Medical Device Manufacturing · Class A & B · MD5 License · MDR 2017 · 2026

CDSCO Registration for PPE in India 2026 — Complete Guide

Everything you need to obtain CDSCO registration for personal protective equipment (PPE) in India — market opportunity, Class A and B classification under MDR 2017, the MD5 manufacturing license, the complete document checklist, the 8-step SUGAM application process, and how Rego Services supports PPE manufacturers from classification through license grant.

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Device Category:PPE — Class A & Class B
License Required:MD5 (Form MD3) · State Licensing Authority
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Personal protective equipment (PPE) is regulated as a medical device in India under CDSCO's Medical Devices Rules, 2017. Most PPE products — including examination gloves, face shields, surgical gowns, surgical caps, goggles, and protective clothing — are classified as Class A or Class B medical devices. To manufacture PPE in India, a company must obtain the CDSCO MD5 manufacturing license, applied via Form MD3 on the SUGAM portal (cdscoonline.gov.in) to the State Licensing Authority (SLA) of the state in which the facility is located — not the Central Licensing Authority, because PPE is primarily Class A and B. The MD5 license has indefinite validity, subject to a retention fee payable every 5 years. CDSCO mandates that PPE manufacturers be ISO 13485 certified. Mandatory documents include the Device Master File, Plant Master File, ISO 13485 certificate, Certificate of Analysis for 3 consecutive batches, facility layout, and personnel records. The government application fee is Rs. 5,000 for Class A/B manufacturing license applications.

The COVID-19 pandemic transformed India's relationship with personal protective equipment manufacturing. Before the pandemic, India was almost entirely import-dependent for PPE. Within sixty days of the national health emergency, India mobilised manufacturing capacity to produce approximately four lakh PPE units per day, ultimately becoming the second-largest PPE manufacturer in the world. That industrial transformation — built on accessible raw materials, competitive production costs, and rapidly scaled manufacturing capability — did not reverse when the pandemic subsided. It created the foundation for a thriving, permanent domestic PPE manufacturing sector.

For companies looking to enter or expand in India's PPE manufacturing sector in 2026, the commercial environment remains strong. Global demand for PPE continues to grow, driven by rising healthcare worker populations, expanding surgical volumes, increasing awareness of infection prevention, and sustained international procurement from healthcare systems across Africa, Southeast Asia, and the Gulf. And with India's regulatory framework now firmly in place — PPE has been classified as a medical device under the Medical Devices Rules, 2017, and a valid CDSCO manufacturing license is required to manufacture, sell, or distribute PPE in India — the market rewards manufacturers who understand and meet the compliance requirements from the outset.

What This Guide Covers What PPE is and how it is classified in India, the market opportunity for PPE manufacturing in 2026, CDSCO Class A and Class B classification under MDR 2017, the MD5 manufacturing license pathway, the complete document checklist, the 8-step SUGAM application process, license validity and retention requirements, and how Rego Services supports PPE manufacturers through the complete licensing journey.

What Is Personal Protective Equipment?

Personal protective equipment (PPE) encompasses a wide range of devices and garments designed to minimise or prevent the wearer's exposure to biological, chemical, radiological, electrical, and mechanical hazards. In healthcare settings, PPE serves two distinct protective functions: it shields healthcare professionals from biological agents — including bloodborne pathogens, respiratory viruses, and drug-resistant bacteria — and it protects patients from contamination introduced by healthcare workers during procedures. This dual protective role makes PPE a fundamental infection prevention tool across virtually every clinical environment, from primary care consultations to high-acuity surgical theatres and intensive care units.

Common healthcare PPE includes gloves (examination and surgical), surgical and isolation gowns, surgical drapes, face masks, N-95 respirators, face shields, goggles, surgical caps, shoe covers, protective clothing for handling biohazardous materials, and specialised items such as radiation protection gloves and goggles for radiology and nuclear medicine settings. PPE protects against transmission routes including person-to-person contact, respiratory droplets, airborne particles, and contaminated surfaces. The specific hazard profile of a given clinical environment determines which PPE type, specification, and quality level is appropriate — and these distinctions map directly to the CDSCO product classification and quality requirements that govern PPE manufacturing in India.

