What Is CoPP? How to Apply for a Certificate of Pharmaceutical Product in India

A Certificate of Pharmaceutical Product, commonly called a CPP or CoPP, is an important regulatory document used for the international registration and export of pharmaceutical products.

Foreign drug regulatory authorities may ask an Indian manufacturer or marketing-authorisation holder to submit a CoPP while:

  • Registering a medicine
  • Renewing a product registration
  • Participating in an international tender
  • Adding a manufacturing site
  • Changing product information
  • Applying for an import authorisation
  • Demonstrating the regulatory and GMP status of a product

The certificate is issued by the competent regulatory authority of the exporting country in the format recommended by the World Health Organization.

WHO created the Certification Scheme to help participating countries obtain reliable information about pharmaceutical products moving in international commerce. The CPP is the principal document under this voluntary international scheme.

Quick Answer

In India, a licensed pharmaceutical manufacturer generally applies for WHO-GMP and CoPP through the ONDLS portal.

Before submitting the application, the manufacturer should ensure that:

  • The manufacturing site is registered on ONDLS.
  • Its manufacturing licence is uploaded and verified.
  • Approved technical staff are mapped to the licence.
  • Licensed product details are uploaded.
  • The State Drug Regulatory Authority has approved the licence and product data.
  • Product permissions are current.
  • The manufacturing facility complies with applicable GMP requirements.
  • Product-specific technical documents are available.
  • Stability, process-validation and quality-review documents are complete.

The application is examined by the concerned regulatory authorities. An inspection may be conducted or relied upon according to the current inspection status and regulatory assessment. Deficiencies must be resolved before the certificate is issued.

What Does CoPP Mean?

CoPP stands for Certificate of a Pharmaceutical Product.

The abbreviations used include:

  • CPP
  • CoPP
  • COPP

All generally refer to the same product certificate issued under the WHO Certification Scheme.

The WHO model uses the expression:

Certificate of a Pharmaceutical Product

It is not technically correct to expand CoPP as “Certificate of Pharmaceutical Products” because a CPP is normally prepared for one specific product.

What Information Does a CoPP Contain?

The WHO model CPP may contain information such as:

  • Certificate number
  • Exporting country
  • Importing or requesting country
  • Product name
  • Dosage form
  • Active ingredients
  • Strength
  • Complete composition or attached formula
  • Product-licence status
  • Marketing status in the exporting country
  • Product-licence number
  • Product-licence holder
  • Manufacturer’s name and address
  • Applicant’s name and address
  • GMP inspection status
  • Frequency of regulatory inspection
  • Confirmation regarding GMP compliance
  • Details of authorized product information
  • Certifying authority
  • Signature or secure electronic authentication
  • Issue date

The certificate establishes the regulatory status of the product and its manufacturing arrangements in the exporting country.

Does WHO Issue the CoPP?

No.

WHO recommends:

  • The certification scheme
  • The certificate format
  • Explanatory notes
  • Implementation principles

The actual certificate is issued by the competent national or regional regulatory authority of the exporting country.

In India, CDSCO and the concerned Central and State regulatory offices participate in the WHO-GMP and CoPP process.

A company should not claim that its certificate was “issued by WHO” merely because it follows a WHO-recommended format.

A more accurate statement is:

Certificate of Pharmaceutical Product issued by the competent Indian regulatory authority in the format recommended by WHO.

Purpose of a CoPP

The main purpose of a CoPP is to provide an importing-country regulator with reliable information about:

  • Whether the product is authorised in the exporting country
  • Whether it is actually marketed there
  • Who holds the product permission
  • Who manufactures the dosage form
  • Whether the manufacturing site is inspected
  • Whether the site complies with applicable GMP requirements
  • Whether the submitted product information agrees with the authorised information

WHO explains that the CPP may be used when a product is being considered for marketing authorisation and when an existing authorisation is being renewed, extended, modified or reviewed.

Is CoPP Compulsory for Every Pharmaceutical Export?

Not necessarily.

A CoPP is required when:

  • The importing-country authority asks for it.
  • It is listed in the destination-country registration dossier.
  • It is required for an international tender.
  • The overseas buyer requests it.
  • The foreign regulator requires proof of product and GMP status.

Some countries may instead or additionally request:

  • Free Sale Certificate
  • WHO-GMP certificate
  • Market Standing Certificate
  • Manufacturing licence
  • Product permission
  • Certificate of Analysis
  • Batch certificate
  • Certificate of Pharmaceutical Product
  • Legalised or apostilled documents
  • Certificate of Pharmaceutical Product issued directly to the authority
  • Written Confirmation for APIs exported to the European Union

The required documents should be confirmed before filing the export dossier.

