MD-27 Permssion

Purpose

• MD-26 is the application form used to seek permission from the Central Licensing Authority (CLA) to import or manufacture a new medical device in India.
• “New” means a medical device that does not have a predicate device (a similar, existing device) in the Indian market.

When is MD-26 Used?

• Importing New Medical Devices: Companies seeking to import a medical device that lacks a predicate device in India must file the MD-26.
• Manufacturing New Medical Devices: Manufacturers in India developing a new medical device (without a predicate) also use the MD-26.

Key Sections of the MD-26 Form

The exact structure of the form may evolve, so always refer to the latest version on the CDSCO’s Sugam portal. Here’s a general outline of information it includes:

• Applicant Details:
  • Company name, address, contact information.
  • Manufacturing license details (if applicable).
• Device Information:
  • Classification of the device (Class A, B, C, or D).
  • Generic name and intended use of the device.
  • Trade name or brand name of the device.
  • Details of the manufacturer (country of origin, manufacturer’s address, legal manufacturer)
• Technical Specifications:
  • Detailed description of the device.
  • Composition and materials used
  • Manufacturing process.
  • Standards and testing information (e.g., ISO, IEC, BIS)
  • Risk analysis report.
• Supporting Documentation:
  • Performance evaluation reports and test reports (biocompatibility, stability, etc.).
  • Clinical investigation report (if applicable).
  • Labeling and user manual drafts.
  • Free Sale Certificate or equivalent from the country of origin.
  • Other required declarations depending on the nature of your product.
• Fees and Payment: Refer to the CDSCO fee structure.

Submission Process

• Sugam Portal: The form is filed through the Sugam online portal (https://cdscomdonline.gov.in). You’ll need to register an account.
• Supporting Documents: Prepare all documents meticulously. Clarity and organization expedite review.

Important Considerations

• Complex Process: Filling out the MD-26 form and gathering supporting documents can be an intricate process. Incorrect or incomplete information can lead to delays or rejection.
• Regulatory Consultant: For complex devices or if you’re new to the process, it’s highly advisable to engage a regulatory consultant who specializes in the Indian medical device market. They can significantly streamline the process.
• Official Resources: Always refer to the latest MD-26 form and guidance document on the CDSCO website (https://cdsco.gov.in/).

Understanding MD-27 Permission

• What it is: MD-27 is permission from the Central Licensing Authority (CLA) to import or manufacture a new medical device in India, meaning one that doesn’t have a predicate device available in the Indian market.
• Significance: It’s a critical step, often one of the first for bringing innovative medical devices into India.

Steps & Considerations

1. Pre-Application Preparation

• Understand your device:
  • Thoroughly understand its classification (according to the Indian Medical Device Rules 2017) and potential risk category (Class A, B, C, or D).
  • Higher risk class means more stringent requirements.
• Assess Novelty: Conduct a detailed search for predicate devices within the Indian market. A qualified regulatory consultant can help with this.
  • No existing predicate device strengthens the case for the MD-27 pathway.
• Technical Documentation: Begin gathering and compiling comprehensive technical specifications, materials and manufacturing information, performance evaluation data, pre-clinical data, and, if relevant, any clinical data.

2. Clinical Investigation (If Required)

• Determination: Depending on your device’s risk profile, the CLA may mandate conducting a clinical investigation in India as part of the MD-27 application.
• Protocol & Approval: A detailed clinical investigation protocol must be designed and submitted for approval. (Form MD-22 is typically used)
• Ethics Committee: The investigation needs ethics committee approval.
• Data Compilation: Upon completion of the investigation, meticulous data collection, analysis, and a clinical investigation report must be generated.

3. MD-27 Application Preparation

• Sugam Online Portal: The CDSCO has streamlined this process through its Sugam online portal (https://cdscomdonline.gov.in). You’ll need to register and create an account.
• Form MD-26: Your application starts with Form MD-26. The level of detail required in this form is significant.
• Key Documents:
  • Technical file with specifications, manufacturing processes, performance data.
  • Detailed risk analysis of the device
  • Test reports (biocompatibility, sterility, etc.)
  • Clinical investigation report (if required)
  • Labeling and user manual drafts
  • Undertakings/Legal Declarations (vary depending on your situation)
• Fees: Review the CDSCO fee structure for the MD-27 process. Budget accordingly.

4. Application Submission & Review

• Form Submission: Meticulously review your application before submitting it with all supporting documents through the Sugam portal.
• Evaluation: The CLA will conduct a thorough review of your application. This can be a time-consuming process.
  • Be prepared to answer additional queries and potentially provide further data or clarifications as needed.

5. Decision & MD-27 Issuance

• Approval: If the CLA is satisfied with the safety and performance demonstrated, it will issue the MD-27 permission.
• Rejection: If major gaps or deficiencies are found, the application may be rejected. You might have opportunities to address these points and re-apply.

Additional Considerations

• Complexity: The process complexity increases with the risk classification of your device.
• Timelines: CLA review times can vary, and the MD-27 process generally takes several months. Anticipate potential delays.
• Guidance: The CDSCO website has valuable resources, but their information can be complex.

Important Notes:

• Regulatory Consultants: Engaging a qualified regulatory consultant specializing in Indian medical device regulation is highly advisable. Their expertise can save you time and increase your success rate.
• Constant Updates: Regulations change. Stay updated with the latest information directly from the CDSCO website.