Why PPE Quality Standards Matter in Manufacturing PPE that fails in clinical use does not merely represent a product quality issue — it represents a patient safety failure and a direct risk to the healthcare workers who depend on it. A surgical glove with substandard barrier properties, a face shield that fogs under normal use, or a gown with inadequate fluid resistance can all contribute to healthcare-associated infections, pathogen transmission, and adverse patient outcomes. This is the patient and worker safety reality that underpins CDSCO's decision to regulate PPE as medical devices under MDR 2017, and the quality standard — backed by ISO 13485-certified quality management systems and rigorous product testing — that every Indian PPE manufacturer must build their operations to satisfy.

Market Opportunity for PPE Manufacturing in India 2026

The global PPE market is expected to reach USD 92.5 billion in the near future, driven by expanding healthcare infrastructure worldwide, the sustained post-pandemic institutionalisation of infection prevention protocols, and the growth of surgical volumes in emerging economies. India sits at the centre of several of these trends simultaneously — as a major domestic consumer of PPE, as the world's second-largest PPE manufacturing base, and as an increasingly significant global supplier of affordable, high-quality protective equipment.

Class A/B
CDSCO classification — MD5 license from the State Licensing Authority, with straightforward regulatory pathway for manufacturers meeting GMP and ISO 13485 standards
Indefinite
License validity with 5-year retention fee — no periodic full renewal once the MD5 is granted by the SLA
Growing
Demand driven by expanding surgical volumes, infection prevention mandates, healthcare worker population growth, and global export opportunities
🏥
Expanding Healthcare Infrastructure

Ayushman Bharat, PM-JAY, and state-level hospital development programmes are adding thousands of hospital beds and primary care facilities across India. Each new clinical facility requires ongoing PPE procurement across gloves, gowns, masks, and protective accessories. Domestically manufactured PPE with valid CDSCO MD5 licenses is well-positioned for government and institutional procurement at scale.

🌍
Export to Emerging Healthcare Markets

India's cost-competitive manufacturing base, combined with the credibility of CDSCO compliance and ISO 13485 certification, positions Indian PPE manufacturers strongly for export to healthcare markets in Africa, Southeast Asia, the Gulf, and Central Asia. These markets have large and growing healthcare worker populations and sustained demand for affordable, certified protective equipment.

🇮🇳
Make in India and Domestic Preference

Government procurement preferences for domestically manufactured medical devices, combined with the institutional memory of import disruption during the COVID-19 pandemic, create structural advantages for Indian PPE manufacturers who hold valid CDSCO licenses. Public sector hospitals, medical colleges, and government health programmes represent reliable, large-volume procurement channels.

🔬
Surgical Volume Growth

India's growing surgical volume — driven by the expansion of surgical oncology, cardiac surgery, orthopaedic procedures, and minimally invasive surgery — drives per-procedure PPE consumption. Each surgical case consumes multiple units of sterile gloves, drapes, surgical gowns, and protective equipment. As surgical volumes grow, the demand for sterile Class B PPE grows with them.

🧬
Infection Prevention Institutionalisation

Post-pandemic, infection prevention and control (IPC) programmes have been strengthened across Indian healthcare facilities at all levels. This has permanently increased baseline PPE consumption by mandating higher-grade protective equipment for a wider range of clinical activities. The institutionalisation of IPC protocols means PPE demand is now less cyclical and more structurally embedded in healthcare operations.

⚗️
Specialised PPE Segments

Beyond standard clinical PPE, specialised protective equipment for laboratory environments, radiation protection, biohazard handling, and industrial healthcare settings represents growing niche segments. Radiation protection gloves and goggles, biosanitizer products, and chemotherapy-handling protective equipment all fall within CDSCO's PPE classification, offering differentiated product opportunities for manufacturers with relevant technical capabilities.