CoPP vs WHO-GMP Certificate

CoPP and WHO-GMP certification are closely connected, but they are not identical.

PointCoPPWHO-GMP certificate
Main subjectA specific pharmaceutical productManufacturing site and approved operations
Main purposeProduct registration and international commerceConfirmation of GMP compliance
Product detailsYesMay list dosage forms or sections
Market-authorisation statusYesNormally not its primary purpose
Manufacturing-site detailsYesYes
Importing countryNormally identifiedMay not be product-country specific
ScopeProduct specificSite or manufacturing-section specific
WHO formatModel CPP formatGMP certification format followed by authority
Issuing authorityCompetent regulatory authorityCompetent regulatory authority

A manufacturer may receive WHO-GMP certification for its approved facility and separate CoPPs for individual products.

CoPP vs Free Sale Certificate

CoPPFree Sale Certificate
Provides detailed product and GMP informationPrimarily confirms lawful sale or marketability
Based on WHO-recommended certification formatFormat depends on issuing authority
Identifies manufacturing and product-licence statusUsually provides less detailed GMP information
Used in pharmaceutical registrationUsed for export or market-status confirmation
Normally product specificMay cover one or more products depending on authority

A Free Sale Certificate does not automatically replace a CoPP.

CoPP vs Market Standing Certificate

A Market Standing Certificate generally confirms matters such as:

  • Product has been licensed.
  • Product has been marketed for a stated period.
  • Manufacturing licence remains valid.
  • Regulatory record or market history, as applicable.

A CoPP provides broader information about product authorisation, manufacturing and GMP status.

CoPP vs Batch Certificate

A CoPP relates to the regulatory and manufacturing status of a product.

A batch certificate relates to a particular manufactured batch or consignment and may include:

  • Batch number
  • Manufacturing date
  • Expiry date
  • Release specifications
  • Test results
  • Confirmation of batch compliance

WHO identifies the batch certificate as a separate document under the Certification Scheme. It is normally issued by the manufacturer and relates to an individual batch.

Who Can Apply for CoPP in India?

The application is generally made by:

  • Licensed pharmaceutical manufacturer
  • Marketing-authorisation or product-permission holder
  • Authorised applicant acting with the consent of the licence holder
  • Manufacturer producing an export-only licensed product
  • Loan-licensee, subject to its approved licensing arrangements
  • Product owner working through an authorised manufacturer, where accepted

The identity and roles of the following parties should be clear:

  • Applicant
  • Product-licence holder
  • Manufacturer
  • Primary packer
  • Secondary packer
  • Testing laboratory
  • Batch-release site
  • Marketing company

The WHO model specifically provides for an applicant that may be different from the product-licence holder, but the relationship and manufacturing arrangements must be disclosed.

Can a Pharma Marketing Company Apply?

A pharma marketing company cannot represent itself as the manufacturer merely because its name appears under “Marketed by.”

Where the marketer is different from the manufacturer:

  • The actual licensed manufacturer must be disclosed.
  • The product permission should support the product.
  • A valid manufacturer–marketer or contract arrangement should exist.
  • The manufacturer’s authorisation may be required.
  • The authority should be able to verify the complete manufacturing arrangement.

The CoPP may identify:

  • Product-licence holder
  • Applicant
  • Actual dosage-form manufacturer
  • Other sites involved in manufacturing or packaging

The exact applicant arrangement should be confirmed through ONDLS and the concerned authority before submission.

Can a Third-Party Manufactured Product Obtain CoPP?

Yes, it may be possible when the product and manufacturing arrangements are properly licensed and documented.

The application should clearly identify:

  • Product owner
  • Product-permission holder
  • Manufacturing site
  • Testing site
  • Packing site
  • Batch-release responsibility
  • Contract or technical agreement
  • Applicant for the certificate

A third-party manufacturing agreement alone is not sufficient if the product permission, licence or approved manufacturing arrangement does not support the product.

Can a Loan-Licence Product Obtain CoPP?

A loan-licensee may apply subject to:

  • Valid loan licence
  • Approved product permission
  • Valid manufacturing-site licence
  • Clear technical agreement
  • GMP status of the manufacturing site
  • Acceptance of the arrangement by the concerned authority

The certificate should accurately identify the loan-licensee and the physical manufacturing site.

Current Application System in India

CDSCO directed that WHO-GMP and CoPP applications be submitted online through ONDLS.

