Establishment level · Required first
The LTO authorises a business establishment to handle regulated health products. It must be obtained before any product registration or notification can be filed — making it the first and most critical step for entering the market with food, drug, cosmetic or medical device products. The LTO covers the establishment, not the individual products.
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Why it matters
What it allows, and what it prevents.
The LTO authorises an establishment to handle regulated health products. Manufacturers, importers, distributors and food, drug, cosmetic and medical device establishments all need one.
No Certificate of Product Registration and no Cosmetic Product Notification can be filed until the LTO is active. No LTO, no registration.
The licence covers your business. Individual products are registered separately on top of it, each with their own certificate and number.
Importers and distributors handling regulated products need the establishment licence in place. We file the consignee LTO alongside the standard establishment licence.
Operating with an expired LTO can result in establishment closure, product recall and administrative sanctions. Renewal is filed ahead of expiry, never after.
Who needs one
An LTO is required of any establishment that manufactures, imports, exports, distributes, wholesales or sells FDA-regulated products — food, drugs, cosmetics, medical devices, and household or urban hazardous substances. The licence attaches to the establishment handling the product, which is what decides who needs one.
Establishment types
Selling online or working from home does not exempt you. The requirement follows the handling of regulated products, not the shopfront, so online-only and home-based sellers are licensed on the same basis as physical stores.
The FDA licenses premises, including the storage used for distribution or importation — which is also why renewals carry a facility inspection. A business with nothing to inspect has nothing to license.
A food manufacturer and a cosmetics distributor apply under different establishment categories. The licence type follows both your activity and your product, so the two applications are not interchangeable.
Working turnarounds, not best cases. Each line is a filing we handle end to end.
| Filing | Code | Turnaround |
|---|---|---|
| FDA LTO — New ApplicationStart here | CM-FDA-001 | 30–40 working days |
| FDA LTO — Renewal | CM-FDA-002 | 2–3 months (incl. facility inspection) |
| FDA LTO — Variation (address / establishment details) | CM-FDA-003 | 2–3 months (incl. facility inspection) |
| FDA LTO — Consignee | CM-FDA-006 | Upon engagement |
| Pharmacist for FDA Compliance (Outsourced) | CM-FDA-008 | 3–5 working days |
Yes. The LTO licenses the establishment, not the product, and it has to be in place before any Certificate of Product Registration or Cosmetic Product Notification can be filed. It is the first step for anyone bringing food, drug, cosmetic or medical device products to market.
A new LTO application runs 30 to 40 working days. A Certificate of Product Registration takes 20 to 30 working days, and a Cosmetic Product Notification 15 to 20 working days. LTO renewals and variations take 2 to 3 months because they include a facility inspection.
CPR validity is 2 years for supplements and 5 years for food products. A CPN is valid for 1 year and renews annually. LTO renewal has to be filed before the existing licence expires.
Operating with an expired LTO can result in establishment closure, product recall and administrative sanctions. This is why renewal is filed ahead of expiry rather than after it.
The establishment that handles the product needs the LTO. For cosmetics in particular, a foreign brand selling through a local distributor has to make sure that distributor holds a valid cosmetic-establishment LTO before any notification is filed.
Yes. We provide an outsourced pharmacist for FDA compliance, typically arranged within 3 to 5 working days, for establishments that need one to satisfy their licensing conditions.
We prepare and file on your behalf, track the application through the FDA, and come back to you when something is needed rather than leaving you to chase it. Tell us the product and where you are in the process, and we will confirm exactly which filings apply and in what order.
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