CDSCO Classification of PPE Products

Under the Medical Devices Rules, 2017, CDSCO classifies medical devices — including PPE — into four risk classes: A (lowest), B (low-to-moderate), C (moderate-to-high), and D (highest). Most PPE products are classified as Class A or Class B medical devices. The classification reflects each product's risk profile — specifically the consequences of failure for the patient, the healthcare worker, or both — and determines the licensing authority and application pathway applicable to the manufacturer.

PPE Product CDSCO Class Risk Level License Required Licensing Authority
Non-latex / Latex medical examination glove Class A Low MD5 (Form MD3) State Licensing Authority
Surgical gown (Non-Sterile), Isolation gown (Non-Sterile) Class A Low MD5 (Form MD3) State Licensing Authority
Face shield, Surgical cap, Patient gown, Surgical helmet Class A Low MD5 (Form MD3) State Licensing Authority
Radiation protection mitten, Radiation face protector Class A Low MD5 (Form MD3) State Licensing Authority
Chemotherapy spill clean-up kit, Medical / Cadaver body bags Class A Low MD5 (Form MD3) State Licensing Authority
Isolation gown (Sterile), Surgical drape and drape accessories Class B Low-to-moderate MD5 (Form MD3) State Licensing Authority
Latex and non-latex surgical glove (Sterile) Class B Low-to-moderate MD5 (Form MD3) State Licensing Authority
Protective clothing, Facemasks, Goggles, Helmets Class B Low-to-moderate MD5 (Form MD3) State Licensing Authority
Biosanitizer for medical devices Class B Low-to-moderate MD5 (Form MD3) State Licensing Authority

The complete CDSCO schedule of PPE products covers approximately 32 distinct product types across Class A and Class B. Manufacturers should confirm the specific classification of their product against the current CDSCO schedule before committing to the application pathway. The most significant regulatory consequence of the Class A/B classification is that the State Licensing Authority (SLA) — not the Central Licensing Authority — is responsible for issuing the MD5 manufacturing license. The applicable SLA is the authority of the state in which your manufacturing facility is located.

Confirm classification before beginning your application: Not every product marketed as "PPE" falls neatly into the Class A or B schedule. If your product incorporates antimicrobial coating, electronic elements (such as powered air-purifying respirators), or is specifically intended for use in nuclear or radiological settings, additional regulatory considerations may apply. Confirm the CDSCO classification of your specific product configuration and verify whether all components are included in the product schedule before selecting the license pathway and preparing documents.

CDSCO License for PPE Manufacturing

PPE manufacturing in India requires the MD5 manufacturing license, which applies to Class A and Class B medical devices. This license is applied for on Form MD3 through the SUGAM portal and is issued by the State Licensing Authority of the state in which the manufacturing facility is located. The MD5 license covers both Class A and Class B products — manufacturers producing multiple PPE product types at a single facility can include all products in a single MD5 application, with each product declared separately.

Lower Risk — Non-Sterile PPE
Class A PPE — MD5 License
CDSCO ClassClass A
License TypeMD5
Application FormForm MD3 on SUGAM
Issuing AuthorityState Licensing Authority
Application FeeRs. 5,000
ExamplesExam gloves, face shields, surgical caps, non-sterile gowns
ValidityIndefinite (5-yr retention fee)
Low-to-Moderate Risk — Sterile PPE
Class B PPE — MD5 License
CDSCO ClassClass B
License TypeMD5
Application FormForm MD3 on SUGAM
Issuing AuthorityState Licensing Authority
Application FeeRs. 5,000
ExamplesSterile surgical gloves, surgical drapes, sterile gowns, facemasks
ValidityIndefinite (5-yr retention fee)
Class B Sterile PPE — Additional Technical Requirements Sterile PPE products — including sterile surgical gloves, sterile isolation gowns, and sterile surgical drapes — carry additional technical documentation requirements compared to non-sterile Class A products. The Device Master File for sterile PPE must address sterile packaging validation, sterilisation process development and validation (including the sterilisation method — EtO, gamma, e-beam — dose setting, and routine control), and biocompatibility assessment under ISO 10993 where the product contacts patient tissue. Manufacturers producing both sterile and non-sterile PPE at the same facility can cover all products under a single MD5 license, but the DMF must contain product-specific sections addressing the sterility requirements for each sterile product in the portfolio.

