CDSCO Regulated Service

Drug Registration
in India — Complete
Compliance Guide

End-to-end support for drug registration under the Drugs & Cosmetics Act, 1940 — from Retail & Wholesale licences to New Drug Applications, Import Licences, NOCs and more.

300+
Drug Licences Obtained
97%
Import Licence Success
15+
Years Experience
24hr
Query Response Time
💊
Drug Licence (Retail)
Form 20 / 21 — State Authority
ACTIVE
🏭
Manufacturing Licence
Form 25 / 28 — GMP Compliant
ACTIVE
📥
CDSCO Import Licence
Form 41 — Central Authority
ACTIVE
🔬
New Drug Application
NDCT Rules, 2019
ACTIVE
📜
Governing ActDrugs & Cosmetics Act, 1940
📋
RulesDrugs Rules, 1945 & NDCT 2019
🏛️
Central AuthorityCDSCO — MOHFW, India
🏢
State AuthorityState Drug Control Dept.
🖥️
PortalSugam / State Portals
⏱️
Timeline30 days – 24 months
Legal Framework

Acts, Rules & Regulatory Framework

India's drug regulation is governed by a multi-layered legal framework. Click each act to explore scope, schedules, and compliance obligations.

⚖️
Primary Legislation · 1940
Drugs & Cosmetics Act, 1940
The foundational law governing the import, manufacture, distribution and sale of drugs and cosmetics in India. Administered jointly by CDSCO (Central) and State Drug Controllers.

Key Provisions

Mandatory licensing for all drug manufacturers, wholesalers and retailers
Central licence required for import of drugs into India (Form 41)
Standards of quality, purity and strength for all scheduled drugs
Prohibition on manufacture/sale of adulterated or misbranded drugs
Powers of inspection, seizure and prosecution for violations
Regulation of clinical trials and new drug approvals

Scope & Coverage

All allopathic, Ayurvedic, Unani, Siddha and Homoeopathic drugs
Cosmetics as defined under Schedule S of the Act
Medical devices that also qualify as drugs under the Act
Biological products and vaccines regulated as drugs
Imported drugs must meet Indian Pharmacopoeia (IP) standards
Penalty provisions: imprisonment up to 10 years + fine
Schedule A — Pharmacopoeia Schedule C — Biological Products Schedule D — Exempted Drugs Schedule G — Caution Drugs Schedule H — Prescription Drugs Schedule H1 — Restricted Drugs Schedule X — Controlled Substances Schedule K — Exempt from Lic. Schedule L1 — Factory Standards Schedule M — GMP Schedule N — Pharmacy Schedule S — Cosmetics
📋
Procedural Rules · 1945
Drugs Rules, 1945
The operational rules under the D&C Act specifying the exact procedures, forms, fees, standards, and conditions for obtaining and maintaining drug licences in India.

Licence Forms Specified

Form 20/20B — Retail Drug Licence (allopathic)
Form 21/21B — Retail Licence for Sch. C & X drugs
Form 20C — Restricted Licence (Govt. dispensaries)
Form 25/28 — Manufacturing Licence (allopathic)
Form 41 — Import Licence (Central Govt.)
Form 10 — Wholesale Drug Licence

Key Compliance Requirements

Minimum area, storage and refrigeration requirements by licence type
Qualified person (Pharmacist / B.Pharma) mandatory for retail
Schedule M GMP compliance for all manufacturing licences
Record-keeping of sales, purchases and dispensing logs
Separate storage for Schedule H, H1 and X drugs
Annual renewal with state drug licensing authority
Form 20 — Retail Licence Form 21 — Sch. C Retail Form 25 — Mfg. Licence Form 28 — Mfg. Renewal Form 10 — Wholesale Form 41 — Import Schedule M — GMP Standards Schedule Y — Clinical Trials
🔬
New Drugs Framework · 2019
New Drugs & Clinical Trials Rules, 2019
Comprehensive rules governing approval of new drugs, biologicals, and the conduct of clinical trials in India. Replaced Schedule Y under Drugs Rules, 1945.

