CDSCO Licence for CT Scanners in India: Class C Registration, IEC 60601-2-44 and Process
A CT scanner builds cross-sectional images from many X-ray projections, delivering more diagnostic detail — and more radiation dose — than plain radiography. Like all X-ray equipment it is regulated twice: by CDSCO as a Class C medical device and by the Atomic Energy Regulatory Board (AERB) for the radiation. CDSCO reviews it against the computed-tomography particular standard and the electro-medical framework. This guide covers the full CDSCO registration pathway for CT scanners under the Medical Devices Rules, 2017 — classification, licence route, IEC 60601-2-44, the AERB overlap, the documents, the fees and the timeline. This guide explains CDSCO registration for ct scanners in India — risk class, licence forms, standards, documents, fees and timeline.
Is a CDSCO Registration Mandatory for CT Scanners?
Yes. A CT scanner is a notified Class C medical device and cannot be manufactured, imported or sold in India without a CDSCO licence. Because it is Class C, a domestic manufacturer applies to the Central Licensing Authority in Form MD-7 for a Form MD-9 licence. An importer applies in Form MD-14 for a Form MD-15 import licence. All CT systems additionally require AERB clearance for the radiation source.
Risk Classification of CT Scanners
Every medical device in India falls into one of four risk classes (A, B, C, D) under the First Schedule of the Medical Devices Rules, 2017. The class fixes the authority, the form, the fee, the audit route and the timeline.
CT scanners are classified as Class C (moderate-to-high risk). A CT scanner is an active device delivering a significant ionising-radiation dose for diagnosis, whose malfunction can cause serious harm, placing it in Class C (moderate-to-high risk) under the First Schedule. Where a device could fall in two classes the higher class applies, and an accessory is classified in its own right. Always confirm against the current CDSCO classification list.
Which CDSCO Licence You Need for CT Scanners
- To manufacture CT scanners in India (Class C) — apply in Form MD-7 to the Central Licensing Authority (CDSCO headquarters). The licensing authority grants the licence in Form MD-9. A CDSCO joint audit team inspects the manufacturing site before the licensing authority grants the licence — site inspection is mandatory for Class C and D.
- To import CT scanners (any class) — the overseas manufacturer appoints an Indian Authorised Agent who files Form MD-14 with the Central Licensing Authority; CDSCO grants the import licence in Form MD-15.
- Test licence — for a small quantity imported or made for testing, evaluation, demonstration or clinical investigation: Form MD-12 application, Form MD-13 licence.
- Loan licence — using another licensee’s approved premises: Form MD-4 (Class A/B) or Form MD-8 (Class C/D) for a licence in Form MD-6 or MD-10.
Applicable Standards for CT Scanners
CT scanners are evaluated against the computed-tomography particular standard plus the electro-medical framework:
- IEC 60601-2-44 — basic safety and essential performance of X-ray equipment for computed tomography.
- IEC 60601-1 — general electrical safety for medical electrical equipment.
- IEC 60601-1-2 — electromagnetic compatibility (EMC).
- IEC 60601-1-3 — radiation protection in diagnostic X-ray equipment.
- Dose-reporting (CTDI/DLP) and image-quality performance as required by the standard.
- AERB type approval / site licensing — for the radiation source, alongside the CDSCO licence.
Documents Required for CDSCO Registration of CT Scanners
Whether you file for a manufacturing or an import licence, CDSCO expects the same core technical dossier built around the device:
- Covering letter and application form — Form MD-3 / MD-7 (manufacture) or Form MD-14 (import) on the CDSCO Medical Device Online portal, stating every device, variant and site.
- Device Master File (DMF) — device description and intended use, materials, design and manufacturing information, ISO 14971 risk file, verification/validation data, sterilisation validation where applicable, shelf-life/stability data and the Essential Principles checklist.
- Plant Master File (PMF) — site layout, equipment, utilities/HVAC, organisation chart with competent technical staff and the QMS procedures governing production.
- ISO 13485 QMS certificate — current, with a scope covering the device.
- Essential Principles of Safety and Performance — a completed checklist mapping the device against each applicable principle with the standard/evidence relied on.
- Risk management file (ISO 14971) — hazards, risk controls and residual-risk justification.
- Test / performance reports — against the applicable BIS/IS or ISO/IEC standards from an accredited laboratory.
- Labels, IFU and packaging — meeting the labelling requirements of the Medical Devices Rules (manufacturer, licence number, sterile status, single-use symbols).
- Undertaking and declaration of conformity to the Essential Principles and applicable standards.