License Validity and Retention Fee

The CDSCO MD5 manufacturing license for PPE is issued with indefinite validity — it does not expire on a fixed calendar date. This provides long-term regulatory stability for PPE manufacturers who build production operations around the license.

License Validity and Retention

The MD5 PPE manufacturing license remains in force indefinitely from the date of grant. However, a license retention fee must be paid every 5 years to maintain the license in active status. Failure to pay the retention fee before the due date can result in the license lapsing — requiring a fresh application with the complete document set. Rego Services recommends maintaining a compliance calendar with the retention fee due date and initiating the payment process at least 60 days ahead of the deadline to avoid any disruption to manufacturing authorisation.

Document Checklist for CDSCO PPE Manufacturing License

The document set required for the CDSCO MD5 PPE manufacturing license is defined under the Medical Devices Rules, 2017. Every document below must be current, accurate, and internally consistent before the SUGAM application is submitted. For PPE manufacturers producing multiple products or product variants, the Device Master File must contain product-specific sections for each declared product, while the Plant Master File covers the shared manufacturing facility infrastructure.

  • Cover letter — Addressed to the State Licensing Authority, referencing Form MD3, and clearly identifying the PPE product(s) applied for, the applicant entity, and the manufacturing facility address. For multi-product applications, include a concise product list with CDSCO classification confirmed for each item.
  • Device Master File (DMF) — The technical product dossier for each PPE product declared: device description and intended use, materials specification (including latex content declaration where applicable), manufacturing process description and flow diagram, design and performance specifications, product testing data against applicable standards (including EN or ISO test standards for barrier performance, tensile strength, particle count, fluid resistance, etc.), risk management records under ISO 14971, labelling and Instructions for Use, and post-market surveillance plan. For sterile products: sterile packaging validation and sterilisation process validation records.
  • Plant Master File (PMF) — The manufacturing facility documentation: premises description and dimensioned layout, equipment list and calibration records, manufacturing process flows, environmental controls (cleanroom class where applicable for sterile products), quality management system overview, incoming material inspection procedures, in-process and finished-product quality control, personnel structure and competency records, and GMP compliance infrastructure documentation.
  • Constitution proof — GST registration certificate, Certificate of Incorporation (CIN), Memorandum and Articles of Association (MOA/AOA), or equivalent documents establishing the legal identity of the applicant company.
  • Sale Deed or Rent / Lease Deed — Valid documentary evidence confirming the applicant's legal right to occupy the manufacturing premises declared in the application.
  • Organisation identity proof — UDYAM Aadhaar, PAN card, or equivalent document establishing the applicant organisation's identity.
  • Certificate of Analysis for 3 consecutive production batches — Laboratory analysis and performance test results demonstrating that three sequential production batches of each PPE product consistently meet all declared specifications. For manufacturers not yet in commercial production, these batches must be produced under a valid CDSCO test license (MD13) before the MD5 application can proceed.
  • Dimensioned building layout — A scaled, dimensioned floor plan of the manufacturing facility showing all rooms, their dimensions, equipment locations, production flow, personnel access routes, and — for sterile PPE — cleanroom zones and gowning areas. The layout must reflect the facility exactly as it exists at the time of submission.
  • ISO 13485 Certificate — A current, valid ISO 13485 certificate from an IAF-accredited certification body, with scope explicitly covering the manufacturing activities for PPE products at the declared facility. For sterile PPE manufacturers, the scope should specifically include sterile medical device manufacturing.
  • Audit reports — Internal and external audit records demonstrating the functioning of the quality management system at the manufacturing facility, including corrective action records where applicable.
  • Fire NOC — No-Objection Certificate from the local fire authority for the manufacturing premises.
  • Pollution NOC — No-Objection Certificate from the State Pollution Control Board for the manufacturing facility.
  • Qualified personnel documentation — Curriculum vitae, educational qualifications, appointment letters, and training records for key technical personnel, including the technical head and persons responsible for quality control and post-market surveillance.