ONDLS is a single-window platform developed by CDAC with CDSCO and State/UT Drug Regulatory Authorities. It processes manufacturing and sale licences and certificates such as:

  • CoPP
  • GMP
  • WHO-GMP
  • Market Standing Certificate
  • Free Sale Certificate
  • Performance Certificate
  • Non-Conviction Certificate

The portal currently lists WHO-GMP and Certificate of Pharmaceutical Product as available certificate services.

Physical or Online Application?

Applications should now be submitted through ONDLS.

The initial CDSCO circular instructed manufacturing units to submit WHO-GMP and CoPP applications through ONDLS and stated that physical files would not be accepted after the prescribed transition date. After an extension, CDSCO reiterated that physical submissions would not be accepted after August 15, 2025.

Prerequisites Before Filing the CoPP Application

Before applying, confirm the following.

1. Valid Manufacturing Licence

The manufacturing site should have the applicable licence, such as:

  • Form 25
  • Form 28
  • Form 25A
  • Form 28A
  • Form 28D
  • Form 28DA
  • Other applicable manufacturing licence

The form depends on the product and manufacturing arrangement.

2. Product Permission

The product should have valid approval or permission from the competent authority.

The product details should match:

  • Product name
  • Generic name
  • Composition
  • Strength
  • Dosage form
  • Manufacturing site
  • Pack size
  • Approved label
  • Shelf life
  • Storage condition

3. Approved Technical Staff

Production and testing personnel approved on the manufacturing licence should be current and mapped in ONDLS.

4. ONDLS Site Registration

The manufacturing unit must be registered through the portal.

5. Verified Licence Data

Existing licence information should be uploaded and approved by the concerned State Drug Regulatory Authority.

6. Verified Product Data

All products requested for CoPP should be mapped to the approved licence and verified by the State authority.

7. GMP Readiness

The manufacturing unit should comply with:

  • Applicable Schedule M requirements
  • Product-specific GMP requirements
  • Applicable WHO GMP expectations
  • Licence conditions
  • Approved manufacturing and testing procedures

CDSCO notified the revised Schedule M through G.S.R. 922(E), dated December 28, 2023, followed by a corrigendum and implementation-related directions.

Preliminary ONDLS Registration Procedure

CDSCO’s annexed online procedure describes the following preliminary steps:

  1. Register the manufacturing site.
  2. Register the technical staff currently endorsed on the licence.
  3. Add licensed products through the old-licence management function.
  4. Add the basic licence data.
  5. Submit the licence data to the concerned State Drug Regulatory Authority.
  6. Obtain State approval of the uploaded licence data.
  7. File the CoPP application after verification.

After State approval, the portal may generate an online number against the existing licence record.

Step-by-Step Procedure to Apply for CoPP

Step 1: Confirm the Importing-Country Requirement

Before filing, obtain a written requirement from:

  • Foreign regulatory authority
  • Importer
  • Overseas agent
  • Tendering authority
  • Registration consultant

Confirm:

  • Whether CoPP is required
  • Number of original certificates
  • Required certificate age
  • Whether a product marketed in India is compulsory
  • Whether an export-only product is acceptable
  • Whether legalisation or apostille is required
  • Whether the certificate must be sent directly by the authority
  • Whether WHO-GMP certificate is also required
  • Whether composition and product information should be attached

This prevents applying for the wrong certificate.

Step 2: Register the Corporate Entity on ONDLS

The authorised signatory should register the corporate entity with details such as:

  • Organisation name
  • Organisation type
  • CIN or PAN
  • Registered address
  • Authorised-person details
  • Identity proof
  • Address proof
  • Undertaking

ONDLS requires the corporate registration to be completed before the manufacturing unit is linked under it.

Step 3: Register the Manufacturing Site

Register the manufacturing unit and upload:

  • Unit name
  • Factory address
  • Licence number
  • Manufacturing-licence copy
  • Authorised-person details
  • Identity proof
  • Undertaking
  • Corporate passcode or linkage information

Uploaded documents should follow the portal’s file-format and size requirements.

Step 4: Add Technical Staff

Add the approved technical persons connected with:

  • Production
  • Quality Control
  • Testing
  • Section-wise manufacturing
  • Microbiology, where applicable

The details should agree with the current manufacturing licence.

Step 5: Upload Existing Licence Details

Use the old-licence management function to add:

  • Licence number
  • Licence form
  • Issue date
  • Retention or validity status
  • Approved dosage forms
  • Approved sections
  • Product list
  • Technical staff

Submit the information to the State authority for verification.

