The Central Drugs Standard Control Organisation (CDSCO)’s new standard operating procedure, released in January 2026, finally gives shape to a long-pending idea: allowing “compounding” of minor offences under drug law. The enabling rules came into force in April 2025, but only now has compounding become a working tool. Applicants may seek it before or after prosecution, provided they cooperate fully and disclose all facts. Immunity is conditional — and rightly so.

This is a practical step forward. Regulators must focus their energies on the biggest threats: spurious, adulterated, misbranded, or unsafe drugs. Criminalising clerical errors or labelling slips wastes capacity. But compounding must not become a backdoor escape. The Jan Vishwas Act expanded the list of compoundable offences. With that wider scope comes greater discretion. That discretion must be exercised transparently.

The CDSCO should publish a redacted, searchable register of all compounding decisions. It should include the type of offence, product category, licence holder, amount compounded, corrective action taken, and whether the offence was a first. Riskier cases must be tied to real-world remedies — corrective action plans, follow-up inspections, and public alerts or recalls where needed.

Penalties should be scaled. Bigger firms and bigger risks should attract higher fines. Repeat violators should face escalating sanctions. A limited window for consumer representatives to submit comments in high-risk cases would also enhance accountability.

Above all, the system must not rely on private file notes. It must show its workings. Done right, compounding can reduce judicial burden, promote self-correction, and improve safety. Done opaquely, it will only shift the problem out of view. The test of regulatory reform is not how much is permitted — but how clearly the public can see what is being done, and why.