Additional documents for sterile Class B PPE:

  • Sterilisation validation records — Evidence of sterilisation process development, dose-setting studies (for radiation sterilisation) or cycle development (for EtO sterilisation), and routine biological indicator monitoring, in line with ISO 11135 (EtO), ISO 11137 (radiation), or other applicable sterilisation standards.
  • Sterile packaging validation records — Seal integrity and packaging system validation demonstrating that the sterile barrier is maintained throughout the intended shelf life, in line with ISO 11607.
  • Biocompatibility testing (where applicable) — For sterile PPE in direct patient contact, risk-based biocompatibility assessment under ISO 10993, including cytotoxicity, sensitisation, and skin irritation testing where contact conditions warrant.
Device Master File for PPE — Prepare Product-Specifically A common error in PPE MD5 applications is submitting a generic Device Master File that does not address the specific test standards and performance requirements for each declared product. A non-latex examination glove and a sterile surgical gown have different applicable standards, different barrier performance metrics, and — in the case of the sterile gown — different sterilisation and packaging validation requirements. Prepare product-specific DMF sections for each product in the application, and ensure that the Certificate of Analysis test data references the same standards described in the DMF. Cross-document inconsistencies in PPE applications are the most common source of SLA queries.

8-Step SUGAM Application Process for CDSCO PPE Manufacturing License

All CDSCO medical device manufacturing license applications are submitted through the SUGAM online portal at cdscoonline.gov.in. For Class A and Class B PPE products, the application is directed to the State Licensing Authority of the state in which the manufacturing facility is located. The MD5 application for PPE manufacturing follows eight structured steps.

1
Confirm PPE Classification and Identify Correct SLA

Before creating your SUGAM application, confirm the CDSCO class (A or B) of each PPE product you intend to manufacture against the current CDSCO PPE schedule. Confirm that your application is directed to the State Licensing Authority of the state in which your facility is located — a common error is misdirecting PPE applications to the CLA, which handles Class C and D devices. If you are manufacturing products spanning both Class A and B, confirm all can be covered under a single MD5 application.

2
Portal Login and Account Verification

Sign in or create a company account at cdscoonline.gov.in. Verify that all portal registration details — company name, address, GST number — exactly match the identity documents to be submitted with the application. For PPE manufacturers that may have previously used the portal for other device applications, confirm that the account is associated with the correct legal entity and the correct manufacturing facility address for this application.

3
Complete Form MD3

Fill the MD3 application form on the SUGAM portal with full accuracy. Required information includes: device classification (Class A or B), brand name for each product, intended use statements (which must match the Device Master File exactly), and detailed product descriptions including material composition, sterile or non-sterile status, and applicable performance standards. For multi-product applications, complete a separate product entry for each PPE type. Every field must match the corresponding supporting document — pay particular attention to intended use statements, which are frequently a source of SLA queries when they are too broad or inconsistent with the DMF.

4
Prepare and Upload All Supporting Documents

Upload every document from the checklist above in the required file format and within the SUGAM portal's size specifications. Conduct a thorough cross-consistency review before upload: each product's intended use in Form MD3 must match the DMF, the manufacturing process described in the DMF must match the PMF, facility layout dimensions must be consistent with the physical premises, and all personnel listed in the PMF must have corresponding qualification records. For sterile products, confirm that sterilisation validation records reference the same sterilisation method, parameters, and equipment described in the PMF and DMF. Confirm that the ISO 13485 certificate scope covers all declared products and manufacturing activities.