New Drug Approval

New Chemical Entity (NCE) approval pathway via CDSCO
New indication or new route for approved drugs
Biologicals: vaccines, blood products, recombinant proteins
Fixed Dose Combinations (FDC) approval requirements
Waiver of Phase I/II trials for well-studied molecules
Accelerated approval pathway for orphan drugs

Clinical Trial Conduct

Phase I–IV clinical trial permissions from CDSCO
Ethics Committee registration and IEC approval mandatory
Informed consent, safety reporting and site audit requirements
Clinical Trial Registry of India (CTRI) registration
Serious Adverse Event (SAE) reporting within 14 days
Bioavailability / bioequivalence study regulations
Form CT-04 — Clinical Trial Permission Form CT-11 — Waiver Application Form NDA-1 — New Drug Application Accelerated Approval Orphan Drug Designation BA/BE Studies
Cosmetics Framework · 2020
Cosmetics Rules, 2020
Separate rules for cosmetic products carved out from the D&C Act. Covers import registration, manufacturing licence, labelling and Schedule S compliance for cosmetics sold in India.

Import Registration

Foreign cosmetics must obtain CDSCO Import Registration Certificate (IRC)
Application via Form Cos-5 on Sugam portal
Product formulation, ingredient list and safety data required
Free Sale Certificate from country of origin mandatory
Indian Responsible Person (IRP) appointment required

Schedule S & Labelling

Schedule S lists prohibited / restricted cosmetic ingredients for India
Mandatory declaration of ingredients in INCI format on label
MRP, batch number, date of manufacture and expiry required
Safety assessment by qualified cosmetic toxicologist
Claims validation — no therapeutic / drug claims permitted
Form Cos-5 — Import Registration Schedule S — Prohibited Ingredients INCI Labelling Safety Assessment IRP Appointment
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Regulatory Updates
Advisories, Notices, Orders & Guidance Documents
CDSCO issues Office Memoranda (O.Ms.), advisories, final & draft notifications, and technical guidance documents that supplement the primary legislation and rules.

Types of Regulatory Documents

Advisories: Informal guidance on regulatory interpretation and best practices
Office Memoranda (O.Ms.): Official communications clarifying procedures
Final Notifications: Gazette-notified rules and schedule amendments in force
Draft Notifications: Proposed changes open for public comment before gazetting

Key Guidance Documents

CDSCO Technical Guidance on dossier preparation for new drugs
ADC NOC — Airport Drug Controller No Objection Certificate
Drug Export NOC — for export of drugs from India
Dual-Use NOC — for substances with dual civil/military use
CDSCO Test Licence — for import of samples for testing purposes
Advisories / Notices O.Ms. / Orders Final Notifications Draft Notifications Guidance Documents ADC NOC Drug Export NOC Dual-Use NOC CDSCO Test Licence
Licence Categories

Drug Licence Types We Handle

From simple retail drug licences to complex new drug approvals — we manage the full spectrum of drug licensing in India.

01
🏪
Retail Drug Licence

Required for retail sale of allopathic drugs to consumers. Issued by the State Drug Control Authority. A qualified pharmacist must be present during business hours.

🏢 State Authority
⏱️ 30–60 days
Form 20 / 21 Pharmacist Required Annual Renewal Sch. H / H1 / X
02
📦
Wholesale Drug Licence

For wholesale distribution of drugs to retailers, hospitals and institutions. Requires dedicated storage area, cold chain facilities and a qualified person-in-charge.

🏢 State Authority
⏱️ 45–90 days
Form 20B / 21B Cold Chain Setup Record Keeping Annual Renewal
03
🏭
Manufacturing Drug Licence

For manufacture of allopathic drugs. Requires GMP-compliant factory, approved premises, qualified staff, and QC laboratory. Issued by State Drug Controller for domestic; CDSCO for certain categories.

🏢 State / CDSCO
⏱️ 3–9 months
Form 25 / 28 Schedule M GMP QC Lab Required Site Inspection
04
📥
CDSCO Drugs Import Licence

Foreign manufacturers must obtain a Central Import Licence (Form 41) from CDSCO before commercially importing any drug into India. Comprehensive dossier and Indian agent required.

🏛️ CDSCO Central
⏱️ 3–12 months
Form 41 Foreign Mfr. Indian Agent Full Dossier
05
📤
Drug Export NOC & ADC NOC

No Objection Certificates required for export of drugs from India and for drugs transported via airports. ADC NOC is issued by the Airport Drug Controller for drugs in passenger baggage or courier.

