Drug

regulatory services

NKG team has a cumulative experience of more than 50 Years in Regulatory affairs. Over years, our experts have been providing exhaustive regulatory services for registration, manufacturing and marketing permissions of drug products in India.

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definitionS of

DRUG

  • All medicines for internal or external use of human beings or animals and all substances intended to be used for or in the diagnosis, treatment, mitigation or prevention of any disease or disorder in human beings or animals, including preparations applied on the human body for the purpose of repelling insects like mosquitoes. 
  • Such substances (other than food) intended to affect the structure or any function of the human body or intended to be used for the destruction of [vermin] or insects which cause disease in human beings or animals, as may be specified from time to time by the Central Government by notification in the Official Gazette. 
  • All substances intended for use as components of a drug including empty gelatin capsules
What is a “new drug”? 

A new drug means; 

  • drug, including active pharmaceutical ingredient or phytopharmaceutical drug, which has not been used in the country to any significant extent has not been approved as safe and efficacious by Central Licencing Authority (CLA) i.e. DCG(I) with respect to its claims; or 
  • drug approved by the CLA for certain claims and proposed to be marketed with modified or new claims including indication, route of administration, dosage and dosage form; or
  • a fixed dose combination of two or more drugs, approved by CLA separately for certain claims and proposed to be combined for the first time in a fixed ratio, or where the ratio of ingredients in an approved combination is proposed to be changed with certain claims including indication, route of administration, dosage and dosage form; or
  • a modified or sustained release form of a drug or novel drug delivery system of any drug approved by the Central Licencing Authority; or 
  • a vaccine, r-DNA derived product, living modified organism, monoclonal antibody, stem cell derived product, gene therapeutic product or xenografts, intended to be used as a drug.

A new drug which is a modified or sustained release form of a drug or Novel Drug Delivery System (NDDS) of any drug approved by the Central Licencing Authority; or a vaccine, recombinant Deoxyribonucleic Acid (r-DNA) derived product, living modified organism, monoclonal antibody, stem cell derived product, gene therapeutic product or xenografts, intended to be used as drug shall continue to be a new drug forever. However, new drugs covered other than above categories shall be considered as a new drug for a period of 4 years of their approval by the CLA.

What is an “investigational new drug ( IND)” 

An “investigational new drug (IND)” means a new chemical or biological entity or substance that has not been approved for marketing as a drug in any country.

What is a “subsequent new drug”? 

A subsequent new drug means a drug approved by the Central Licencing Authority for certain claims and proposed to be marketed with modified or new claims including indication, route of administration, dosage and dosage form. A subsequent new drug also includes a new drug already approved in the country

What is an “orphan drugs”? 

An “orphan drug” means a drug intended to treat a condition which affects not more than 5 lakh persons in India.

INTRODUCTION TO

drugs

In India, import, manufacturing, sale, and distribution of drugs are regulated under the Drugs and Cosmetics Act 1940 and Rules 1945. At present, bulk drugs (active pharmaceutical ingredients) and finished formulations are regulated under the said Act. Any substance falling within the definition of a drug (Section 3b of the Act) is required to be registered before import into the country. Not only drugs themselves, but the actual manufacturing site manufacturing the drug product also needs to be registered for import. 

The application for registration certificate and import license can be made as per the requirements of Rule 24(A) & 24 of Drugs & Cosmetics Rules 1945 to the Licensing Authority under the Act, i.e., to the Drugs Controller General (I) at CDSCO, FDA Bhawan, Kotla Road, Near Bal Bhawan, New Delhi, by the local authorized agent of the foreign manufacturer having either a manufacturing or sale license or by the foreign manufacturers having a wholesale license in the country through the online portal of CDSCO, i.e., “SUGAM.”.

The import of drugs into India is regulated under Chapter III of the Drugs & Cosmetics Act 1940 and Part IV of the Drugs & Cosmetics Rules 1945. 