Step 6: Obtain State Approval

The State Drug Regulatory Authority verifies:

  • Licence
  • Site
  • Technical staff
  • Product permissions
  • Approved products

The applicant should resolve any mismatch before filing the certificate application.

Common mismatches include:

  • Different spelling of company name
  • Different manufacturing address
  • Old technical staff
  • Incorrect composition
  • Missing product permission
  • Changed pack size
  • Different strength
  • Unapproved brand name
  • Incomplete licence retention

Step 7: Select WHO-GMP or CoPP Service

After licence and product approval, select the required service from the certificate section.

The portal separately lists:

  • WHO-GMP
  • Certificate of Pharmaceutical Product
  • CoPP/WHO endorsement

Select the correct service according to the overseas requirement.

Step 8: Enter Product-Specific Information

Enter the required product information accurately.

It may include:

  • Brand name
  • Generic name
  • Dosage form
  • Strength
  • Complete composition
  • Product-permission number
  • Product-permission date
  • Manufacturing licence
  • Manufacturing site
  • Pack size
  • Shelf life
  • Storage condition
  • Importing country
  • Requesting authority
  • Marketing status in India
  • Applicant details

Every entry should match the approved regulatory documents.

Step 9: Upload Supporting Documents

Upload all documents required by:

  • ONDLS checklist
  • State Licensing Authority
  • CDSCO zonal or sub-zonal office
  • Product category
  • Importing-country requirement

Do not rely only on an old generic checklist because document requirements may change.

Step 10: Pay the Applicable Fee

Pay the fee generated or prescribed through the current portal and retain:

  • Payment receipt
  • Transaction reference
  • Application number
  • Submission acknowledgement

The fee may depend on the certificate service and regulatory requirements.

Step 11: Submit the Application

After final checking:

  • Digitally submit the application.
  • Download the acknowledgement.
  • Record the application number.
  • Monitor the dashboard.
  • Check regulatory queries regularly.
  • Respond within the permitted time.

Step 12: Regulatory Scrutiny

The concerned authorities may verify:

  • Licence status
  • Product approval
  • Formula
  • Manufacturing arrangements
  • Inspection status
  • GMP compliance
  • Stability data
  • Validation
  • Labelling
  • Export requirement
  • Previous certificate history

The authority may raise an online query where information is incomplete or inconsistent.

Step 13: Inspection

A GMP inspection may be conducted where:

  • The unit is applying for the first time.
  • Existing certification has expired.
  • A new dosage-form section is added.
  • Significant changes have occurred.
  • Previous compliance is not satisfactory.
  • Risk assessment requires inspection.
  • The latest inspection does not cover the requested scope.
  • Serious quality or regulatory concerns exist.

The inspection arrangement may involve officers from CDSCO and the State Licensing Authority according to the applicable jurisdiction and procedure.

Step 14: Submit CAPA

Where deficiencies are observed, submit a Corrective and Preventive Action response containing:

  • Inspection observation
  • Root-cause analysis
  • Immediate correction
  • Corrective action
  • Preventive action
  • Responsible person
  • Completion date
  • Supporting evidence
  • Effectiveness check

Avoid giving only statements such as “noted and will comply.”

Step 15: Certificate Issuance

After satisfactory review and compliance, the certificate may be issued electronically through the current regulatory system.

Check the issued certificate for:

  • Product name
  • Strength
  • Dosage form
  • Composition
  • Licence number
  • Licence holder
  • Manufacturer
  • Importing country
  • Manufacturing address
  • Certificate number
  • Issue date
  • Digital signature or authentication
  • Annexures

Report any discrepancy immediately.

Products Under Licence Consideration

CDSCO issued a circular in September 2025 regarding CoPP applications for products whose licence approval was still under consideration through ONDLS.

Under this updated approach, processing may begin while the product application is pending, but final CoPP or WHO-GMP approval should not be issued until the concerned State Licensing Authority confirms the product approval.

Applicants should not treat the submission of a product-permission application as equivalent to receiving the permission.

Documents Required for CoPP Application

The exact checklist can vary. A practical document package may contain the following.