5
Pay the Application Fee

Pay the applicable government fee through the SUGAM portal's integrated payment system. For Class A and Class B manufacturing license applications, the fee is Rs. 5,000. Retain the digital payment receipt and application reference number. Fee payment formally submits the application — prior to payment, it remains in draft status and has not been received by the State Licensing Authority for review. Confirm the current fee schedule with your regulatory consultant before payment, as schedules are subject to revision.

6
Receive Application Reference Number

On successful submission and fee payment, SUGAM generates an application reference number confirming your submission is in the SLA's queue. Retain this number for all correspondence and for tracking application status on the portal. Monitor SUGAM regularly after submission — SLA notifications and query communications are delivered through the portal, and timely responses to queries are essential for maintaining application momentum and avoiding unnecessary delays.

7
Application Review and Facility Inspection

The State Licensing Authority reviews the application and all submitted documents. The SLA review for PPE typically includes document verification — checking completeness of the DMF and PMF, confirming ISO 13485 certificate scope, and reviewing batch CoA data against declared specifications — and a facility inspection to verify GMP compliance, equipment availability, manufacturing process execution, and personnel qualifications. For sterile PPE, the inspection will specifically cover cleanroom environments, sterilisation equipment and controls, and sterile packaging and labelling operations. Respond to any SLA queries promptly and thoroughly through the SUGAM portal.

8
License Grant

Once all documentation, query responses, and inspection requirements are satisfied, the State Licensing Authority grants the MD5 manufacturing license for PPE. The license is issued on SUGAM, specifying each declared product, the manufacturing site, and the license holder. Review the license details carefully — confirm that every product name and description, the facility address, and the applicant entity name are all accurate before commencing commercial production. Any errors in the issued license should be flagged to the SLA immediately for correction, as these affect downstream compliance obligations.

Common Application Challenges and How to Overcome Them

Challenge 01
Generic Device Master Files

The most frequent documentation gap in PPE applications is a Device Master File that describes PPE generically rather than product-specifically. SLAs query applications where the DMF does not identify the applicable test standards for each product type, where performance specifications are stated without corresponding test data, or where the manufacturing process description does not match the actual production workflow at the facility. Prepare a product-specific DMF section for each PPE type in the application, with test data referenced to the exact product and batch declared in the Certificate of Analysis.

Challenge 02
ISO 13485 Scope Gaps

ISO 13485 certificates that cover a facility's manufacturing activities in general terms, without specifically mentioning PPE or the relevant product categories, generate SLA queries. For sterile PPE manufacturers, the scope must explicitly include sterile medical device manufacturing. Before submitting the MD5 application, review the ISO 13485 certificate scope statement against each product declared in Form MD3 and confirm the scope unambiguously covers all declared products at the manufacturing facility.

Challenge 03
Insufficient Sterility and Packaging Records

For Class B sterile PPE, inadequate sterilisation validation records — particularly for EtO processes where bioburden, dose-mapping, and biological indicator data must be documented — are a consistent source of SLA observations. Applications that reference a sterilisation method without providing the validation basis, or that submit packaging validation records that do not cover the full range of pack sizes and configurations, attract substantive technical queries. Engage a sterilisation validation specialist during DMF preparation, not after receiving SLA observations.

Challenge 04
Facility Inspection Discrepancies

Common observations during SLA facility inspections for PPE manufacturing include: facility layout that does not match the submitted building plan, equipment not present at the time of inspection that was listed in the PMF, personnel records that are incomplete or not available for review, and quality control testing procedures that differ from those described in the DMF. Conduct a rigorous pre-inspection internal audit using the PMF and DMF as the inspection checklist. Ensure every document referenced in the application files is physically available at the facility before the inspection date.