🏛️ CDSCO / ADC
⏱️ 15–45 days
Export NOC ADC NOC Dual-Use NOC Airport Transit
06
🔬
CDSCO Test Licence & New Drug NDA

Test Licences allow import of drug samples for testing/analysis without full commercial registration. New Drug Applications (NDA) are for NCEs, fixed dose combinations, biologicals and new indications under NDCT Rules 2019.

🏛️ CDSCO Central
⏱️ 3–24 months
Test Licence New Drug NDA Biological FDC Approval NDCT 2019
Step-by-Step

Drug Registration Process

Our structured 6-step approach ensures your drug licence application is complete, compliant and processed without unnecessary delays.

1
Licence Category Assessment
Identify the correct licence type (retail / wholesale / mfg. / import) based on your business model, drug category and territory.
Week 1
2
Dossier & Documentation Preparation
Compile the complete application dossier — technical data, quality standards, manufacturing/GMP certificates and product information.
Week 2–6
3
Indian Agent / Authorised Person Setup
Appoint and register the Indian Authorised Agent or responsible person required for import and central licences.
Week 2–3
4
Application Submission & Fee Payment
File on Sugam portal (central) or state drug portal, upload documents in prescribed format and pay government fees.
Week 3–4
5
Authority Review & Site Inspection
CDSCO / State Drug Controller reviews the application. Manufacturing licences require physical factory inspection for GMP compliance.
Month 1–9
6
Licence Grant & Post-Licence Compliance
Receive drug licence certificate. We assist with annual renewals, label changes, additional product additions and pharmacovigilance reporting.
Approval + ongoing
STEP 1 OF 6

Licence Category Assessment

The first step is determining which drug licence is applicable to your specific situation — retail, wholesale, manufacturing or import — and whether it's a state-level or central (CDSCO) licence. Getting this right avoids wasted time and fees.

Business model review (retail / wholesale / mfg. / import)
Drug category determination (Sch. H, H1, X, C, etc.)
State vs. Central authority identification
Premises, staff and infrastructure gap assessment
Timeline and fee estimate for your licence type
1 wk
Duration
₹0
Fee This Step
Free
Consultation
Documentation

Documents Required by Licence Type

Required documents vary significantly by licence type. Below is a comprehensive breakdown for the most common drug licence categories.

🏪
Retail & Wholesale Drug Licence
State Drug Control Authority
📋
Application form (Form 19/19A/19B) with declaration● Mandatory
📋
Site plan / floor plan of premises (min. area per rules)● Mandatory
📋
Registered pharmacist / competent person certificate● Mandatory
📋
Proof of ownership / lease agreement of premises● Mandatory
📋
Refrigerator facility proof (for Sch. C drugs)● If Sch. C
📋
Affidavit of no existing drug licence cancellation● Mandatory
🏭
Manufacturing Drug Licence
State / CDSCO Authority
📄
GMP / Schedule M compliance certificate or self-declaration● Mandatory
📄
Factory plan with manufacturing, QC and warehouse areas● Mandatory
📄
Qualified person details (B.Pharm / M.Pharm / relevant degree)● Mandatory
📄
List of plant and machinery with capacity● Mandatory
📄
Product-wise master formula / manufacturing process● Mandatory
📄
Quality control lab equipment and SOP list● Mandatory
📥
CDSCO Import Licence (Form 41)
Foreign Manufacturer — Central CDSCO
📑
Manufacturing / GMP certificate from country of origin● Mandatory
📑
Free Sale Certificate (FSC) or WHO-GMP certificate● Mandatory
📑
Full product dossier (CTD / ACTD format)● Mandatory
📑
Pharmacopoeia standards compliance (IP/BP/USP)● Mandatory
📑
Indian agent authorisation letter and undertaking● Mandatory
📑
Clinical / safety data for new drugs or biologicals● New drugs
🔬
New Drug Application (NDA)
NDCT Rules 2019 — CDSCO
📑
Common Technical Document (CTD) / ACTD full dossier● Mandatory
📑
Preclinical (toxicology, pharmacology) study reports● Mandatory
📑
Phase I / II / III clinical trial data● Mandatory
📑
Indian patient data or waiver justification● CDSCO discretion
📑
Bioavailability / bioequivalence study data● Generic drugs
📑
Risk management plan and pharmacovigilance system● Mandatory
Mandatory for all
Conditional / situation-specific
Optional / recommended
Government Fees & Timelines

Indicative Fees & Approval Timelines

Fees vary by state, authority level and licence category. Timelines are statutory but actual durations depend on query resolution and inspection scheduling.