Notification of New Drugs and Clinical trial Rules 2019

Effective March 19, 2019, the Ministry of Health and Family Welfare (MoHFW) has published the New Drugs and Clinical Trials Rules, 2019. These new rules will apply to all new drugs, investigational new drugs for human use, clinical trials, bioequivalence studies, bioavailability studies, and the Ethics Committee.

The rules will apply to all new drugs, investigational new drugs for human use, clinical trial, bioequivalence study, bioavailability study and Ethics Committee. The new rules will supersede Part XA and Schedule Y of Drugs and Cosmetics Rules, with immediate effect. 

If there is any inconsistency between these rules and any other rule made under the Drugs & Cosmetics Act, the provisions of these rules shall prevail over such other rules. Actions taken according to the existing rules [Drugs & Cosmetics Rules, 1945] shall continue to be in effect and valid. This means existing licenses, orders, directions will continue to remain valid.

Regulations for Import and registration of Drugs will remain the same as per earlier Registrations.

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overview of various

FORMS & FEES

Clear regulatory strategy and understanding of the regulatory framework of Drugs as per Drugs & Cosmetics Act 1940 is very important for successful approvals from the Licensing Authority. NKG experts work closely with Importers & Manufacturers in preparing and filing activities of regulatory dossiers. Needless to say, Our team has been an asset to our clients.

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Form Applied form
Approval Recieved form
Fees
CDSCO
SLA
1 Form 8
Application For Licence To Import Drugs (Excluding Those Specified In Schedule X) To The Drugs And Cosmetics Rules, 1945
Form 10
Licence To Import Drugs (Excluding Those Specified In Schedule X) To The Drugs And Cosmetic Rules, 1945
Rs.10000/- For One Product
Rs.1000/- For Additional Product
 
2 Form 8A
Application For Licence To Import Drugs Specified In Schedule X To The Drugs And Cosmetics Rules, 1945
Form 10A
Licence To Import Drugs Specified In Schedule X To The Drugs And Cosmetics Rules, 1945
Rs.10000/- For One Product
Rs.1000/- For Additional Product
 
3 Form 40
Application To Import Drugs
Form 41
License To Import Drugs 

USD 10000 For Plant 
USD 5000 For Product (Per Product)

 
4 Form CT-01 
Application For Registration/Renewal Of Ethics Committee Relating To Clinical Trial Or Bioavailability And Bioequivalence Study Or Biomedical Health Research 
Form CT-03 
Grant Of Registration Of Ethics Committee Relating To Biomedical Health Research
Form CT-02  Grant Of Registration Of Ethics Committee Relating To Clinical Trial Or Bioavailability And Bioequivalence Study 
Will Confirm You Soon Not Found In Rule  
5 Form CT-04 
Application For Grant Of Permission To Conduct Clinical Trial Of New Drug Or Investigational New Drug 
Form CT-06 
 Permission To Conduct Clinical Trial Of New Drug Or Investigational New Drug 

