Drugs & Cosmetics Act, 1940 · State Drug Authority
Form20B + 21B

Wholesale Drug
Licence in India

Complete regulatory support for obtaining a Wholesale Drug Licence (Form 20B / 21B) from the State Drug Control Authority — required for every pharma distributor, stockist, C&F agent and wholesaler selling drugs in bulk to retailers, hospitals and institutions.

99%
Approval Rate
600+
Licences Obtained
30 Days
Min. Timeline
All States
Covered
Wholesale drug distribution warehouse
Form 20B ApprovedACTIVE
Allopathic wholesale licence
❄️Form 21B — Sch. CENDORSED
Vaccines & cold chain drugs
🧑‍💼Competent PersonVERIFIED
Graduate with 1 yr experience
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Governing LawD&C Act, 1940
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RulesDrugs Rules, 1945
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AuthorityState Drug Controller
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FormsForm 20B + Form 21B
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RequirementCompetent Person
⏱️
Timeline30 – 90 days
Overview

What is a Wholesale Drug Licence?

A Wholesale Drug Licence authorises a business to purchase drugs in bulk from manufacturers and sell them to retailers, hospitals, government dispensaries and other licensed entities — but not directly to the public.

Drug wholesale distribution warehouse
State Drug Controller
5 Yrs
Typical licence validity
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Legal Obligation

No person can wholesale drugs without a valid licence under the D&C Act, 1940. Unlicensed wholesale attracts criminal prosecution — imprisonment up to 3 years and heavy fines. Each state premises requires its own separate licence.

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Who Needs This Licence

Pharma distributors, C&F agents, super stockists, hospital suppliers, government tender participants, importers selling to retailers, and any business purchasing drugs from manufacturers to sell onward to licensed entities.

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Competent Person Mandatory

A Competent Person — a graduate in pharmacy, medicine, science, chemistry or equivalent with at least 1 year's experience in drug trading — must be appointed and must be present during business hours.

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Annual Renewal Required

Wholesale Drug Licences must be renewed annually or as specified by the state. We track all renewal deadlines for clients and file renewals 45 days in advance — preventing any lapse in licence validity.

Service Categories

Wholesale Drug Licence Services

Whether you are a first-time distributor, a C&F agent, or a pharma importer — we handle the complete licence lifecycle across all states.

Wholesale pharmacy Form 20B
Form 20B⏱ 30–60 days
// 01
Form 20B — New Wholesale Licence

The primary wholesale drug licence for distributing allopathic drugs to retailers, hospitals, clinics and licensed entities. Issued by the State Drug Controller after verification of premises and competent person credentials.

Allopathic DrugsForm 20BState SDCNew Application
Apply Now →
Schedule C drugs Form 21B
Form 21B⏱ 30–60 days
// 02
Form 21B — Schedule C & X Endorsement

Additional endorsement required for stocking and distributing Schedule C (biologicals, vaccines, insulin, blood products) and Schedule X (habit-forming) drugs. Requires refrigeration and separate record-keeping. Usually held alongside Form 20B.

Schedule CSchedule XVaccinesCold Chain
Apply Now →
AYUSH wholesale licence
AYUSH Wholesale⏱ 45–90 days
// 03
AYUSH Wholesale Licence

For wholesale distribution of Ayurvedic, Unani, Siddha and Homoeopathic drugs. Issued by the State AYUSH Department — separate from the allopathic wholesale licence. Requires a qualified AYUSH competent person.

AYUSH Dept.AyurvedicHomoeopathicState-specific
Apply Now →
C&F agent wholesale licence
C&F Agent⏱ 30–60 days
// 04
C&F Agent / Super Stockist Licence

Clearing & Forwarding agents and super stockists acting on behalf of manufacturers require the same Form 20B/21B wholesale licence. We handle state-specific C&F applications including storage requirements and competent person appointment.

Form 20BC&F AgentSuper StockistState-specific
Apply Now →
Wholesale drug licence renewal
Renewal⏱ 15–30 days
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Annual Renewal & Amendments

Annual renewal of Form 20B/21B wholesale licence. Amendments required for change of competent person, change of premises, addition of drug categories or change in ownership. We track all deadlines and file before expiry.

