CDSCO Licence for Enteral Feeding Tubes in India: Class B Registration, ISO 20695 and Process
An enteral feeding tube delivers nutrition and medication directly to the stomach or intestine when a patient cannot eat normally — from short-term nasogastric tubes to longer-term gastrostomy (PEG) tubes. Because it enters the body and connects to the GI tract, CDSCO regulates the enteral feeding tube as a Class B device with the enteral-equipment standards and the ENFit connector requirement behind the licence. This guide covers the full CDSCO registration pathway for enteral feeding tubes under the Medical Devices Rules, 2017 — classification, licence route, ISO 20695, the documents, the fees and the timeline. (Confirm the class for long-term/implanted gastrostomy devices against the current CDSCO list.) This guide explains CDSCO registration for enteral feeding tubes in India — risk class, licence forms, standards, documents, fees and timeline.
Is a CDSCO Registration Mandatory for Enteral Feeding Tubes?
Yes. An enteral feeding tube is a notified Class B medical device and cannot be manufactured, imported or sold in India without a CDSCO licence. A domestic manufacturer holds a Form MD-5 licence from the State Licensing Authority. An importer holds a Form MD-15 import licence through an Indian Authorised Agent. Nasogastric, nasojejunal and gastrostomy tubes, and enteral syringes/giving sets, fall within the framework.
Risk Classification of Enteral Feeding Tubes
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.
Enteral Feeding Tubes are classified as Class B (low-to-moderate risk). An enteral feeding tube is a surgically invasive device introduced through a body orifice (or stoma) that connects to the GI tract, placing it in Class B (low-to-moderate risk) under the First Schedule. Long-term gastrostomy devices may be classified higher. 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 Enteral Feeding Tubes
- To manufacture enteral feeding tubes in India (Class B) — apply in Form MD-3 to the State Licensing Authority (SLA). The licensing authority grants the licence in Form MD-5. A CDSCO-empanelled Notified Body audits the site. For Class A the audit is post-grant. For Class B the Notified Body conducts it before the licensing authority grants the licence.
- To import enteral feeding tubes (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 Enteral Feeding Tubes
Enteral feeding tubes are evaluated against the enteral-equipment standards plus the misconnection-prevention connector:
- ISO 20695 — enteral feeding systems: design and testing.
- ISO 80369-3 — small-bore connectors (ENFit) for enteral applications, to prevent tubing misconnections.
- ISO 10993 series — biocompatibility of the tube and connectors.
- ISO 11135 / 11137 — sterilisation validation.
- Radiopacity and flow/kink performance as required.
- Shelf-life / stability data supporting the expiry.
Documents Required for CDSCO Registration of Enteral Feeding Tubes
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 Enteral Feeding Tubes
Device-specific documents on top of the core set for enteral feeding tubes:
- ISO 20695 test reports — flow, tensile, kink and radiopacity performance.
- ISO 80369-3 (ENFit) connector conformity to prevent misconnection.
- Sterilisation validation with the sterility assurance level.
- Biocompatibility (ISO 10993) for the tube and connectors.
- Balloon/retention-device evidence for gastrostomy tubes.
- Country-of-origin approval / 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 Enteral Feeding Tubes
Enteral-feeding-tube labelling is checked for size, connector and sterility:
- French size, length, tube type (NG/NJ/gastrostomy) and connector (ENFit), with the reference number.
- Manufacturer name and address, and the CDSCO licence number.
- Batch/lot number, date of manufacture and use-by date.
- “STERILE” with the sterilisation-method symbol and a single-use symbol.
- “For enteral use only” and placement/verification information in the IFU.
ENFit Connectors: Misconnection Prevention
The defining requirement for modern enteral devices is the ENFit (ISO 80369-3) connector — an enteral-specific design introduced worldwide to stop dangerous tubing misconnections (e.g. enteral feed into an IV line). CDSCO expects enteral feeding tubes to use the correct small-bore enteral connector, not a luer. Beyond that, short-term nasogastric tubes and long-term gastrostomy (PEG) tubes differ in retention design and can differ in class. Fix the tube type and the connector standard at the outset.
Step-by-Step CDSCO Registration Process for Enteral Feeding Tubes
- Confirm the classification. Fix the risk class against the CDSCO classification list and the First Schedule — Class B here — which decides the form, authority, fee and audit route.
- Choose the route. Manufacture (Form MD-3 → MD-5) 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-empanelled Notified Body audits the site. For Class A the audit is post-grant. For Class B the Notified Body conducts it before the licensing authority grants the licence.
- Respond to queries and receive the licence. Answer the deficiency letter within the stipulated period. On approval the licence issues in Form MD-5 (manufacture) or MD-15 (import).
CDSCO Registration Fees and Timeline for Enteral Feeding Tubes
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 B device the fee is Rs 5,000 per site plus Rs 500 for each distinct device, paid to the State Licensing Authority (SLA). 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 B manufacturing file typically clears in about three to six 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
Common query reasons for enteral-feeding-tube applications are:
- Wrong connector — a luer instead of the ENFit (ISO 80369-3) enteral connector.
- Sterilisation validation missing or not matching the cycle.
- Gastrostomy tubes without retention/balloon evidence.
- Biocompatibility not covering the intended dwell time.
- Free Sale Certificate scope not covering all sizes/types on import.
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.
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 Enteral Feeding Tubes
What CDSCO class is an enteral feeding tube?
An enteral feeding tube is Class B. A domestic manufacturer files Form MD-3 for an MD-5 licence. An importer files Form MD-14 for an MD-15 licence. Confirm the class for long-term gastrostomy devices on the current CDSCO list.
Which standards apply to enteral feeding tubes in India?
ISO 20695 for enteral feeding systems and ISO 80369-3 (ENFit) for the enteral connector, with ISO 10993 biocompatibility and validated sterilisation.
What is ENFit and why does it matter?
ENFit (ISO 80369-3) is the enteral-specific small-bore connector introduced to prevent dangerous tubing misconnections; CDSCO expects enteral tubes to use it rather than a luer.
Does CDSCO require a factory audit?
Yes — for Class B manufacture a CDSCO-empanelled Notified Body audits the site before the licensing authority grants the MD-5 licence.
How long does registration take?
A complete Class B manufacturing (MD-5) file usually clears in about three to six months. An import (MD-15) file typically takes six to nine months.
Does the licence expire?
No — the MDR 2017 licence is perpetual, subject to the five-yearly retention fee and continued compliance.
Related CDSCO Registration Guides
Need end-to-end help? See our CDSCO registration services, or read these related guides:
- CDSCO Registration for COVID-19 Antigen Test Kits in India
- CDSCO Registration for Dengue & Malaria Rapid Test Kits in India
- CDSCO Registration for Blood Bags in India
- CDSCO Registration for Eyebrow Pencil & Brow Products 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 enteral feeding tubes 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 enteral feeding tubes — 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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