Phase I-Rs.3,00,000/-

Phase II,III & IV- Rs. 2,00,000/-

 
6 Form CT-05 
Application For Grant Of Permission To Conduct Bioavailability Or Bioequivalence Study
Form CT-07 
Permission To Conduct Bioavailability Or Bioequivalence Study Of New Drug Or Investigational New Drug
Rs.2,00,000/-  
7 Form CT-08  
Application For Registration/Renewal Of Bioavailability Or Bioequivalence Study Centre
Form CT-09 
Grant Of Registration Of Bioavailability Or Bioequivalence Study Centre 
Rs.5,00,000/-  
8 Form CT-10 
Application For Grant Of Permission To Manufacture New Drug Or Investigational New Drug For Clinical Trial Or Bioavailability Or Bioequivalence Study Or For Examination, Test And Analysis 
Form CT-11
Permission To Manufacture New Drug Or Investigational New Drug For Clinical Trial, Bioavailability Or Bioequivalence Study Or For Examination, Test And Analysis
Rs.5000/- Per Product  
9 Form CT-12 
Application For Grant Of Permission To Manufacture Formulation Of Unapproved Active Pharmaceutical Ingredient For Test Or Analysis Or Clinical Trial Or Bioavailability Or Bioequivalence Study 
Form CT-15 
Permission To Manufacture Unapproved Active Pharmaceutical Ingredient For The Development Of Formulation For Test Or Analysis Or Clinical Trial Or Bioavailability Or Bioequivalence Study
Rs.5000/- Per Product  
10 Form CT-13 
Application For Grant Of Permission To Manufacture Unapproved Active Pharmaceutical Ingredient For Development Of Formulation For Test Or Analysis Or Clinical Trial Or Bioavailability Or Bioequivalence Study
Form CT-15 
Permission To Manufacture Unapproved Active Pharmaceutical Ingredient For The Development Of Formulation For Test Or Analysis Or Clinical Trial Or Bioavailability Or Bioequivalence Study
Rs.5000/- Per Product  
11 Form CT-14  
Permission To Manufacture Formulation Of Unapproved Active Pharmaceutical Ingredient For Test Or Analysis Or Clinical Trial Or Bioavailability Or Bioequivalence Study 
Form CT-15 
Permission To Manufacture Unapproved Active Pharmaceutical Ingredient For The Development Of Formulation For Test Or Analysis Or Clinical Trial Or Bioavailability Or Bioequivalence Study
Rs.5000/- Per Product  
12 Form CT-16 
Application For Grant Of Licence To Import New Drug Or Investigational New Drug For Clinical Trial Or Bioavailability Or Bioequivalence Study Or For Examination, Test And Analysis 
Form CT-17 
Licence To Import New Drug Or Investigational New Drug For The Purpose Of Clinical Trial Or Bioavailability Or Bioequivalence Study Or For Examination, Test And Analysis 
Rs.5000/- Per Product  
13 Form Ct-18 
Application For Grant Of Permission To Import New Drug For Sale Or For Distribution 
Form CT-20 
Permission To Import Pharmaceutical Formulations Of New Drug For Sale Or For Distribution
Form CT-19
Permission To Import New Active Pharmaceutical Ingredient For Sale Or For Distribution 
Rs.5,00,000/-

Rs.5,00,000/-

 
14 Form CT-21 
Application For Grant Of Permission To Manufacture New Drug Formulation For Sale Or For Distribution 
Form Ct-22 
Permission To Manufacture New Active Pharmaceutical Ingredient For Sale Or For Distribution 
Form Ct-23 
Permission To Manufacture Pharmaceutical Formulation Of New Drug For Sale Or For Distribution 

Rs.5,00,000/-

 

 

Rs.5,00,000/-

 
15 Form CT-24  
Application For Licence To Import Of Unapproved New Drug For Treatment Of Patients Of Life Threatening Disease In A Government Hospital Or Government Medical Institution 
Form CT-25 
Licence To Import Unapproved New Drug For Treatment Of Patients Of Life Threatening Disease In A Government Hospital Or Medical Institution
Rs.10,000/-  
16 Form CT-26 
Application For Grant Of Permission To Manufacture Unapproved New Drug But Under Clinical Trial For Treatment Of Patients Of Life Threatening Disease In A Government Hospital Or Medical Institution 
Form CT-27 
Permission To Manufacture Unapproved New Drug But Under Clinical Trial For Treatment Of Patients Of Life Threatening Disease In A Government Hospital Or Medical Institution 
Rs.5000/-  
17 Renewal or Re-Registration
Form 40-Application for Import of Drugs
Form 41
License To Import Drugs 
USD 10000 For Plant 
USD 5000 For Product (Per Product)
 
18 Shelf Life Extension/Reduction Amendment of Certificate USD 1800  
19 Personal Use
Form 12A Application for the issue of a permit to import small quantities of drugs for personal use
Form 12 B
Permit for the import of small quantities of drugs for personal use
Zero  
20 CT-28 
Application for import of unapproved new drug for Compassionate use for treatment of patients by hospitals or and medical institution
CT-29
Grant of licence for import of new drug for compassionate use
N.A  
21 CT-30 
Application for the permission to manufacture new drug for Compassionate use
CT-31
Grant of the permission to manufacture new drug for Compassionate use
N.A  
drugs regulatory services

