Import License Retention Fees in India

Manufacturers seeking to retain market access will need to pay Retention fees every 5 years for each Import License (manufacturing site) and each Endorsement (product registration). These fees range from US$50 for a Class A device to US$3,000 for Class D Import License and are the same as the initial application’s fee.

The fees, specified in the Second Schedule of MDR 2017, apply to each overseas manufacturing site and each approved medical device is endorsed to the license.

The initial application, and retention fees, are as follows:

It is important to note that retention fees are due every 5 years from the date for which the specific Import License or Endorsement was originally approved. Therefore, if an Import License with 1 product is approved in 2018 and then 2 more products are added in 2020, the manufacturer will need to pay the government fees for 1 Import License (Plant Master File) and 1 Endorsement (Device Master File) in 2023 while the other 2 products will be renewed in 2025. The fee will stay the same amount as the original fee and is in accordance with the Classification of the manufacturing site, or the Classification of the product.

Documentation Requirements for India Retention

The CDSCO MD’s Online checklist mandates submission of the following documents and information as part of the process for the retention of import licenses:

1. Application and intention forms,
2. Copy of all licenses, approvals, and endorsements related to the MD-15 Import License,
3. List of products being removed from the license (if applicable),
4. Declaration from the manufacturer confirming there are no changes,
5. Sales data by product,
6. Post market surveillance reports,
7. Free Sale Certificate from National Regulatory Authority of country of origin and following six reference countries: USA, EU, UK, Canada, Japan, Australia – both are required.
8. Updates ISO 13485 certificate,
9. Copy of any post approval changes,
10. Additional information,
11. Retention fees based on manufacturing site and individual products listed.

Manufacturers will want to ensure the they possess the above documentation in order to successfully renew their import license. A Retention Certificate will be issued once the retention fee is paid and the documents submitted online are reviewed and approved by CDSCO.

Amendments: The system does not allow for amendments during the renewal and updates to the product will need to be made separately. The renewal process requires a declaration from the manufacturer that no changes have been made to the product or manufacturing process. Manufacturers should be vigilant with license maintenance in India in order to avoid complications and delays in the license renewal process, which could interrupt market access.

Late Fees: Retention fees are to be submitted for maintenance of the perpetual import licenses. The fees can be paid after the renewal date but will incur a late fee.