. 5,000 per application
    • Rs. 500 per product
  • MD15 Import License:

    • $2,000 per site
    • $1,000 per product

Budgeting accurately for these fees and associated costs like laboratory testing and notified body audits is essential for project planning.

Common Challenges and Solutions

Challenge: Delays due to incomplete documentation or non-compliance with quality standards.

Solution: Engage experienced regulatory consultants early to audit your documents, ensuring compliance with CDSCO requirements and ISO standards.

Challenge: Scheduling audits with notified bodies leading to timeline slips.

Solution: Pre-book audit dates and maintain a checklist of audit readiness, including staff training and document availability.

Challenge: Ambiguities in device classification affecting license type.

Solution: Utilize official CDSCO classification resources or consult with regulatory experts to confirm device class and applicable licensing pathway.

Expert Consultation and Support

With over 25 years of experience and 500+ successful CDSCO licensing projects, our team provides tailored consulting services for dental device manufacturers and importers. We assist with:

  • End-to-end application preparation and submission
  • Device and Plant Master File compilation
  • Risk management and essential principles compliance
  • Coordination with notified bodies and testing labs
  • Post-approval compliance and renewals

Our practical insights reduce application rejections and expedite market entry.

Getting Started with Your CDSCO License Application

  1. Assess Your Device Classification: Confirm that Zinc phosphate dental cement is Class B and requires an MD5 license for manufacturing.
  2. Prepare Preliminary Documents: Gather company constitution, premises proof, and technical staff details.
  3. Apply for Test License (MD13): Submit on the CDSCO MD Online Portal to start manufacturing and testing legally.
  4. Arrange Product Testing: Coordinate with government-approved testing laboratories to obtain compliance reports.
  5. Compile Technical Files: Develop your Device Master File and Plant Master File using our detailed guides.
  6. Schedule Notified Body Audit: Select an auditor from the notified bodies list and prepare for inspection.
  7. Submit MD5 Application: After successful testing and audit readiness, apply using Form MD3.

Initiating your CDSCO licensing journey with these practical steps and expert guidance ensures a smoother, faster approval process for Zinc phosphate dental cement. Contact us today to leverage our deep regulatory expertise and seamless support.


For further details on medical device classification and risk management, explore our resources on Medical Device Classification and Risk Management.

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About the Author

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Tails Azimuth
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