In India, the form for obtaining permission to import or manufacture a new In-Vitro Diagnostic (IVD) medical device is MD-28. Here’s an overview of the process and related forms:

Key Forms

  • MD-28: The application form submitted to the Central Licensing Authority (CLA) seeking permission to import or manufacture a new IVD.
  • MD-29: The permission letter issued by the CLA, granting approval for importing or manufacturing the new IVD.

The Application Process

  • Clinical Performance Evaluation (if required): For new IVDs without a predicate device, clinical performance studies might be needed. You may need to apply for Form MD-24 to get permission for the study and Form MD-25 for protocol approval.
  • MD-28 Submission: Submit the MD-28 application through the Sugam portal, along with:
    • Device information (classification, intended use, etc.)
    • Technical documentation
    • Clinical performance evaluation data (if applicable)
    • Manufacturing details
    • Certifications (like ISO 13485 for your quality management system)
    • Declarations and proofs
  • CDSCO Review: The CDSCO reviews the application and supporting documents.
  • MD-29 Issuance: If the application is approved, the CLA grants permission in the form of MD-29.

Additional Notes

  • The process can vary slightly depending on the specific IVD device and its classification.
  • The CDSCO website (https://cdsco.gov.in/opencms/opencms/en/Home/), has further details and guidance documents.
  • It’s recommended to seek assistance from a regulatory consultant specializing in Indian medical device and IVD regulations, as the process can be complex.

MD-28 Form Structure

The exact structure of the MD-28 form can be found on the CDSCO’s SUGAM portal, but here’s the general type of information it typically requests:

  • Part I: Applicant and Device Information
    • Applicant/Manufacturer Details: Name, address, manufacturing license/wholesale license details, authorized Indian agent details.
    • Device Details: Device name, classification, intended use, whether predicate devices exist domestically and internationally, etc.
  • Part II: Technical Documentation
    • Design and Manufacturing Information: Detailed drawings, materials list, specifications, manufacturing process description.
    • Performance and Safety Data: Results of performance testing, analytical and clinical validation data, risk analysis, stability studies.
    • Labeling: Specimen/product labels, instructions for use, list of symbols used.
  • Part III: Clinical Performance Evaluation (if applicable)
    • Study Protocol: If a clinical study was conducted, the detailed protocol would be included.
    • Study Report: Comprehensive report summarizing the study results, data, and conclusions on safety and performance.
  • Part IV: Quality Management System
    • Quality certificates: ISO 13485 or equivalent for the manufacturing facility.
    • Process Validation: Documented validation of key manufacturing processes.
  • Part V: Additional Declarations and Information
    • Declarations of conformity to standards.
    • Undertakings regarding post-market vigilance.
    • Proof of fee payment.

Key Considerations

  • Data Quality: The success of your application depends heavily on the quality of the data you provide. Ensure your device testing, clinical studies (if applicable), and documentation are rigorous and well-organized.
  • Regulatory Classification: IVD devices are classified based on risk. This will influence the level of data required. Consult CDSCO guidance or a regulatory specialist to understand your IVD’s classification.
  • Predicate Devices: If a similar IVD (predicate device) already exists in India or internationally, include detailed information for comparison, potentially simplifying the process.

Guidance Resources

  • CDSCO Website: The CDSCO website (https://cdsco.gov.in/opencms/opencms/en/Home/) has relevant guidance documents.
  • Medical Device Rules, 2017: Search for guidance specific to IVDs.

Professional Assistance

Due to the complexity of the process, and especially if your IVD is high-risk or entirely novel, consider working with a regulatory affairs consultant who specializes in the Indian market. They’ll guide you through:

  • Compiling documentation
  • Ensuring data meets CDSCO standards
  • Optimizing the application strategy

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