MD 41 is the application form submitted to the State Licensing Authority to request approval for wholesale distribution of medical devices under MDR 2017.
In early 2024, one of our clients from Pune, a newly established medical equipment trading firm, contacted Silvereye Certifications last year with a common problem: They had stocked imported pulse oximeters and diagnostic devices worth over 40 lakhs, but their shipments were held during inspection because they did not possess the required MD 41 and MD 42 License.
Their accountant had assumed that a basic drug wholesale license was enough. But medical devices in India no longer fall under the traditional Drugs & Cosmetics Act alone. Once the Medical Device Rules, 2017 (MDR 2017) came into effect, the landscape changed.
This situation is now extremely common. Every month, we receive queries from distributors, importers, and hospital suppliers unsure whether they need an MD 41 License, an MD 42 License, or both.
The MD 41 & MD 42 License refers to the regulatory approval required for businesses involved in the wholesale distribution, stocking, or sale of notified medical devices in India.
The Medical Devices Rules, 2017, introduced a structured regulatory system for selling, stocking, exhibiting, or distributing medical devices in India. Under these rules, the government created two key authorizations for wholesale operations, established through Rule 87A.
| Parameter | MD 41 (Form) | MD 42 (Certificate) |
|---|---|---|
| Type | Application Form (Submitted by applicant) | Final Wholesale License (Issued by SLA) |
| Purpose | To apply for permission to sell, stock, or distribute medical devices. | Official approval to legally wholesale medical devices. |
| Status | Initiates the licensing process. | Confirms business meets MDR 2017 standards. |
| Legal Function | Allows authority to evaluate premises, staff, and documentation. | Grants legal authorization to conduct wholesale business. |
The MD 42 License is the final approval document that legally authorizes a firm to sell, stock, exhibit, offer for sale, or distribute medical devices and in-vitro diagnostic devices in India.
| Benefit Category | Description |
|---|---|
| Legal Compliance | Ensures the business operates legally under the Medical Devices Rules, 2017, preventing violations during inspections. |
| Risk Mitigation | Protects businesses from shipment seizure, penalties, or operational shutdown during audits. |
| Tender Eligibility | Mandatory qualification for vendors participating in government and corporate healthcare tenders (GeM listings). |
| Market Credibility | Builds trust with hospitals, diagnostic chains, and corporate healthcare clients who prefer licensed distributors. |
| Quality Assurance | Ensures devices are stored, handled, and distributed by trained and authorized personnel under proper standards. |
| Traceability | Helps importers and large distributors maintain essential traceability and accountability required by CDSCO. |
Before applying for a wholesale medical device license, you must correctly classify the devices you handle, as this impacts premises and staff requirements.
| Class | Risk Level | Wholesale Handling Requirement |
|---|---|---|
| Class A | Low Risk (e.g., Bandages, Stethoscopes) | Must be listed in the MD-41 application. |
| Class B | Low to Moderate Risk (e.g., BP Monitors, Nebulizers) | Must be listed in the MD-41 application |
| Class C | Moderate to High Risk (e.g., Ventilators, Ultrasound Systems) | Still requires MD-41 application, demanding higher scrutiny of storage. |
| Class D | High Risk / Life-supporting Devices (e.g., Implants, Defibrillators) | Still requires MD-41 application, requiring stringent handling protocols. |
Why classification matters: Authorities verify whether your infrastructure and technical staff qualifications match the risk class of the devices listed in your MD-41 application.
| Benefit Category | Benefit Description for MD 41 & MD 42 License |
|---|---|
| Legal Compliance | Ensures the business operates legally under the Medical Devices Rules, 2017. |
| Regulatory Approval | Grants government authorization to sell, stock, and distribute medical devices. |
| Market Credibility | Builds trust with hospitals, diagnostic centres, importers, and tender authorities. |
| Smooth Supply Chain | Prevents stock seizure, compliance delays, or penalties during inspections. |
| Tender Eligibility | Mandatory for participation in government and corporate healthcare tenders. |
| Quality Assurance | Ensures devices are stored, handled, and distributed under proper standards. |
| Parameter | Detail |
|---|---|
| Application Fee | ₹3,000 INR (Government Fee) |
| Typical Timeline | 30–90 days (Varies by State Licensing Authority). |
| Validity | Perpetual / Indefinite |
| Renewal / Retention | Mandatory payment of a Retention Fee (currently ₹3,000 INR) every five years. |
Wholesale distribution of medical devices requires structured compliance, and the MD 41 and MD 42 License form the backbone of legal operations in India. Whether a business handles simple diagnostic tools or advanced therapeutic equipment, choosing the correct license ensures uninterrupted supply, regulatory protection, and trust with customers. Don't let a compliance gap seize your inventory.
Silvereye Certifications supports manufacturers, traders, importers, and hospital suppliers with complete end-to-end guidance so they can operate confidently and compliantly under the Medical Devices Rules, 2017.
MD 41 is the application form submitted to the State Licensing Authority to request approval for wholesale distribution of medical devices under MDR 2017.
MD 42 is the final wholesale license issued after MD 41 is approved. It authorises a business to sell, stock, and distribute medical devices legally.
Any distributor, trader, importer, hospital supplier, or online seller dealing in medical devices must obtain the MD 42 wholesale license.
Yes. Businesses handling Class A, B, C, or D medical devices must apply via MD 41 and receive approval through MD 42.
Yes, every applicant must appoint qualified technical staff responsible for compliance and storage oversight.
Most approvals take 30–90 days, depending on documentation quality and inspection timelines.
It remains valid indefinitely with timely payment of retention fees and continued compliance.
Authorities may seize stock, impose penalties, or restrict the business during audits and tenders.
Yes, MD 42 can include Class A, B, C, and D devices if the premises and CTS meet requirements.
Silvereye Certifications provides complete support—from documentation and classification to inspection preparation—making the MD 41 and MD 42 license process faster, accurate, and compliant.
At Silvereye Certifications & Consulting Services Pvt. Ltd., we simplify compliance and certification processes, guiding you to achieve and maintain required industry approvals with complete trust.
IMPORTANT DISCLAIMER: Silvereye Certifications is a private consulting firm. We do NOT issue government certificates, licenses, or official documents. We provide professional consulting services to help businesses navigate the application process for government certifications. All certificates and approvals are issued solely by the relevant government authorities.