Annual RenewalCP ChangePremises ChangeOwnership
Apply Now →
Multi-state drug licence
Multi-State⏱ 30–90 days
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Multi-State Wholesale Licence Portfolio

Pharma companies operating across multiple states need a separate wholesale licence for each state's distribution centre or warehouse. We provide bulk application packages with coordinated timelines across multiple states.

Pan-IndiaMultiple DepotsCoordinated FilingBulk Package
Apply Now →
Pre-Conditions

Eligibility & Key Requirements

The State Drug Inspector verifies these requirements before granting the wholesale licence. We audit your readiness before filing to prevent rejection.

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Competent Person Requirements
Graduate + 1 year experience — mandatory
Graduate in pharmacy, medicine, science or chemistry mandatory● Mandatory
Minimum 1 year experience in dealing in drugs required● Mandatory
Must be present during all business hours of the firm● Mandatory
Name, qualification and working hours displayed prominently● Mandatory
Appointment letter and employment agreement from the firm● Mandatory
Locum (substitute) allowed for short absences with intimation● Conditional
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Premises Requirements
Physical warehouse / storage — minimum standards
Minimum 10 sq.m. storage area (state-specific requirements vary)● Mandatory
Ownership or registered lease agreement of premises● Mandatory
Adequate shelving, storage racks and ventilation● Mandatory
Refrigerator (2°C–8°C) for Schedule C drugs if applicable● If Sch. C stocked
Separate locked storage for Schedule H1 and Schedule X drugs● Mandatory
Display board showing licence number, CP name and hours● Mandatory
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Record-Keeping Requirements
Mandatory registers and invoices
Purchase register maintained for all drug purchases from manufacturers● Mandatory
Sales register / invoice for all drug sales with buyer's licence number● Mandatory
Separate register for Schedule H1 drugs — full details mandatory● Mandatory
Separate register for Schedule X drugs with complete details● Mandatory
All registers maintained for minimum 2 years and available for inspection● Mandatory
Cold chain temperature log for Schedule C drugs● If Sch. C
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Sales & Purchase Restrictions
Who you can buy from and sell to
Can purchase drugs only from licensed manufacturers or other licensed wholesalers● Mandatory
Can sell only to licensed retailers, hospitals, clinics and institutions — not to public● Mandatory
Must verify buyer's drug licence before every sale of prescription drugs● Mandatory
Cannot sell Schedule H, H1 or X drugs without prescription / buyer licence● Mandatory
MRP must not be exceeded on any sale — Legal Metrology Act applies● Mandatory
Check expiry date of all drugs before accepting or dispatching● Mandatory
Drug Schedules

Drug Schedules — What Wholesalers Must Know

Different drug schedules impose different obligations on wholesale licence holders — from record-keeping requirements to separate storage and cold chain obligations.

Pharmaceutical warehouse drugs storage
Schedule H

Prescription-Only Drugs

Can only be sold to licensed entities. Separate sales register maintained. Must not be sold over the counter to the public. Label must carry "Rx" symbol and "Not for Sale Without Prescription" warning.

AntibioticsAntihypertensivesSteroids
Schedule H1

Restricted Prescription Drugs

Stricter than H. Separate register with full prescriber and buyer details mandatory. Third-generation antibiotics, anti-TB and ARV drugs fall under H1. Wholesalers must maintain additional documentation per CDSCO guidelines.

3rd-Gen AntibioticsAnti-TBARV Drugs
Schedule X

Habit-Forming / Psychotropic

Separate locked storage mandatory. Separate register with full buyer and consignment details. Stock reconciliation required. Form 21B endorsement needed to stock these products in wholesale.

BenzodiazepinesBarbituratesHypnotics
Schedule C & C1

Biological & Cold Chain Products

Refrigerator (2°C–8°C) mandatory. Daily temperature log required. Separate purchase and sales records. Form 21B endorsement required. Cold chain must be maintained throughout storage and transport.

VaccinesInsulinSeraBlood Products
Schedule G & K

Caution Labels & Exemptions

Schedule G drugs require caution labels on packaging. Schedule K drugs are exempt from certain provisions — primarily vitamins, surgical dressings and some OTC categories. No special wholesale register needed for K.