A. Application and Legal Documents

  • Online application
  • Covering letter
  • ONDLS acknowledgement
  • Fee receipt
  • Manufacturing-licence copy
  • Licence-retention proof
  • Loan licence, where applicable
  • Product-permission copies
  • Constitution documents
  • Authorised-signatory letter
  • Manufacturer’s authorisation, where applicable
  • Contract manufacturing agreement
  • Technical or quality agreement
  • Previous WHO-GMP or CoPP certificates
  • Importing-country request, where available

B. Product-Specific Documents

  • List of products applied for
  • Product name
  • Dosage form
  • Strength
  • Complete composition
  • Approved formula
  • Product-permission number and date
  • Approved label
  • Carton artwork
  • Package insert
  • Prescribing information
  • Patient Information Leaflet, where applicable
  • Pack sizes
  • Shelf life
  • Storage conditions
  • Manufacturing process
  • Finished-product specification
  • Standard testing procedure
  • Certificate of Analysis
  • Product summary sheet

WHO recommends submitting information on the marketing authorisation, product name, dosage form, active ingredients, licence holder, manufacturing sites, complete composition, approved product information and packaging.

C. Site Master File

Submit a current Site Master File describing:

  • General company information
  • Licensed manufacturing activities
  • Pharmaceutical Quality System
  • Quality-risk management
  • Personnel
  • Premises
  • Equipment
  • Utilities
  • Documentation
  • Production
  • Quality Control
  • Contract activities
  • Storage
  • Distribution
  • Complaints
  • Recalls
  • Self-inspection
  • Product-quality review

The Site Master File should reflect the current facility and current GMP framework.

D. Technical-Staff Documents

  • Organisation chart
  • Production personnel list
  • Quality Control personnel list
  • Quality Assurance personnel list
  • Qualification certificates
  • Experience records
  • Regulatory approvals
  • Appointment letters
  • Job descriptions
  • Training records

E. Equipment and Instrument Documents

  • Section-wise machinery list
  • Laboratory instrument list
  • Equipment identification numbers
  • Qualification status
  • Calibration status
  • Preventive-maintenance status
  • Major equipment specifications
  • Computerised-system list

F. Water-System Documents

  • Water-system schematic
  • Material of construction
  • Pretreatment system
  • Purified Water or Water for Injection system
  • Storage and distribution loop
  • Sampling points
  • Qualification status
  • Sanitisation procedure
  • Trend data
  • Chemical and microbiological results

G. HVAC Documents

  • HVAC schematic
  • Air-handling unit details
  • Area classification
  • Pressure-differential plan
  • Terminal-filter configuration
  • Temperature and humidity limits
  • Qualification status
  • HEPA integrity testing, where applicable
  • Environmental-monitoring programme

H. SOP and Specification Lists

  • Master list of SOPs
  • Master list of specifications
  • Master list of testing procedures
  • Document-control procedure
  • Change-control procedure
  • Deviation procedure
  • CAPA procedure
  • OOS procedure
  • Complaint procedure
  • Recall procedure
  • Data-integrity procedure
  • Vendor-qualification procedure
  • Batch-release procedure

I. Validation Documents

  • Validation Master Plan
  • Process-validation reports
  • Cleaning-validation reports
  • Analytical-method validation
  • Analytical-method verification
  • Hold-time studies
  • Equipment qualification
  • HVAC qualification
  • Water-system qualification
  • Computerised-system validation
  • Transport validation, where applicable
  • Aseptic-process simulations, where applicable
  • Sterilisation validation, where applicable

J. Stability Documents

  • Stability protocol
  • Accelerated stability data
  • Long-term stability data
  • Intermediate-condition data, where applicable
  • Stability summary
  • Stability commitments
  • Ongoing stability programme
  • Stability-chamber qualification
  • Excursion records
  • Trend review

The stability data should support the approved:

  • Shelf life
  • Container
  • Pack size
  • Storage condition
  • Product formula
  • Manufacturing process

K. Product Quality Review Documents

  • Annual Product Quality Review or Product Quality Review
  • Number of batches manufactured
  • Number of batches rejected
  • Deviations
  • OOS results
  • Complaints
  • Recalls
  • Returns
  • Stability trends
  • Process capability
  • Change controls
  • CAPA effectiveness
  • Yield trends
  • Critical-quality trends

L. Revalidation or Renewal Documents

For renewal, revalidation or repeat certification, the authority may ask for:

  • Previous certificate
  • Export data
  • Countries supplied
  • Product-wise export quantities
  • Changes since previous inspection
  • Previous observations
  • CAPA status
  • Product Quality Reviews
  • Complaints and recalls
  • Regulatory actions
  • Updated stability data
  • Updated validation status
  • Updated Site Master File

Suggested Product Summary Sheet

A product summary sheet may include:

