An MD-41 and MD-42 wholesale license Registration required to stock, distribute, or sell medical devices in bulk in India. Anyone trading in notified medical devices — distributors, stockists, C&F agents, and even sellers on marketplaces like Amazon or Flipkart — must apply on Form MD-41 to the State Licensing Authority and receive the Form MD-42 grant of license before starting operations.
The process involves submitting business and premises documents, a competent-person declaration, and a government fee, followed by a physical inspection by a Drug Inspector. The license is valid for five years and must be renewed before expiry to stay compliant.
A medical device wholesale license is an official authorization issued by the State Licensing Authority (SLA) that permits a business to purchase medical devices in bulk from manufacturers or importers and sell them onward — to retailers, hospitals, nursing homes, diagnostic centres, or other wholesale dealers. It is granted under the Medical Devices Rules, 2017 (MDR 2017), framed under the Drugs and Cosmetics Act, 1940.
The license works through two linked forms. Form MD-41 is the application you file with the SLA, whether through the CDSCO portal or your state's drug control department. Form MD-42 is the wholesale licence certificate granted once your application, documents, and premises inspection are approved. Without a valid MD-42 licence, wholesale trade in medical devices is treated as an unlicensed — and illegal — activity under Indian law.
This licence applies to anyone engaged in the wholesale trade of medical devices — not just traditional distributors.
| Needs MD-41/MD-42 | Exempt / Needs a Different License |
|---|---|
| A distributor buying from manufacturers/importers and selling to sub-distributors or retailers | A retail pharmacy or device shop selling directly to end consumers (needs a retail license instead) |
| A C&F (clearing and forwarding) agent managing distribution for a device company | A licensed manufacturer distributing its own devices (already covered under its manufacturing license) |
| A trader or stockist running a depot/warehouse for medical devices | A business dealing exclusively in exempt, low-risk Class A devices notified by CDSCO |
| An e-commerce seller of regulated Class A/B/C/D devices (Amazon, Flipkart, etc.) | — |
| A hospital procurement department reselling devices to affiliated centres (state rules vary) | — |
Unlike drug wholesale licensing, MDR 2017 does not rigidly mandate a registered pharmacist for every medical device wholesale operation. However, most State Licensing Authorities expect a qualified competent person to be responsible for the premises:
| Device Class | Competent Person Requirement |
|---|---|
| Class A / Class B | A diploma or degree in science, engineering, or a related technical field — or at least 2 years of prior experience in medical device distribution |
| Class C / Class D (higher risk) | A degree in a relevant technical/scientific field is generally expected; some states require a pharmacist or biomedical engineer |
The competent person must be available at the business premises during working hours, and requirements can vary slightly by state — always confirm the current rule with your specific SLA before applying.
| Particular | Details |
|---|---|
| Government Fee | ₹3,000 per premises (non-refundable) |
| When to Pay | Before submitting the MD-42 registration application |
| Payment Mode | Online through the CDSCO portal or the State Drug Control Department's designated payment channels |
| Fee Applicability | Payable separately for each business premises applying for MD-42 registration |
| Important Note | While the Medical Devices Rules prescribe a ₹3,000 government fee for registration per premises, applicants should verify any state-specific administrative charges or updated fee requirements with the concerned State Licensing Authority (SLA) before filing the application. |
| Stage | Details |
|---|---|
| Application Form | Submit a complete Form MD-41 application along with all required supporting documents. |
| Premises Inspection | The State Licensing Authority (SLA) conducts an inspection of the business premises, if applicable. |
| Expected Processing Time | The MD-42 Wholesale Licence is generally issued within 30–60 days after successful application submission and inspection. |
| Possible Delays | Processing may take longer if the inspection identifies deficiencies, documents are incomplete, or corrections/additional information are required. |
Filing Form MD-41 correctly — matching business documents, premises details, and competent-person qualifications to what your State Licensing Authority expects — is easy to get wrong without regular experience with the process, especially since requirements shift slightly from state to state. Silvereye Certifications works with distributors, stockists, and e-commerce sellers to prepare a complete MD-41 application, coordinate the premises inspection, and track the file through to the MD-42 grant of licence — helping businesses avoid the documentation gaps and inspection issues that most often cause delays.
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