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  • 1.  Labelling Requirements for Medical Devices in India

    Posted 29-Nov-2022 13:21

    Medical device manufacturers must follow labelling requirements and appropriate labelling must be done on all Medical Devices before placing them in Indian Market. Rule 109A of Medical Device Rules, 2017 gives instructions for labelling of Medical Devices in India.

    The following details must be printed in indelible ink on the label, on the shelf pack of the medical device or on the outer cover of the medical device and on every outer covering in which the medical device is packed:

    1.      name of the medical device; 

    2.      the details of the device and its use; 

    3.      the name and address of manufacturer

    4.      net quantity in terms of weight, measure, volume, number of units, and the number of the devices contained in the package expressed in metric system; 

    5.      the month and year of manufacture and expiry (alternately the label shall bear the shelf life of the product): 

    •  In case of sterile devices, the date of sterilization can be given as date of manufacture of the device.
    • If the device is made up of stable materials such as stainless steel or titanium, and supplied non-sterile or in case of medical equipment or instruments or apparatus, the date of expiry may not be necessary. 
    • The date of expiry shall be in terms of the month and the year and it shall mean that the medical device is recommended till the last day of the month and the date of expiry shall be preceded by the words "Expiry date" or "Shelf Life";

    6.      an indication that the device contains medicinal or biological substance, if applicable; 

    7.      a distinctive batch number or lot number preceded by the word "Lot No." or "Lot" or "Batch No." or "B. No."; 

    8.      any special storage or handling conditions applicable to the device;  

    9.      if the device is supplied as a sterile product, its sterile state and the sterilisation method; 

    10.  warnings or precautions to draw the attention of the user of medical device; 

    11.  if the device is intended for single use; 

    12.  to overprint on the label of the device, the words "Physician's Sample-Not to be sold", if a medical device is intended for distribution to the medical professional as a free sample; 

    13.  the manufacturing licence number by preceding the words "Manufacturing Licence Number" or "Mfg. Lic. No." or "M. L" for devices Manufactured in India and "Import License number" or "Imp. Lic. No." or "I. L" for devices Imported into India. 

    14.  the import licence number, name and address of the importer, address of the actual manufacturing premises and the date of manufacture, in case of imported devices, by way of stickering, where such details are not already printed.

    The label may bear symbols recognised by the Bureau of Indian Standards (BIS) or International Organisation for Standardisation (ISO) in lieu of the text and the device safety is not compromised by a lack of understanding on the part of the user, in case the meaning of the symbol is not obvious to the device user;

    The Instructions for Use (either paper or electronic) need to be accompanied along with the label of the Medical Device, as applicable.

    Labelling Requirements for Medical Devices in India

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    Labelling Requirements for Medical Devices in India
    Medical device manufacturers must follow labelling requirements and appropriate labelling must be done on all Medical Devices before placing them in Indian Market. Rule 109A of Medical Device Rules, 2017 gives instructions for labelling of Medical Devices in India.
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    ------------------------------
    Sravan Kumar Manchikanti, RAC
    Hyderabad
    India
    ------------------------------


  • 2.  RE: Labelling Requirements for Medical Devices in India

    Posted 30-Nov-2022 02:34
    Dear Sravan,
    thank you for posting this!

    I have some additional questions:
    Is it required for non Indian manufacturers to get a manufacturer license?
    Is it required for non Indian manufacturers of non-measuring, non -sterile class A devices to get a manufacturer license?
    And if yes, should the manufacturing licence number be printed on the label for non-measuring, non-sterile class A devices?


    many thanks in advance

    ------------------------------
    Eric Caus
    Regulatory Officer
    Kortrijk
    Belgium
    ------------------------------



  • 3.  RE: Labelling Requirements for Medical Devices in India

    Posted 30-Nov-2022 12:32
    Hi Eric,

    Here are my answers

    Q1) Is it required for non Indian manufacturers to get a manufacturer license?
    Ans: A non-Indian manufacturer (i.e., foreign manufacturer) shall have an import license to market the devices in India. In India, domestic manufacturers need 'Manufacturing License' whereas foreign manufacturers need 'Import License'. 

    Q2) Is it required for non Indian manufacturers of non-measuring, non -sterile class A devices to get a manufacturer license?
    Ans: As stated above, Foreign manufactures don't need manufacturing license. However, Indian FDA has recently introduced a self certification by registering in an online portal for non-measuring, non -sterile class A devices (both from foreign & domestic manufacturers). 

    Q3) And if yes, should the manufacturing license number be printed on the label for non-measuring, non-sterile class A devices?
    Ans: Foreign manufactures shall have Indian import license number sticked on top of the international label.

    Hope I have answered all your questions. If you have any further questions, you can reach out to me at +91-9390029538 or mns.sravan@gmail.com

    Thank you,
    Sravan


    ------------------------------
    Sravan Kumar Manchikanti, RAC
    Hyderabad
    India
    ------------------------------



  • 4.  RE: Labelling Requirements for Medical Devices in India

    Posted 01-Dec-2022 01:16
    Thank you very much Sravan!

    ------------------------------
    Eric Caus
    Regulatory Officer
    Kortrijk
    Belgium
    ------------------------------



  • 5.  RE: Labelling Requirements for Medical Devices in India

    Posted 30-Nov-2022 02:34
    Great and clear overview of the requirements.
    Any idea of the required language for the IFU? Is that Indian or is English also accepted?

    ------------------------------
    Chriscilia Tehupeiori
    Alphen aan den Rijn
    Netherlands
    ------------------------------



  • 6.  RE: Labelling Requirements for Medical Devices in India

    Posted 30-Nov-2022 12:33
    Hi Chriscilia,

    English is very much accepted in India. There is no need for any translation into local languages. 

    Thank you,
    Sravan

    ------------------------------
    Sravan Kumar Manchikanti, RAC
    Hyderabad
    India
    ------------------------------



  • 7.  RE: Labelling Requirements for Medical Devices in India

    Posted 16-Jan-2023 10:01
    Does India recognize UDI as a Manufacturing Date or does this need to be explicitly noted on the packaging? I understand that India does not recognize CE requirements, so how is it required to be placed on the labeling and at what level(s)?

    ------------------------------
    Magdalena Corral
    Director, QA/RA
    Kennewick WA
    United States
    ------------------------------



  • 8.  RE: Labelling Requirements for Medical Devices in India

    Posted 19-Jan-2023 13:41
    Hi Magdalena,

    Manufacturing date needs to be added separately and must be printed in indelible ink on the label, on the shelf pack of the medical device or on the outer cover of the medical device and on every outer covering in which the medical device is packed. This information can be added by way of stickering, where such details are not already printed.

    Thank you,
    Sravan

    ------------------------------
    Sravan Kumar Manchikanti, RAC
    Hyderabad
    India
    ------------------------------