FieldInformation
Product nameBrand and generic name
CompositionComplete active composition
StrengthPer tablet, capsule, ml or dose
Dosage formTablet, capsule, injection, syrup etc.
Product permissionNumber and date
Manufacturing licenceForm and licence number
Batch historyBatches made during review period
Commercial scaleBatch sizes manufactured
StabilityAccelerated and long-term period completed
Process validationCompleted, ongoing or not applicable
Cleaning validationStatus
Analytical methodValidation or verification status
Reference standardsAvailability and validity
Product quality reviewLatest period completed
Complaints and recallsSummary
Previous CoPPCertificate number and issue date

Suggested Stability Summary Format

General Information

  • Product name
  • Strength
  • Dosage form
  • Batch number
  • Batch size
  • Manufacturing date
  • Stability initiation date
  • Pack style
  • Storage condition
  • Expiry or proposed shelf life

Test Results

TestSpecificationInitial3 months6 months12 months18 months24 months36 months
DescriptionApproved limit
AssayApproved limit
Related substancesApproved limit
DissolutionApproved limit
Microbial qualityApproved limit

The actual tests and time points should follow the approved stability protocol and product requirements.

What Inspectors Check During WHO-GMP Inspection

Pharmaceutical Quality System

Inspectors may review:

  • Quality policy
  • Management responsibilities
  • Quality-risk management
  • Change control
  • Deviations
  • CAPA
  • Product-quality review
  • Management review
  • Knowledge management
  • Continual improvement

Personnel

They may check:

  • Qualifications
  • Experience
  • Approved technical staff
  • Training
  • Hygiene
  • Medical examination
  • Duties and job descriptions
  • Independence of Quality Control

Premises

Inspection may cover:

  • Building condition
  • Material flow
  • Personnel flow
  • Cross-contamination control
  • Warehouses
  • Production rooms
  • Laboratories
  • Change rooms
  • Pest control
  • Waste handling
  • Maintenance

Equipment

Inspectors may assess:

  • Suitability
  • Qualification
  • Calibration
  • Preventive maintenance
  • Cleaning
  • Logbooks
  • Breakdown history
  • Computerised controls

Documentation

They may review:

  • Master formulae
  • Batch records
  • Packing records
  • SOPs
  • Specifications
  • Testing procedures
  • Raw data
  • Audit trails
  • Corrections
  • Document control
  • Record retention

Production

Production review may cover:

  • Dispensing
  • Line clearance
  • In-process controls
  • Reconciliation
  • Yield
  • Hold times
  • Process validation
  • Cleaning validation
  • Prevention of mix-ups
  • Prevention of contamination

Quality Control

Quality Control inspection may cover:

  • Sampling
  • Raw-material testing
  • Finished-product testing
  • Reference standards
  • Reagents
  • OOS investigations
  • Method validation
  • Stability
  • Data integrity
  • Retained samples

Complaints and Recalls

Inspectors may review:

  • Complaint investigations
  • Adverse-quality trends
  • Recall procedure
  • Mock recall
  • Distribution traceability
  • Returned products
  • Regulatory reporting

WHO GMP principles require licensed products to be manufactured by licensed manufacturers whose activities are regularly inspected by competent authorities.

Common Reasons for CoPP Delay

Applications may be delayed because of:

  • Licence data not mapped on ONDLS
  • State approval pending
  • Product missing from licence
  • Incorrect product composition
  • Different product name in documents
  • Expired manufacturing permission
  • Technical staff mismatch
  • Incomplete Site Master File
  • Missing stability data
  • Incomplete process validation
  • Unresolved inspection observations
  • Weak CAPA
  • Missing approved artwork
  • Different manufacturing addresses
  • Incorrect importing-country details
  • Unpaid fee
  • Delayed response to an online query

Common Reasons for Rejection

An application may be rejected or returned when:

  • The product is not approved.
  • The manufacturing licence does not cover the dosage form.
  • Product details are materially inconsistent.
  • The facility does not meet GMP requirements.
  • Serious inspection deficiencies remain unresolved.
  • False or misleading information is submitted.
  • The applicant cannot establish authority over the product.
  • The certificate request does not match the actual manufacturing arrangement.
  • Required technical documents are absent.
  • The applicant fails to respond to regulatory queries.

Validity of CoPP

The WHO model CPP records the issue date and current regulatory status of the product. It does not establish one universal validity period for every country.

Check:

  • Validity shown on the issued certificate
  • WHO-GMP certificate validity
  • ONDLS record
  • Importing-country requirement
  • Tender requirement
  • Whether changes have occurred since issuance
  • Whether the product licence remains valid
  • Whether the manufacturing site remains GMP compliant

A foreign regulator may ask for a recently issued CoPP even when an older certificate has not been formally cancelled.