How Rego Services Supports PPE Manufacturers

Rego Services Private Limited provides end-to-end regulatory support for PPE manufacturers seeking the CDSCO MD5 license across Class A and Class B product categories — from examination gloves and surgical gowns to sterile drapes and specialist protective equipment. Our regulatory team understands the specific document requirements and SLA review patterns for PPE applications, and has experience supporting manufacturers through the complete licensing process for both non-sterile and sterile PPE.

  • Device classification confirmation — We confirm the CDSCO class of each PPE product in your portfolio, identify the correct SLA, and assess whether any product configurations trigger special classification considerations or additional regulatory requirements beyond the standard MD5 pathway.
  • ISO 13485 certification coordination — If ISO 13485 is not yet in place, we support the full certification process — QMS gap analysis, documentation development, implementation support, and certification body liaison — with scope language specifically covering PPE manufacturing activities, including sterile manufacturing where relevant.
  • Device Master File preparation — We prepare CDSCO-compliant Device Master Files for all PPE product types — incorporating product description, materials specification, intended use, manufacturing process, risk management records under ISO 14971, applicable product standard compliance data, labelling and Instructions for Use, and post-market surveillance plan. For sterile products, we include sterilisation and packaging validation documentation.
  • Plant Master File preparation — We prepare Plant Master Files that accurately describe your manufacturing facility — including equipment records, manufacturing process flows, quality control procedures, environmental monitoring (cleanrooms for sterile products), personnel qualifications, and GMP infrastructure documentation in the format SLA reviewers expect.
  • Document consistency review — Before any submission, we conduct a full cross-document consistency review — ensuring Form MD3, the DMF, the PMF, ISO 13485 certificate scope, and batch records are all internally aligned, cross-referenced correctly, and consistent with the physical facility and declared products.
  • SUGAM portal submission management — We manage the complete portal submission process — account verification, form completion for each product, document upload, fee payment coordination, and formal submission — eliminating procedural errors that delay the SLA review clock starting.
  • SLA query response and inspection preparation — We draft and coordinate SLA query responses for PPE applications, and prepare the facility, personnel, and documentation for the SLA facility inspection — including mock inspection exercises that reflect SLA inspection patterns for Class A and B medical device manufacturers.
  • Post-grant compliance — We support ongoing license compliance — retention fee scheduling, post-market surveillance obligations, adverse event reporting, and license variation applications when new PPE products or variants are added to the license.

Frequently Asked Questions

Can I manufacture both Class A and Class B PPE products under a single MD5 license?

Yes. A single MD5 license can cover multiple PPE products across both Class A and Class B, provided each product is declared in the Form MD3 application and the Device Master File contains a product-specific section for each declared product. Adding a new PPE product after the initial license is granted requires a variation application to the State Licensing Authority — this involves submitting a product-specific DMF section and batch Certificate of Analysis for the new product, and paying the applicable variation fee. It does not require a new full license application.

What is the difference between MD5 for PPE and MD9 for higher-risk medical devices?

The MD5 license applies to Class A and Class B medical devices (including most PPE) and is issued by the State Licensing Authority (SLA) of the state where the facility is located. The MD9 license applies to Class C and Class D devices and is issued by the Central Licensing Authority (CLA) at CDSCO Headquarters. The MD5 application fee (Rs. 5,000) is significantly lower than the MD9 fee (Rs. 50,000), and the SLA review process — while rigorous — is less intensive than the CLA process for higher-risk devices. PPE manufacturers should confirm their specific products are Class A or B before assuming the MD5 pathway applies.

What standards apply to PPE testing for the CDSCO license application?

