05/04/2026
Importing Class C & D medical devices without a GHTF Free Sale Certificate is possible, but it requires a completely different regulatory approach.
For high-risk medical devices under the Medical Devices Rules, 2017 (MDR 2017), CDSCO typically expects prior approval from GHTF countries as a key validation of safety and performance. However, in cases where such approvals are not available, applicants may still proceed through an alternate regulatory pathway, supported by strong clinical and technical evidence.
This may include clinical investigation reports generated in India, along with a Free Sale Certificate from the country of origin or any other country where the device is marketed, supported by a robust technical dossier and clear justification.
The key shift for Class C & D devices is simple:
👉 Approval depends on scientific evidence, not just regulatory history.
These applications are highly evaluation-driven, and incomplete documentation or weak justification can lead to regulatory queries, delays, or rejection.
At NKG Advisory, we support manufacturers and importers with:
• Alternate pathway strategy for high-risk devices
• Clinical and technical documentation planning
• CDSCO import licensing under MDR 2017
• End-to-end medical device & IVD regulatory compliance
If your device does not have GHTF approval and you’re exploring the Indian market, it’s critical to assess the right pathway before filing.
📞 +91 9711197602
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🌐 www.nkgabc.com