When Should a Fresh CoPP Be Obtained?

A fresh certificate may be needed when:

  • Importing country changes
  • Product name changes
  • Composition changes
  • Strength changes
  • Dosage form changes
  • Manufacturing site changes
  • Product-licence holder changes
  • Manufacturing arrangement changes
  • Major packaging information changes
  • Certificate becomes too old for the destination country
  • Existing certificate expires
  • Foreign authority asks for a newly issued certificate

How Much Time Does CoPP Approval Take?

There is no single guaranteed timeline.

The processing time depends on:

  • ONDLS data verification
  • Completeness of documents
  • Inspection requirement
  • Inspection scheduling
  • Number and seriousness of deficiencies
  • CAPA response
  • State and CDSCO coordination
  • Product-permission status
  • Regulatory workload

WHO recommends that certifying authorities aim to issue a certificate ideally within 30 working days after sufficient documents are submitted, but this is an international recommendation and not a guaranteed Indian processing period.

Does CoPP Guarantee Product Registration Abroad?

No.

A CoPP supports the overseas registration application, but the foreign authority may still review:

  • Product dossier
  • Formula
  • Specifications
  • Stability
  • Bioequivalence
  • Clinical information
  • Labels
  • GMP documents
  • Pharmacovigilance
  • Local agent
  • Samples
  • Registration fee

The importing country makes the final registration decision.

Can a Product Not Marketed in India Obtain CoPP?

The WHO model certificate provides for situations where:

  • A product is authorised and marketed.
  • A product is authorised but not actually marketed.
  • Marketing authorisation is absent for a stated reason.

The certificate may record whether authorisation was:

  • Not required
  • Not requested
  • Under consideration
  • Refused

However, Indian issuance depends on valid product permissions, export status and the concerned regulatory authority’s assessment. The destination country must also accept that status.

CoPP for Export-Only Products

Export-only products may require:

  • Valid manufacturing permission
  • Export NOC or approval, where applicable
  • Importing-country formula or specification
  • Justification where the product is not marketed domestically
  • Approved manufacturing site
  • Product testing
  • GMP compliance
  • Destination-country acceptance

Do not manufacture an unapproved export product merely on the basis of a foreign purchase order.

CoPP for Ayurvedic Products

CDSCO continues to publish details of Ayurvedic products granted CoPP under the WHO-GMP Certification Scheme, including an updated list dated April 15, 2026.

However, the documentation and inspection process for Ayurvedic, Siddha and Unani products may differ from conventional allopathic pharmaceuticals.

Applicants may need documents such as:

  • AYUSH manufacturing licence
  • Product approval
  • Formula
  • Classical reference or proprietary status
  • GMP certificate
  • Raw-material controls
  • Finished-product specifications
  • Stability or shelf-life support
  • Testing methods
  • Product labels
  • Site Master File
  • Export details

Use the latest applicable CDSCO and AYUSH checklist.

Is CoPP Available for Nutraceuticals?

Ordinary FSSAI-regulated nutraceuticals are food products rather than pharmaceutical products.

A pharmaceutical CoPP should not automatically be expected for:

  • Health supplements
  • Nutraceuticals
  • Food for special dietary use
  • Foods for special medical purpose
  • Functional foods

The exporter may instead need documents such as:

  • FSSAI licence
  • Free Sale Certificate
  • Health Certificate
  • Certificate of Analysis
  • Country-of-origin certificate
  • Manufacturer declaration
  • Product registration documents required by the destination country

Product classification should be confirmed before applying.

Is CoPP Available for Medical Devices?

Medical devices are regulated under a separate framework.

A device exporter may need:

  • Free Sale Certificate
  • Market Standing Certificate
  • Manufacturing licence
  • ISO 13485 certificate
  • Certificate to Foreign Government
  • Product registration documents

Do not use the pharmaceutical CoPP process automatically for a medical device.