Licence Type Authority Approx. Govt. Fee Validity Statutory Timeline Key Form
Retail Drug Licence State Drug Controller ₹ 500 – ₹ 3,000 1–5 years 30–60 days Form 20 / 21
Wholesale Drug Licence State Drug Controller ₹ 1,000 – ₹ 5,000 1–5 years 45–90 days Form 20B / 21B
Manufacturing Licence State / CDSCO ₹ 5,000 – ₹ 50,000 5 years 3–9 months Form 25 / 28
CDSCO Import Licence CDSCO Central USD 1,000 – 5,000 3–5 years 3–12 months Form 41
New Drug NDA CDSCO Central ₹ 50,000 – ₹ 5,00,000 Permanent 12–24 months NDA-1 / CT-04
Drug Export NOC CDSCO Central ₹ 1,000 – ₹ 5,000 Per shipment 15–30 days Export NOC Form
ADC NOC Airport Drug Controller ₹ 500 – ₹ 2,000 Single use 7–15 days ADC Application
CDSCO Test Licence CDSCO Central ₹ 2,000 – ₹ 10,000 1–2 years 30–60 days Test Licence Form
ℹ️
Fees shown are approximate government fees only and subject to revision. State drug licence fees vary by state. Our professional service fees are separate. Contact us for a detailed quote tailored to your licence type and state.
Controlled Substances

Drug Schedules & Prescription Requirements

Understanding which schedule your drug falls under is critical — it determines prescription requirements, storage, sales records and penalties for non-compliance.

💊
Schedule H
Prescription-Only Drugs

Drugs that can only be sold on a valid prescription from a registered medical practitioner. Must be stored separately; sale records maintained for 2 years.

Antibiotics Antidepressants Antihypertensives Steroids
⚠️
Schedule H1
Restricted Prescription Drugs

Stricter than Schedule H. Requires prescription with doctor's registration number. Sales must be recorded in a separate register with patient and prescriber details.

3rd Generation Antibiotics Anti-TB Drugs Anti-Retrovirals
🔒
Schedule X
Habit-Forming Drugs

Habit-forming or psychotropic substances. Requires separate storage, special prescription with doctor details, and 2-year record retention. Separate licence often required.

Benzodiazepines Hypnotics Barbiturates
🚫
NDPS Act
Narcotic & Psychotropic Substances

Regulated under the NDPS Act, 1985 (not D&C Act). Requires special NDPS licence from NCB / State authority. Extremely strict storage, reporting and record requirements.

Morphine Codeine (high dose) Fentanyl
Schedule G
Caution-Label Drugs

Drugs requiring a caution label on the package: "Caution: To be sold by retail on the prescription of a Registered Medical Practitioner only." Less restrictive than Schedule H.

Hormones Anticoagulants Certain Vitamins (inj.)
🌡️
Schedule C & C1
Biological & Special Products

Biological and special products such as vaccines, sera, and blood products. Require special storage (cold chain, 2–8°C), separate records and testing before release.

Vaccines Sera Blood Products Insulin
Why Choose Us

Why RegPath for Drug Registration?

15+ years of navigating India's complex drug licensing framework — across all states and central CDSCO — means faster approvals and fewer rejections.

🎯

Multi-State Drug Licence Expertise

We handle drug licences across all Indian states — understanding each state authority's specific requirements, inspectors' expectations and timelines.

Pre-Built Dossier Templates

CDSCO-compliant CTD / ACTD dossier templates for import licences and new drug applications reduce preparation time by up to 50%.

🌐

Foreign Manufacturer Specialists

Extensive experience helping USA, EU, Japanese, and Korean pharma companies obtain Indian import licences — familiar with bridging foreign CTDs to Indian requirements.

🔬

New Drug & Biologicals Experience

Handled complex NDAs for new chemical entities, fixed dose combinations, biologicals and biosimilars under NDCT Rules 2019 with ex-CDSCO experts on our team.