HormonesVitamins (inj.)OTC Exemptions
Step-by-Step

How to Get a Wholesale Drug Licence

Our 6-step process takes you from premises readiness through Drug Inspector verification to licence grant — across any state in India.

01
Premises & CP Assessment
Week 1
02
Document Compilation
Week 1–2
03
Application Filing
Week 2–3
04
Drug Inspector Visit
Week 3–6
05
Query Resolution
Week 4–8
06
Licence & Renewal
Ongoing
Process step
STEP 01 / 06
Premises & Competent Person Assessment

We review your proposed wholesale premises — checking area, storage capacity, refrigeration (for Sch. C), and the Competent Person's qualifications and experience against state requirements. Prevents rejection at the inspection stage.

Premises area check (min. 10 sq.m.)
Competent Person qualification review
Storage, shelving and refrigeration adequacy
Sch. H1 / X separate storage provision
State-specific requirement check
Gap report with action checklist
1 wk
Duration
₹0
Govt. Fee
Free
Consult
Documentation

Documents Required

The exact checklist varies by state. Below is a comprehensive guide covering the most common state requirements. Select a tab for your scenario.

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Premises & Business Documents
Warehouse / godown / office
01
Application Form 19 (for Form 20B/21B wholesale licence)● Mandatory
02
Ownership deed or registered lease agreement of premises● Mandatory
03
Site plan / floor plan with dimensions and storage layout● Mandatory
04
Municipal trade licence / shop & establishment registration● Mandatory
05
GST registration certificate and PAN card of firm● Mandatory
06
Refrigerator invoice / photo for Schedule C drugs storage● If Sch. C
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Competent Person & Proprietor Documents
Person-specific requirements
01
Graduate degree certificate (B.Sc / B.Pharm / MBBS / B.Com + Science)● Mandatory
02
Experience certificate — 1 year in dealing drugs (employer letter)● Mandatory
03
Appointment letter appointing CP in the wholesale firm● Mandatory
04
Proprietor / partners ID proof and address proof● Mandatory
05
Affidavit — no previous drug licence cancellation or conviction● Mandatory
06
Passport-size photographs of proprietor and competent person● Mandatory
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Annual Renewal Documents
Filed before expiry of licence
01
Renewal application form (state-specific renewal form)● Mandatory
02
Original licence certificate for surrender or endorsement● Mandatory
03
CP's updated qualification and experience evidence (if changed)● Mandatory
04
Renewal government fee payment (varies ₹300–₹2,000 by state)● Mandatory
05
Declaration that premises and CP remain unchanged and compliant● Mandatory
06
GST returns for the year (some states require proof of business activity)● State-specific
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Late Renewal — Additional Documents
If filed after expiry date
01
Late renewal fee / penalty as specified by state authority● Mandatory
02
Affidavit explaining reason for delay in renewal filing● Mandatory
03
Undertaking that no drugs were sold during lapsed licence period● Mandatory
04
Drug Inspector may require fresh premises inspection● Authority discretion
05
Updated premises and CP documents if anything has changed● If changed
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Competent Person Change
Most common amendment type
01
Amendment application form with nature of change stated● Mandatory
02
New CP's degree certificate and experience certificate● Mandatory
03
New CP appointment letter from the firm● Mandatory
04
Relieving letter from previous CP or no-objection● Mandatory
05
Original licence for endorsement● Mandatory
06
Amendment fee as specified by state (₹200–₹1,000)● Mandatory
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Premises Change / Expansion
Relocating or adding storage
01
New premises ownership deed / registered lease agreement● Mandatory
02
Revised site plan of new premises with dimensions● Mandatory
03
No-objection from existing partners / directors (ownership change)● Mandatory
04
Updated Partnership Deed / MOA for reconstituted firm● If applicable
05
Fresh Drug Inspector premises inspection at new location● Usually required
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AYUSH Wholesale Licence Documents
Ayurvedic / Homoeopathic / Unani
01
Application form as per state AYUSH department norms● Mandatory
02
Qualified AYUSH competent person certificate (BAMS/BUMS/BHMS)● Mandatory
03
CP experience in AYUSH drug trading (minimum 1 year)● Mandatory
04
Premises proof and site plan (min. 10 sq.m. typically)● Mandatory
05
Trade licence and GST registration● Mandatory
06
Declaration of compliance with AYUSH drug rules● Mandatory
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Key Differences from Allopathic Licence
AYUSH-specific points
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Issued by State AYUSH Department — not State Drug Controller● Different authority
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AYUSH qualifications (BAMS/BHMS/BUMS) accepted as CP qualification● AYUSH qualified
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Cannot wholesale allopathic drugs under AYUSH licence — separate needed● Important limit
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AYUSH schedules (E1, L, T) apply instead of D&C schedules● Separate schedules
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We assist combined applications (AYUSH + Allopathic) for broad-line distributors● Our service
Mandatory for all
Conditional / situation-specific
Optional / recommended
Fees & Timeline

