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Local Regulatory Experts

Connect with regulatory affairs consultancies specializing in this region.

Registrar Corp

Hampton, Virginia (HQ), Shenzhen, China, London, United Kingdom, Paris, France, Madrid, Spain, Hyderabad, India, Kuala Lumpur, Malaysia, Tel Aviv, Israel, Guatemala City, Guatemala, Cape Town, South Africa

Registration

A global FDA compliance firm assisting businesses in the food, medical device, drug, and cosmetic industries with registration, U.S. Agent services, labeling, and regulatory software solutions.

ARQon Pte. Ltd.

Singapore (HQ), Malaysia, Vietnam, Indonesia, Philippines, Thailand, Taiwan, Hong Kong, South Korea, Switzerland, USA, Australia, New Zealand, Rwanda, India, Sri Lanka

Registration

We are a premier regulatory consultancy firm specializing in medical devices, in-vitro diagnostics (IVD), and pharmaceuticals. Founded in 2014, the company offers a comprehensive suite of services ranging from product development strategy and clinical trials to product registration and post-market surveillance. With a team of experts possessing vast experience in regulatory authorities and industry, we bridge the gap between scientific innovation and regulatory compliance, ensuring patient safety while fostering medical advancement. The company also provides unique business matching services through its ATTOPOLIS platform and training through the International Medical Device School.

Regulatory Compliance Associates Inc. (RCA)

Pleasant Prairie, WI, Tampa, FL

Registration

Regulatory Compliance Associates (RCA) is a leading global provider of regulatory and compliance expert consulting services for life science companies. The company offers expertise in regulatory affairs, assessments and audits, agency response, preparation and remediation, and new product development support for medical devices, pharmaceuticals, and compounding pharmacies.

Emergo by UL

USA, Canada, Brazil, Australia, China, Hong Kong, Taiwan, India

Registration

A dedicated partner for medical device and IVD manufacturers, we offers deep local regulatory expertise through its offices in over 20 global locations. Services include product registration, human factors research, clinical strategy, and local in-country representation to ensure rapid, compliant market access worldwide.

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Clinical Trials

April 1, 2025

Approximately 5 minutes

Predicate Device Identification in India: Requirements for Equivalence and Clinical Data Waiver

Predicate Device Identification in India

In India's medical device registration process, governed by the Medical Devices Rules, 2017, the existence of a registered predicate device significantly impacts the cost, time, and documentation required for a product to obtain an Import License (MD Form 15).


📜 Definition of a Predicate Device

The CDSCO defines a "predicate device" as:

“...a device, first time and first of its kind, approved for manufacture for sale or for import by the Central Licensing Authority and has the similar intended use, material of construction, and design characteristics as the device which is proposed for license in India.”

This definition emphasizes the need for substantial equivalence in intended use, materials, and design between the proposed device and the registered predicate.

Importance in Registration

  1. Standard Pathway: If a medical device has an identified predicate device registered in India, the manufacturer follows the standard Form MD-14 (Import License) application process.
  2. Clinical Data Requirement: If no registered predicate device can be identified, the device may be treated as "novel" or "first of its kind." This situation can trigger a requirement for pre-market or post-market clinical data from India, as determined on a case-by-case basis by the Subject Expert Committee (SEC) review.

🧪 Equivalence and Clinical Data Waiver

To establish a predicate device, the manufacturer must identify similar products that use similar technology and have the same indications for use. Simple differences, like a drug-eluting stent compared to an ordinary stent, would disqualify the latter as a predicate.

Exemption from Local Clinical Data

To alleviate the burden of requiring extensive clinical studies in India for devices entering the market, the CDSCO offers an important exemption:

  • Devices that have been registered in a reference market for more than two years will be exempted from the local clinical data requirement.
  • Reference Markets include the US, the EU, the United Kingdom, Japan, Canada, or Australia.

By demonstrating substantial foreign approval history, manufacturers can bypass the lengthy and costly local clinical investigation, even if an exact predicate is not yet registered in India.


🔍 Identifying the Predicate

Manufacturers should strategically identify potential predicate devices by:

  1. Identifying competing products that share the necessary characteristics (intended use, materials, design).
  2. Confirming that these potential predicates are officially registered in India via the CDSCO's public database or by working with local regulatory partners.

Need Expert Guidance?

Contact us at contact@elendilabs.com / +852 4416 5550