- Government fee receipt — paid online through the CDSCO portal.
Device-Specific Documents for CT Scanners
Device-specific documents on top of the core set for CT scanners:
- IEC 60601-2-44 performance report — image quality, CTDI/DLP dose reporting and reproducibility.
- IEC 60601-1 / -1-2 / -1-3 reports for electrical safety, EMC and radiation protection.
- AERB type approval / no-objection for the CT X-ray source.
- Software / reconstruction documentation — lifecycle and validation for image reconstruction and any AI features.
- Risk-management file (ISO 14971) addressing over-dose and reconstruction error.
- Country-of-origin approval and Free Sale Certificate for imports.
For an import licence (Form MD-14) there are three further essentials:
- Free Sale Certificate (FSC) — from the National Regulatory Authority of the country of origin, legalised (apostille/embassy attestation).
- Country-of-origin regulatory approval — US FDA 510(k)/PMA, EU CE certificate or equivalent.
- Power of Attorney and Authorised Agent licence — notarised, legalised PoA to the Indian Authorised Agent, plus the agent’s valid wholesale/manufacturing licence.
QMS & Essential Principles — What CDSCO Checks
- Essential Principles of Safety and Performance (Fifth Schedule) — the device must be safe and perform as intended, with risks reduced as far as possible. Shown through recognised standards and the risk-management file.
- Quality Management System (ISO 13485) — design controls, supplier control, process validation, traceability, complaint handling and CAPA, evidenced at audit.
- Risk management (ISO 14971) — a living file with residual risks justified and communicated in the IFU.
- Clinical evidence — proportionate to the class: clinical evaluation for lower-risk devices and clinical investigation data for many Class C/D and novel devices.
Label & IFU Requirements Specific to CT Scanners
CT-scanner labelling and the IFU are checked for safety, dose and electrical information:
- Device name, model and serial number, and rated electrical supply.
- Manufacturer name and address, and the CDSCO licence number.
- Radiation-warning symbols and the IEC 60601 safety classification.
- Batch/serial identification and the date of manufacture.
- Dose-management (CTDI/DLP), interlock and radiation-protection information in the IFU.
CDSCO, AERB and the Reconstruction Software
A CT scanner registration has two things a plain device does not. First, the AERB radiation track runs in parallel with the CDSCO device licence — both are mandatory. Second, the reconstruction and dose-modulation software (and increasingly AI-based image tools) is a substantial part of the device, so its lifecycle and validation are assessed and any AI/diagnostic-assist feature raises the evidence bar. Plan for both the AERB overlap and the software documentation from the outset.
Step-by-Step CDSCO Registration Process for CT Scanners
- Confirm the classification. Fix the risk class against the CDSCO classification list and the First Schedule — Class C here — which decides the form, authority, fee and audit route.
- Choose the route. Manufacture (Form MD-7 → MD-9) or import (Form MD-14 → MD-15). Importers appoint an Indian Authorised Agent holding a valid manufacturing or wholesale licence.
- Build the Device Master File and Plant Master File. Assemble device description, materials, design and process data, the ISO 14971 risk file, sterilisation/stability data and the site file with the QMS.
- Complete the Essential Principles checklist. Map the device against each applicable essential principle and cite the BIS/IS or ISO/IEC standard or test report relied on.
- Draw the test and performance reports. Test to the applicable standards at an accredited laboratory. Sterile and measuring devices carry additional validation.
- Register and file on the CDSCO Medical Device Online portal. Create the account, pay the government fee online and upload the full dossier under the correct form.
- Site audit / inspection. A CDSCO joint audit team inspects the manufacturing site before the licensing authority grants the licence — site inspection is mandatory for Class C and D.
- Respond to queries and receive the licence. Answer the deficiency letter within the stipulated period. On approval the licence issues in Form MD-9 (manufacture) or MD-15 (import).
CDSCO Registration Fees and Timeline for CT Scanners
The Second Schedule of the Medical Devices Rules sets the fees, and you pay them online through the CDSCO portal. For manufacture of a Class C device the fee is Rs 50,000 per site plus Rs 1,000 for each distinct device, paid to the Central Licensing Authority (CDSCO headquarters). CDSCO charges import fees under Form MD-15 per site and per device in USD — roughly USD 1,000 per site plus USD 50 per device for lower-risk devices, up to about USD 3,000 per site plus USD 1,500 per device for Class C and D. A test licence (Form MD-13) carries a modest fee. Always confirm the current figure on the CDSCO portal before filing.