Wholesale Drug Licence Fees & Timelines

Government fees vary by state and licence type. Below is an indicative guide — we provide state-specific quotes on request.

Licence / ServiceAuthorityApprox. Govt. FeeValidityTimelineForm
Form 20B — New (Allopathic)State Drug Controller₹ 300 – ₹ 3,0001–5 years30–60 daysForm 20B
Form 21B — Sch. C & X EndorsementState Drug Controller₹ 300 – ₹ 2,0001–5 years30–60 daysForm 21B
AYUSH Wholesale LicenceState AYUSH Dept.₹ 500 – ₹ 2,0001–3 years45–90 daysState Form
Annual RenewalState Drug Controller₹ 200 – ₹ 2,0001 year15–30 daysRenewal Form
CP Change AmendmentState Drug Controller₹ 200 – ₹ 1,000N/A7–21 daysAmendment
Premises ChangeState Drug Controller₹ 300 – ₹ 2,000N/A30–60 daysAmendment
Multi-State Package (3+ states)Multiple SDCs₹ 900+ combined1–5 years30–90 daysMultiple Forms
ℹ️
Government fees vary significantly by state. Maharashtra, Karnataka and Delhi tend to have higher fees than smaller states. Contact us for a state-specific fee breakdown. Our professional service fees are separate and quoted based on state and complexity.
Stay Compliant

Compliance Tips for Wholesale Drug Licence Holders

Drug Inspectors conduct surprise visits to wholesale premises. These are the most common compliance failures — stay ahead of them.

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Competent Person Presence

A graduate competent person must be present at the premises during all business hours. Absence during a Drug Inspector visit is the #1 cause of show-cause notices. Have a registered substitute arrangement in place for planned absences.

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Purchase & Sales Registers

All purchase and sales registers must be maintained up to date — including buyer's drug licence number, batch number, expiry date and quantity. Missing or incomplete entries attract penalties. Registers must be retained for 2 years.

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Cold Chain — Schedule C Drugs

Vaccines, insulin, blood products and other Schedule C drugs must be stored at 2°C–8°C with continuous temperature monitoring. Maintain a daily temperature log and ensure power backup for the cold chain refrigerator.

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Separate Storage — Sch. X

Schedule X drugs must be stored in a separate locked cupboard. Keep a complete stock register with reconciliation. Any discrepancy between purchase, sales and stock records attracts serious regulatory action.

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Never Let Licence Lapse

Wholesale operations on an expired licence is equivalent to operating without a licence — a criminal offence. File renewal at least 30 days before expiry. RegPath tracks all renewal dates and files proactively with 45-day advance notice.

Verify Buyer's Licence

Before every supply of Schedule H, H1 or X drugs, verify the buyer's valid retail drug licence. Supplying to unlicensed entities or individuals makes the wholesaler criminally liable. Keep a copy of all buyer licences on file.

Why RegPath

Why Choose RegPath for Your Wholesale Drug Licence?

600+ wholesale drug licences obtained across all Indian states — single depots to 30-state distribution networks. Our all-state expertise means no learning curve, no delays.

Pharmaceutical regulatory expert
99%
Approval Rate
600+
Licences Obtained
🗺️

All-State Drug Controller Expertise

We know every state's specific documents, fees, Drug Inspector preferences and timelines — Maharashtra, Karnataka, Delhi, UP, Tamil Nadu, and 25 more. No learning curve on any state.

