India named 41 bulk drugs it could not keep importing. Eight never found a taker.

In 2020 the Government of India drew up a list. Forty-one bulk drugs (active pharmaceutical ingredients, key starting materials and drug intermediates) where import dependence had become a strategic problem rather than a commercial one. The Production Linked Incentive scheme for bulk drugs was built to bring their manufacture back to India.

Six years on, the headline numbers are good. As of March 2026, 48 projects have been approved, covering 33 of those 41 products. Committed investment has been exceeded: ₹4,814 crore against ₹4,322 crore promised. Roughly ₹2,190 crore of imports have been avoided, with cumulative sales of ₹2,722 crore and exports of ₹528 crore.

Penicillin G is the flagship. India stopped making it commercially years ago. It is now being produced domestically again, at scale, with a minimum import price in place to protect the plant that makes it. That is a genuine reversal of a dependency most people had written off as permanent.

So the scheme works. That is the honest starting point, and it is not the interesting part.

The interesting part is the eight that are missing.

Which eight

Forty-one minus thirty-three is eight. That arithmetic is straightforward. Working out which eight is not, and that difficulty is itself worth reporting.

The government publishes the list of 41. It publishes approvals, in tranches, as separate documents. It publishes headline counts in press releases and parliamentary answers. What it does not publish, anywhere I could find, is the reconciliation: a single current statement of which products still have no project attached.

Working from the scheme's product annexure and the Department of Pharmaceuticals' published list of approved applicants, the products that appear to have no approved project are:

Erythromycin Thiocyanate · Neomycin · Gentamycin · Clindamycin Base · Streptomycin · Tetracycline · 2-Methyl-5-Nitro-Imidazole · Dicyandiamide

I want to be precise about the confidence here. The count is certain, because the government has stated it. The composition of the list is a reconstruction, built by subtracting published approvals from the published annexure. It reconciles to exactly eight, which is a good sign, but approvals are published piecemeal and I have not found an official document naming these eight together. I have asked the Department of Pharmaceuticals for the consolidated position. If this list is wrong, it will be corrected here and logged on the corrections page.

There is one strong piece of corroborating evidence. Partway through the scheme, the government re-opened applications for products that had failed to attract bidders the first time around. That re-tender list included Neomycin, Gentamycin, Clindamycin Base, Tetracycline and Streptomycin, five of the eight above. It also included Vitamin B1, CDA, Norfloxacin, Artesunate and Aspirin, all of which were subsequently taken up. So the eight are not a random residue. They are, for the most part, products that were offered twice and declined twice.

The pattern

Sort the 41 by target segment and the shape becomes obvious.

Segment IV, the ordinary chemical-synthesis APIs such as Atorvastatin, Telmisartan, Levofloxacin and Acyclovir, is essentially fully subscribed. Twenty-three products, and close to all of them taken.

Segment II, the fermentation-based niche products, has five of ten covered. Half the segment went unwanted.

Segment I, the four large fermentation-based starting materials, has three of four.

Seven of the eight uncovered products are fermentation-based, or sit in fermentation-heavy antibiotic chains.

That is the finding. India's remaining dependence is not scattered randomly across eight leftover molecules. It is concentrated almost entirely in one kind of chemistry.

Why fermentation resisted

Chemical synthesis and fermentation are different industrial propositions, and the difference is what the incentive scheme ran into.

A synthesis plant is comparatively cheap, quick to build, and competes on process chemistry and yield, areas where Indian manufacturers are world-class. An incentive that improves the margin by a few percentage points can flip the investment case.

Fermentation is a different animal. It needs very large capital, long payback periods, continuous cheap power and steam, effluent handling at scale, and above all volume. China built that base over three decades and runs it at a unit cost Indian producers have struggled to approach. A production-linked incentive improves the economics at the margin. It does not close a structural cost gap.

Penicillin G is the exception that demonstrates the rule. It took one of the largest pharmaceutical groups in the country to build it, and after the plant started, the government set a minimum import price to stop cheaper imports undercutting it. Capacity alone was not enough. It needed a tariff wall behind it.

Which raises the question the eight pose: if that is what it took for the one fermentation product that succeeded, what exactly is the plan for the seven that nobody bid on?

What this means in practice

For anyone sourcing these inputs, the practical reading is that the PLI scheme has not changed their position and is not going to. There is no domestic project coming. For Neomycin, Gentamycin, Streptomycin, Tetracycline and Clindamycin Base, the supply picture in 2030 looks much like it does today unless something other than this scheme changes it.

That is a different planning horizon from the products in Segment IV, where domestic capacity is arriving and the sensible question is when to qualify a local vendor.

Meanwhile China's share of India's total bulk drug imports has held between roughly 70 and 74 percent across FY24 and FY25. The absolute value of imports substituted is real. The share has barely moved.

What's next

I am working through these eight one at a time: what each goes into, who imports them and in what volume, which Chinese provinces they come from, and what substitution would actually require. That work will appear here, and each molecule will go into the tracker with its trade data and sources attached.

If you work in procurement or supply chain at a manufacturer using any of these, I would like to hear which ones actually worry you, and whether the reading above matches what you see from the inside. Corrections and disagreements are welcome and will be published.

Sources. Product annexure by target segment: ICRA, Indian Pharmaceutical Industry, June 2021. Approved applicants: Department of Pharmaceuticals, published applicant lists under the PLI scheme for KSMs/DIs/APIs. Scheme status: PIB, 13 April 2025 (41 identified bulk drugs; 48 projects selected); Ministry of Chemicals and Fertilizers, 10 March 2026 (48 projects covering 33 drugs; investment and import substitution figures); PIB, 19 August 2025 (production capability established for 26 products as of June 2025).

Note on confidence. The count of eight is from official statements. The named composition of those eight is a reconstruction from published sources and is not yet officially confirmed. It will be updated here when it is.

Feedstock India does not provide investment advice and makes no recommendation regarding any security.