A complete Class C manufacturing file typically clears in about six to nine months. An import (MD-15) file usually takes six to nine months. Every deficiency letter effectively restarts the clock. Unlike the old registration certificates, an MDR 2017 licence does not expire — it stays valid as long as you pay the retention fee (equal to the licence fee) every five years and meet the conditions of licence.
Common Mistakes That Trigger a CDSCO Query
For active Class C radiation equipment, the recurring query reasons are:
- IEC 60601-2-44 / -1-3 reports missing, out of date, or not for the exact model.
- No AERB type approval for the CT radiation source.
- Thin software/reconstruction verification and validation.
- Dose-reporting (CTDI/DLP) evidence incomplete.
- Free Sale Certificate / country-of-origin approval scope not covering the model.
Related Approvals to Plan Alongside CDSCO
- DGFT Importer-Exporter Code — mandatory for any importer of record before the first consignment.
- Wholesale / sale licence (Form 20B/21B or Form MD-42) — for stocking and distributing the device. The Indian Authorised Agent for an import licence must already hold one.
- Legal Metrology (LMPC) registration — importers of pre-packaged devices declare MRP, net quantity, importer details and country of origin on the pack.
- BIS certification — where the device or its electrical components fall under a mandatory BIS/CRS scheme.
- AERB approval (eLORA) — type approval and site licensing for the CT radiation source, mandatory alongside the CDSCO licence.
Post-Approval Obligations
- Print the licence number on the label and keep the Essential Principles conformity current.
- Operate a Post-Market Surveillance (PMS) system and file the Periodic Safety Update Report (PSUR) on the schedule for the device’s class.
- Report adverse events and field safety corrective actions through the Materiovigilance Programme of India (MvPI) and to CDSCO within the prescribed timelines.
- Report any change in device, materials, site, labelling or QMS, and any regulatory action or recall in another country.
- Retain distribution records for traceability and allow CDSCO to draw samples and inspect the premises.
- Pay the retention fee every five years to keep the licence in force, and track BIS/ISO standard revisions.
FAQs on CDSCO Registration for CT Scanners
What CDSCO class is a CT scanner?
A CT scanner is Class C, so a domestic manufacturer files Form MD-7 for an MD-9 licence with the Central Licensing Authority, and an importer files Form MD-14 for an MD-15 licence.
Do CT scanners need AERB approval too?
Yes — the AERB regulates the radiation source with type approval and site licensing via eLORA, in parallel with the CDSCO device licence.
Which standard applies to CT scanners in India?
IEC 60601-2-44 for computed tomography, with IEC 60601-1 electrical safety, IEC 60601-1-2 EMC and IEC 60601-1-3 radiation protection.
Is the reconstruction software assessed?
Yes — image-reconstruction and dose-modulation software (and any AI features) form part of the device and their lifecycle/validation is reviewed.
How long does CT-scanner registration take?
Budget roughly six to nine months for the CDSCO Class C file (MD-9/MD-15), with the AERB track planned in parallel.
Does the licence expire?
No — the MDR 2017 licence is perpetual, subject to the five-yearly retention fee; AERB approvals carry their own validity.
Related CDSCO Registration Guides
Need end-to-end help? See our CDSCO registration services, or read these related guides:
- CDSCO Registration for Condoms in India
- CDSCO Registration for Adhesive Bandages in India
- CDSCO Registration for Coronary Stents in India
- CDSCO Registration for Contact Lenses in India
Official references: Central Drugs Standard Control Organisation (CDSCO) and the CDSCO MD Online portal.
Why Choose PCN India Global
- Classification triage — we confirm the correct risk class for your CT scanners against the current CDSCO list before we draft anything.
- Route selection — manufacture (MD-5/MD-9) or import (MD-15), with the Indian Authorised Agent arrangement handled.
- Dossier build — Device Master File, Plant Master File, Essential Principles checklist and ISO 13485/ISO 14971 readiness.
- Standards and testing — the right BIS/IS or ISO/IEC standards mapped and accredited test reports coordinated.
- End-to-end online filing — application, audit support, query response and the licence grant managed for you.
- Adjacent approvals — DGFT/IEC, LMPC, wholesale/sale licence and BIS coordinated alongside your CDSCO licence.
PCN India Global manages the complete CDSCO process for CT scanners — from classification and route selection to Device and Plant Master File preparation, online filing, audit support and the licence grant. WhatsApp or call +91 80109 05029, or email admin@pcnindiaglobal.com, to get your registration underway.
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