Authorized Agent Services

IMPORTER

In India, Overseas Brands or Manufacturers of drugs cannot submit an application for registration as applicants. Appointing an Indian Entity as applicant is mandatory in order to submit an application for registration of imported Drugs or Cosmetics. A registration certificate once issued to a brand holder and an Indian Entity can be used by only such companies to import products in India. 

NKG holds a valid stock and sale license (Form 20B and 21B) to assist foreign manufacturers to import their products  in India in less time and without any hassle.

NKG understands the needs of global brand owners and offers bespoke services to such Brand Owners or manufacturers. NKG can be nominated by overseas companies to act as its Authorised Agent in India.

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drugs regulatory services

REGISTRATION CERTIFICATE and IMPORT LICENSE

IMPORTER

“Registration Certificate” means a certificate issued under Rule 27A by the licensing authority in Form 41 for registration of the premises and the drugs intended to be imported in India. CDSCO  Registers Both the Product as well as the Manufacturing site from where the product has to be imported to ensure Quality of the Product.

NKG experts are well versed with dossiers for registration in Form 41  and make the process of filing and approval efficient and predictable.

Import ,Manufacturing & Distribution of Drugs is regulated under Drugs and Cosmetics Act 1940.

In case, an applicant intends to Import Drugs, an application seeking permission from CDSCO has to be Applied in Form 8 or Form 8A for approval in Form 10 and Form 10A respectively.

NKG team works efficiently to ensure timely communication of documents and submission so that clients can obtain permissions smoothly.

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drugs regulatory services

New Drugs Approval

IMPORTER MANUFACTURER

A new drug means a drug, including API , FDC or phytopharmaceutical drug, which has not been approved by DCG(I) with respect to its claims; or dosage, new claims, route of administration, modified or sustained release of a drug or novel drug delivery system, veterinary products and for vaccines, recombinant Deoxyribonucleic Acid (r-DNA) derived products, living modified organisms, monoclonal antibodies, stem cells, gene therapeutic products and xenografts which are intended to be used as drugs.

Effective 19 March 2019 New Drugs are regulated under New Drugs and Clinical trial Rules 2019 which ultimately fall under the ambit of Drugs & Cosmetics Act 1940 & RUles 1945.

NKG experts assist clients with successful approval of their New Drug applications.

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drugs regulatory services

Subsequent New Drugs

IMPORTER MANUFACTURER

A subsequent new drug means a drug approved by the Central Licencing Authority for certain claims and proposed to be marketed with modified or new claims including indication, route of administration, dosage and dosage form. A subsequent new drug also includes a new drug already approved in the country.

NKG experts are well versed with SND dossiers and make the process of filing and approval efficient and predictable.

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drugs regulatory services

Clinical Trials

IMPORTER MANUFACTURER

Conducting Clinical trials in India require mandatory approvals from the Central Licensing authority i.e. CDSCO.

At NKG, we understand the procedure for the same and work closely with our clients to obtain various permissions for conducting clinical trials such as Phase I, II & III permissions.

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drugs regulatory services

NOC For Personal Use

In case, someone is in need of importing small quantities of Drugs for personal use, an application in form 12A  needs to be submitted to CDSCO through the online SUGAM portal.

Trust NKG experts to handle such a situation swiftly and efficiently.

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drugs regulatory services

BA/BE

The licensing authority has clearly laid out the regulatory requirements for BA/BE in public domain. Information and details with respect to type of Drug, type of disease and corresponding study are required to be submitted to the regulator with an applicant for Export/Import of BA/BE studies.

NKG experts assist clients with successful approval of such permissions.

