Registration Pathway Overview
DGDA ยท Drug and Cosmetics Act 2023 ยท BD-unique features highlighted
Registration Requirements by Classโ
| Class | Registration | Validity | AR Required | ISO 13485 |
|---|---|---|---|---|
| A | โ Not required | โ | โ | Not required |
| B | โ Mandatory | 5 years | โ Yes | โ Required |
| C | โ Mandatory | 5 years | โ Yes | โ Required |
| D | โ Mandatory | 5 years | โ Yes | โ Required |
BD-unique: Class A devices require no registration and have no expiry. They may be freely imported and distributed. Class B/C/D registrations expire after 5 years and must be renewed.
Mandatory Local Entity โ Authorized Representativeโ
All DGDA registrations for foreign-manufactured devices must be held by a Bangladesh-registered Authorized Representative (AR). A foreign manufacturer cannot register directly with DGDA.
Who can be an AR?
- Any Bangladesh-registered company with the technical and administrative capacity to fulfil AR obligations
- Commonly the local distributor, a dedicated regulatory affairs company, or a locally registered subsidiary
- The AR and the physical importer may be different entities
What does the AR do?
- Submits the DGDA registration application
- Holds the registration licence in their name
- Corresponds with DGDA on all regulatory matters
- Manages post-market obligations (vigilance, recalls, pricing compliance)
Registration Application Processโ
Step 1: Appoint AR and Obtain Authorisationโ
The manufacturer issues a Letter of Authorization to the AR, formally appointing them as the legal representative in Bangladesh.
Step 2: Compile the Registration Dossierโ
The AR works with the manufacturer to prepare the dossier. For Class B/C/D this includes:
- Completed DGDA application form
- Letter of Authorization from manufacturer
- ISO 13485 certificate (scope-appropriate)
- Free Sale Certificate (FSC) from the country of manufacture
- Device description and specifications
- Risk management documentation (ISO 14971 summary)
- Clinical/performance evaluation evidence
- Labelling and IFU in English (and Bengali where applicable)
- Manufacturing site information and GMP evidence
Full requirements per class: see Dossier Requirements.
Step 3: Submit to DGDAโ
The AR submits the complete dossier to the DGDA central office.
Step 4: Quarterly Completeness Review โ BD-Uniqueโ
The DGDA reviews submitted applications for completeness on a quarterly basis, not continuously. This means:
- Applications received in Q1 are reviewed at the Q1 completeness window
- Applications received after a quarterly window must wait for the next quarter
- Incomplete applications are returned with a deficiency list; the clock restarts
Strategic tip: Find out the DGDA's current quarterly review schedule before submitting. Submitting just before a quarterly review window maximises your chance of a prompt completeness check.
Step 5: Technical Reviewโ
Applications that pass completeness review proceed to DGDA technical review, where evaluators assess the substantive technical content of the dossier.
Step 6: Registration Decisionโ
DGDA issues the registration certificate to the AR or rejects the application with reasons. The AR has an opportunity to respond to queries during technical review.
Timelineโ
Average total timeline: 4โ6 months from submission to registration decision โ though this can vary depending on:
- Whether the quarterly review window is close when you submit
- Completeness of the dossier on first submission (incomplete dossiers reset the clock)
- Complexity of the device (Class D takes longer than Class B)
- DGDA workload at the time of submission
See Registration Timeline for detailed planning guidance.
Class A Devices โ What to Doโ
Class A devices do not require registration, but this does not mean unregulated supply:
- The device must still meet essential principles of safety and performance
- The manufacturer/AR should maintain technical documentation demonstrating compliance
- Import licence may still be required for commercial importation
- If a Class A device is later reclassified (e.g., through a change in intended purpose), registration becomes mandatory