Our Drug Licence Track Record
Based on 300+ drug licence applications (2009–2024)
Retail / Wholesale Licences99%
Manufacturing Drug Licence96%
CDSCO Import Licence (Form 41)97%
New Drug NDA / Biologicals88%
NOC / ADC / Test Licence100%

"RegPath helped us obtain our CDSCO Form 41 Import Licence in 8 months — their knowledge of dossier requirements and CDSCO procedures was exceptional."

— Regulatory Director, European Pharma Company
Frequently Asked Questions

Drug Registration FAQs

Answers to the most common questions from pharmaceutical companies, importers and retailers about drug licensing in India.

What is the difference between a retail and wholesale drug licence?
+
A retail drug licence (Form 20/21) permits sale of drugs directly to end consumers (patients). A wholesale drug licence (Form 20B/21B) permits sale to retailers, hospitals, dispensaries and institutions in bulk. Both are issued by the State Drug Control Authority and require a qualified pharmacist, but wholesale licences have different minimum area and record-keeping requirements.
Do I need a separate licence for Schedule H1 and Schedule X drugs?
+
Schedule H1 drugs can be dispensed under the same retail drug licence but with additional record-keeping requirements (separate register with doctor registration number). Schedule X drugs typically require an endorsement on your existing drug licence and a separate locked storage facility. NDPS drugs require an entirely separate licence from the Narcotics Control Bureau (NCB) or State authority.
Can a foreign pharma company directly sell drugs in India without an Indian entity?
+
No. Foreign manufacturers must appoint an Indian Authorised Agent / Indian Importer who holds or applies for the CDSCO Import Licence (Form 41). The foreign company provides authorisation to the Indian entity, which is then responsible for regulatory compliance in India. The Indian importer's name and address must appear on the product label.
What is the CTD / ACTD dossier format required by CDSCO?
+
CDSCO follows the ASEAN Common Technical Document (ACTD) format for most drug applications, which is similar to ICH CTD but with some differences in Module 1 (administrative). The dossier has 4 parts: Administrative, Quality (equivalent to CTD Module 3), Non-clinical (Module 4), and Clinical (Module 5). For new drugs, a full CTD in eCTD format may be required. RegPath can prepare or review your dossier for CDSCO compliance.
What is the validity of a CDSCO Import Licence (Form 41)?
+
CDSCO Import Licences for drugs are typically valid for 3 years, extendable on renewal. Some licences may be granted for up to 5 years. Renewal applications should be filed at least 6 months before expiry. Changes in formulation, label, or pack size require a variation application before implementation.
Is WHO-GMP certificate mandatory for CDSCO drug import registration?
+
Yes, a WHO-GMP certificate or an equivalent GMP certificate issued by the regulatory authority of the manufacturing country is mandatory for CDSCO drug import registration (Form 41). Additionally, a Free Sale Certificate (FSC) from the country of origin confirming the drug is approved for sale in that country is also required. Both documents must be apostilled or attested by the Indian Embassy.
What is pharmacovigilance and is it mandatory after drug approval?
+
Pharmacovigilance (PV) is the science of monitoring, detecting, assessing, understanding and preventing adverse effects of drugs. It is mandatory for all drugs approved under CDSCO. Licence holders must report Serious Adverse Events (SAEs) within 15 days, submit Periodic Safety Update Reports (PSURs), and maintain a pharmacovigilance system. RegPath provides ongoing PV compliance support to our clients.
How long does GMP inspection take for a manufacturing licence?
+
For domestic manufacturing licences, state drug controllers typically inspect within 1–3 months of application submission. The inspection itself takes 1–3 days depending on factory size and product range. For CDSCO-regulated categories or foreign manufacturers seeking India GMP certification, central inspections by CDSCO may take 3–6 months to schedule. RegPath assists in preparing for GMP inspections with mock audits and SOP review.

Ready to Obtain Your Drug Licence in India?

Book a free 30-minute consultation with our drug regulatory experts. We'll assess your licence requirements, prepare a roadmap and provide a transparent fee estimate.

📍
New Delhi, IndiaConnaught Place — 110001
✉️
info@regpathcdso.inResponse within 24 hours
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Mon – Sat9:00 AM – 6:30 PM IST