Applicable standards depend on the specific PPE product. Common standards referenced in CDSCO PPE applications include EN 455 series (medical gloves), ISO 10282 (sterile single-use surgical rubber gloves), EN 13795 (surgical drapes and gowns), EN 14683 (medical face masks), BIS standards for equivalent Indian specifications, and ISO 10993 for biocompatibility where products contact patient tissue. Test reports must be from accredited testing laboratories and must demonstrate compliance with the specific product standards declared in the Device Master File. Rego Services advises on applicable standards for each PPE product category as part of the DMF preparation process.

Does the CDSCO PPE license cover export as well as domestic sale?

The CDSCO MD5 manufacturing license authorises the manufacture of PPE products for distribution in India. For export, additional requirements depend on the destination market — including regulatory clearance from the importing country's authority, Free Sale Certificate (issued in India by CDSCO), and compliance with the applicable product standards of the export market. Rego Services can advise on export regulatory pathways for PPE manufacturers who wish to develop international markets alongside their Indian operations.

✓ Key Takeaways

  • PPE products in India are regulated as medical devices under CDSCO's Medical Devices Rules, 2017 — a valid MD5 manufacturing license is mandatory before any PPE is manufactured for sale or distribution in India
  • Most PPE is classified as Class A or Class B — examination gloves, face shields, non-sterile gowns, and surgical caps are typically Class A; sterile surgical gloves, sterile gowns, surgical drapes, and facemasks are typically Class B
  • The MD5 license is issued by the State Licensing Authority (SLA) of the state in which the facility is located — not the Central Licensing Authority, which handles Class C and D devices
  • Application is made via Form MD3 on the SUGAM portal (cdscoonline.gov.in) with a government fee of Rs. 5,000
  • A valid ISO 13485 certificate from an IAF-accredited body with scope covering PPE manufacturing is mandatory — CDSCO mandates this for all PPE manufacturers
  • The Device Master File must be product-specific — including applicable test standards, performance data, risk management records, and — for sterile PPE — sterilisation and packaging validation documentation
  • A Certificate of Analysis for 3 consecutive production batches is required; first-time manufacturers need an MD13 test license to produce these batches before submitting the MD5 application
  • The MD5 license has indefinite validity, subject to a retention fee payable every 5 years
  • A single MD5 license can cover multiple PPE products across Class A and B — new products added after license grant require a variation application
  • India's expanding healthcare infrastructure, global export opportunity, Make in India policy, and growing surgical volumes create a strong commercial case for domestic PPE manufacturing in 2026

Your Next Step

Starting or expanding a PPE manufacturing business in India in 2026 offers a compelling combination of strong domestic demand, meaningful export opportunity, and a regulatory pathway — the CDSCO MD5 license under MDR 2017 — that is navigable for manufacturers who approach it with proper preparation. The commercial fundamentals are sound: India's healthcare infrastructure is expanding, surgical volumes are rising, infection prevention mandates have permanently elevated PPE consumption, and government procurement channels reward domestically licensed manufacturers.

The most consistent differentiator between PPE manufacturers who license efficiently and those who face extended delays is documentation quality — specifically, the completeness and product-specificity of the Device Master File and the accuracy of the cross-document consistency between Form MD3, the DMF, the PMF, and the Certificate of Analysis. These are preparation challenges, not inherent complexity in the regulatory framework itself. With the right support, the PPE MD5 license application is a manageable process with a predictable outcome.

Rego Services has supported medical device manufacturers across India through the CDSCO licensing process for Class A and Class B devices. Our regulatory team understands what State Licensing Authorities look for in PPE applications, where documentation gaps most commonly arise, and how to prepare an application — and a facility — that moves through SLA review without unnecessary query cycles or inspection re-visits.

Contact Rego Services today to confirm your PPE product classification, map your MD5 licensing pathway, and receive a timeline-specific regulatory plan tailored to your product range, facility, and commercial goals.

📅 Last Updated: June 2026  |  ✓ Regulation: Medical Devices Rules, 2017  |  Source: MDR 2017, CDSCO SUGAM Application Guidelines, CDSCO PPE Product Schedule  |  Published by Rego Services Private Limited