30-Day Turnaround — Fastest Possible

Our pre-filled application templates, complete checklists and proactive Drug Inspector follow-up consistently achieve licences faster than average state timelines.

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Pre-Application Premises Audit

We physically or virtually audit your wholesale premises before filing — ensuring the Drug Inspector finds everything in order on the first visit. No re-inspections.

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Multi-State Portfolio Management

For pharma companies with pan-India distribution, we manage simultaneous applications across 5, 10 or 30 states — coordinated timelines, single point of contact, unified reporting.

// Our Track Record (2009–2024)
Form 20B — Wholesale Licence99%
AYUSH Wholesale Licence98%
First-Attempt Inspection Pass95%
Annual Renewal Success Rate100%
FAQs

Wholesale Drug Licence — FAQs

Answers to the most common questions from pharma distributors, C&F agents, stockists and first-time wholesale applicants.

What is the difference between a retail and wholesale drug licence?
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A retail drug licence (Form 20/21) allows selling drugs directly to end consumers — patients and the public. A wholesale drug licence (Form 20B/21B) allows selling drugs in bulk to licensed retailers, hospitals, clinics and institutions — not to the public. A pharmacist (B/D.Pharm) is required for retail, while a graduate with 1 year experience (competent person) is required for wholesale.
Who qualifies as a Competent Person for a wholesale licence?
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A Competent Person for a wholesale drug licence must be a graduate in pharmacy, science, medicine, chemistry, or any other related discipline AND have at least 1 year of experience in dealing in drugs. Unlike retail, a B.Pharm/D.Pharm is not mandatory — a B.Sc with drug trading experience qualifies. The CP must be present during all business hours.
Can I sell drugs directly to patients with a wholesale licence?
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No. A wholesale drug licence does not permit selling drugs directly to the public or patients. Wholesale licences only allow sales to other licensed entities — retailers with a valid retail drug licence, hospitals, government dispensaries, and other licensed wholesalers. Selling to the public under a wholesale licence is an offence under the D&C Act.
Do I need a separate licence for each warehouse or godown?
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Yes. A wholesale drug licence is premises-specific. Each warehouse or distribution centre requires its own Form 20B/21B licence for that specific address. Additionally, if the warehouse is in a different state, a separate state drug licence from that state's drug controller is required. We offer multi-state portfolio packages for companies with multiple distribution centres.
What records must a wholesale drug dealer maintain?
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Wholesale drug dealers must maintain: (1) Purchase register with batch number, expiry date, manufacturer and quantity for every purchase, (2) Sales register with buyer's licence number, batch, expiry and quantity for every sale, (3) Separate Schedule H1 and Schedule X registers with detailed entries, (4) Cold chain temperature log if stocking Schedule C drugs. All records must be retained for at least 2 years.
Can a C&F agent use the manufacturer's drug licence for wholesale operations?
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No. A C&F (Clearing & Forwarding) agent must hold their own wholesale drug licence for the premises from which they store and distribute drugs — even if they are acting as an agent on behalf of a licensed manufacturer. The C&F agent's own Form 20B/21B is required at their specific warehouse premises. We handle C&F agent licence applications across all states.
What happens if my competent person resigns?
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If your competent person resigns, you must immediately stop wholesale operations if you do not have a qualified substitute available. Notify the State Drug Controller and file an amendment application to update the competent person details once a new one is appointed. Operating without a competent person — even briefly — is an offence. We handle emergency CP change amendments on priority.
How long is a wholesale drug licence valid and when should I renew?
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Validity varies by state — most states issue wholesale licences valid for 1 to 5 years. Renewal must be filed before expiry. Filing late attracts a penalty and the licence may lapse — making continued operations illegal. RegPath tracks all renewal deadlines and sends alerts 45 days in advance, then files renewals proactively so your operations are never interrupted.

Get Your Wholesale Drug Licence
— Any State, Fast

Book a free consultation. We'll check your premises readiness, competent person eligibility and give you a state-specific roadmap — at zero cost.

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Head OfficeConnaught Place, New Delhi — 110001, India
✉️
Emailinfo@regpathcdso.in — Response within 24 hours
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Call / WhatsApp+91 98100 00000 — Mon–Sat, 9AM–6:30PM IST
Response TimeFree consultation scheduled within 24 hours