Practical CoPP Application Checklist

Before submission, confirm:

  • Manufacturing site registered on ONDLS
  • Corporate registration completed
  • Valid manufacturing licence uploaded
  • Licence data approved by State authority
  • Technical staff mapped
  • Product permission uploaded
  • Product mapped to licence
  • Importing country confirmed
  • Product name checked
  • Composition checked
  • Strength checked
  • Dosage form checked
  • Pack details checked
  • Approved artwork available
  • Site Master File updated
  • Stability data updated
  • Process validation completed
  • Cleaning validation completed
  • Analytical methods validated or verified
  • Product Quality Review completed
  • Water and HVAC documents updated
  • Inspection CAPA closed
  • Fee paid
  • Covering letter prepared
  • Manufacturer authorisation available
  • Application reviewed before submission

Common Mistakes to Avoid

Avoid these mistakes:

  • Saying WHO directly issued the certificate
  • Calling it Certificate of Pharmaceutical Products
  • Assuming one certificate covers every product
  • Applying before ONDLS licence verification
  • Applying for an unapproved product
  • Using an outdated Site Master File
  • Submitting three-batch validation data copied from another product
  • Showing a marketer as the manufacturer
  • Ignoring third-party manufacturing arrangements
  • Using different compositions in different documents
  • Assuming universal three-year validity
  • Applying for the wrong importing country
  • Ignoring foreign regulator requirements
  • Submitting expired stability data
  • Giving incomplete CAPA
  • Continuing to send only physical files
  • Treating CoPP as guaranteed foreign registration

Final Answer

A CoPP is a Certificate of a Pharmaceutical Product issued by the competent regulatory authority of an exporting country in the format recommended by WHO.

It provides information about:

  • Product authorisation
  • Marketing status
  • Licence holder
  • Manufacturer
  • Manufacturing site
  • GMP inspection
  • Approved product information

In India, WHO-GMP and CoPP applications are now processed through the ONDLS portal.

The main steps are:

  1. Register the corporate entity and manufacturing site.
  2. Upload the manufacturing licence.
  3. Register approved technical staff.
  4. Upload licensed products.
  5. Obtain State authority verification.
  6. Select the CoPP or WHO-GMP service.
  7. Upload product and GMP documents.
  8. Pay the required fee.
  9. Complete regulatory scrutiny and inspection.
  10. Resolve observations through CAPA.
  11. Download or receive the approved certificate.

A CoPP is product specific and should not be confused with a WHO-GMP certificate, Free Sale Certificate, Market Standing Certificate or batch certificate.

The validity or acceptance period should be taken from the issued certificate and the importing-country requirements rather than relying on a universal three-year statement.

Frequently Asked Questions

1. What is the full form of CoPP?

CoPP stands for Certificate of a Pharmaceutical Product.

2. Is CPP different from CoPP?

No. Both abbreviations are commonly used for the Certificate of a Pharmaceutical Product.

3. Does WHO issue CoPP?

No. The competent national regulatory authority issues it in the format recommended by WHO.

4. Who issues CoPP in India?

The certificate is processed through the Indian drug-regulatory system involving CDSCO and the concerned regulatory authorities.

5. Where is the application submitted?

Applications are currently submitted online through ONDLS.

6. Are physical applications accepted?

CDSCO stopped accepting physical WHO-GMP and CoPP applications after the transition to the ONDLS system.

7. Is CoPP issued for the entire factory?

No. CoPP is product specific. WHO-GMP certification mainly relates to the manufacturing site and approved activities.

8. Can one CoPP contain many products?

The WHO model CPP is intended for a single product. Multiple product requests may be processed administratively, but product-specific certificates or entries are required according to the authority’s process.

9. Is CoPP compulsory for exports?

Only when required by the importing authority, buyer, tender or destination-country registration process.

10. Is CoPP valid for three years?

Do not assume a universal three-year validity. Check the issued certificate and destination-country requirement.

11. Can a marketed-by company apply?

It may apply only under an accepted and documented arrangement. The actual licensed manufacturer and product-permission holder must be correctly identified.

12. Can third-party manufactured products obtain CoPP?

Yes, where the product permission, contract arrangement, manufacturing site and GMP status are properly documented and accepted.

13. Is WHO-GMP compulsory for CoPP?

The CPP records whether the manufacturing facilities comply with applicable GMP requirements. Therefore, satisfactory GMP status is fundamental to the certification process.

14. Can an export-only product receive CoPP?

It may be possible where the product has valid permission and the certificate accurately explains its domestic marketing status.

15. Does CoPP guarantee registration in another country?

No. The importing authority makes the final decision after reviewing the complete product dossier.

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Ajay Kamboj

Ajay Kamboj is an entrepreneur and business owners associated with many Ayurvedic and Pharmaceutical start-ups. With years of experience in Ayurvedic product marketing, pharmaceutical distribution, franchise development, and client relationship management, he regularly shares practical business insights based on real-world experiences. His articles focus on business growth, entrepreneurship, customer management, and lessons learned from the healthcare and wellness industry.

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