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drugs regulatory services

Test License

IMPORTER MANUFACTURER

In case an importer or manufacturer intends having a valid wholesale license in form 20 B & 21 C, intends to import drugs for the purpose of examination, test or analysis  in small quantities which is otherwise prohibited under Section 10 of the D & C Rules, 1945. an application seeking permission to import for Test License.

NKG experts have competent understanding of how to obtain Test License.

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drugs regulatory services

Renewal/Re-registration of Drugs in  Form 40

IMPORTER

Under the Drugs & Cosmetics Act 1940 & Rules 1945, the permissions issued to applicants for registration certificates and import licenses are valid for a particular and defined time period. Such registration certificates and import licenses are expected to be renewed within the stipulated time by submitting prescribed documents and fee before expiration if the applicant intends to continue such permissions issued in its favor.

NKG team understands that ensuring timely submission of dossiers for renewal or re-registration are critically important to ensure that there is neither any regulatory gap nor there is any disruption in supply chain of its clients.

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drugs regulatory services

Shelf Life Extension/Reduction

There can be Changes in Shelf life of a product once an approval is received by an applicant. Shelf life of products can either be extended or reduced.

In both cases, an application for seeking permission to change Shelf Life of a product post approval has to be submitted to the Import & Registration Division of CDSCO.

Only when the approval is granted, can an applicant claim the new shelf life on the product label.

NKG experts assist clients in filing and approval of applications for Shelf Life Extension to ensure that there is neither any regulatory gap nor there is any disruption in supply chain of its clients.

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drugs regulatory services

Dual Use NOC

Dual use means drugs which can be used in both pharmaceutical as well as other industries.

In cases of imports of such drugs, an application for NOC i.e. No Objection Services need to be procured from the Zonal Office of CDSCO.

NKG experts have competent understanding of how to obtain Dual NOC from Zonal offices.

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drugs regulatory services

Special/Neutral Code for Export

Many a times, in cases of export of pharmaceutical products , special codes are required on the product label due to external regulatory requirements. In such cases, NKG experts assist our clients in obtaining NOC for special codes on label for products such as finished formulations, Bulk drug, Narcotic drug, Psychotropic substances, etc.

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drugs regulatory services

Rule 37 Permission

Under Rule 37 of Drug and Cosmetic Rules, 1945 provisions are laid out concerning packing of patent or proprietary medicines and its import in India for retail sale in the country. 

Importer intending to import such products need to apply for a permission in prescribed forms to CDSCO. Such an application needs to be made at least 3 months prior to the planned import.

NKG team works efficiently to ensure timely communication of documents and submission so that clients can obtain permissions smoothly.

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drugs regulatory services

Manufacturing License

For Manufacturing of Pharmaceutical products falling under the purview of Drugs & Cosmetics Act 1940, obtaining a manufacturing permission is mandatory from State Licensing Authority (SLA).  The requisite documents and presibried government fee need to be deposited to the SLA for processing and grant of manufacturing permission.

drugs regulatory services

WholeSale License in 20B/21B

License in Form 20 B & 21 B for wholesale and stocking is mandatory for sale or distribution of drug products under the purview of Drugs & Cosmetics Act 1945.

The requisite documents and presibried government fee need to be deposited to the State Licensing Authority i.e. SLA for processing and grant of license in Form 20 B & 21 B.

The license can be renewed in Form 21 C.

drugs regulatory services

Free Sale Certificate

Free Sale certificate is a document issued by a regulatory authority of an overseas country to an overseas brand holder/manufacturer giving evidence that products manufactured by such a manufacturer are legally sold or distributed  freely without restriction, and approved by the regulatory authority of the country of origin

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NKG has a Dedicated and Efficient team of experienced regulatory professionals who have Registered more than 2000 brands until now who can help you Plan your regulatory needs and smoothen the process for Regulatory approvals. Strategically located in New Delhi, the “regulatory “ capital of India, NKG makes a head start by following its unique time tested “Step-by- Step “ process that puts a lot of method in between the madness.

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