IVDR Regulation EU 2017/746

Medical Device / IVD Loan License

The Medical Device/IVD Loan License, governed by the Central Drugs Standard Control Organization (CDSCO), is a crucial aspect of India's regulatory framework for medical devices and in vitro diagnostics (IVDs). This licensing mechanism facilitates the manufacturing of medical devices and IVDs under specific conditions, ensuring compliance with the stringent standards set by the Medical Device Rules, 2017.

A loan licence is essentially a permission granted to a firm (licensee) that does not possess its own manufacturing facility but wishes to manufacture medical devices or IVDs at the premises of another firm (licensee holder), which holds a valid manufacturing licence. This arrangement allows firms to leverage existing manufacturing facilities without the need to invest heavily in infrastructure, thereby fostering innovation and enabling quicker market entry for new products.

The application process for a Medical Device/IVD Loan License involves several steps. First, the applicant must submit an application in Form MD-4 to the CDSCO, along with necessary documents such as the manufacturing agreement, product specifications, quality assurance procedures, and evidence of compliance with the essential principles of safety and performance. The application must also include details of the licensee holder’s manufacturing site, which must already be registered with the CDSCO and comply with Good Manufacturing Practices (GMP).

Upon receipt of the application, the CDSCO conducts a thorough evaluation, which may include an inspection of the manufacturing site to ensure it meets the required standards. The inspection assesses various aspects such as the facility’s infrastructure, quality control systems, manufacturing processes, and the competency of personnel. If the inspection is satisfactory and all documents are in order, the CDSCO grants the loan licence in Form MD-6, allowing the licensee to manufacture the specified medical devices or IVDs at the licensed premises.

The regulatory requirements for maintaining a Medical Device/IVD Loan License are stringent. Both the licensee and the licensee holder are jointly responsible for ensuring compliance with the Medical Device Rules, 2017. This includes adhering to quality management systems, conducting regular internal audits, and maintaining detailed records of manufacturing processes, quality control tests, and distribution activities. Any changes in the manufacturing process or the specifications of the medical devices/IVDs must be promptly reported to the CDSCO for approval.

The Medical Device/IVD Loan License system offers several benefits. For emerging companies and startups, it provides a cost-effective route to bring innovative products to market without the significant investment required for setting up manufacturing facilities. It also allows established manufacturers to optimise the use of their existing facilities, thereby increasing production capacity and operational efficiency. Moreover, this system promotes collaboration between firms, fostering a competitive and dynamic medical device industry in India.

Documents Needed :
  • Device Master File
  • Site Master File
  • QMS Documents
  • Manufacture Licence

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