Description
This guidance provides recommendations regarding the control of elemental impurities of human drug products marketed in the United States consistent with implementation of International Council for Harmonisation (ICH) guidance for industry Q3D Elemental Impurities (ICH Q3D).
Key Topics
Terms and concepts identified from this document
Scope & Applicability
Product Classes
3Guidance is applicable to drug and biological products
Guidance does not specifically provide recommendations addressing dosage optimization for radiopharmaceuticals
Drug products recognized in official pharmacopeias
Stakeholders
1Entity responsible for submitting NDINs
Regulatory Context
Regulatory Activities
3Biologics License Application
Abbreviated New Drug Application
New Drug Application
Document Types
2Official standards for specific drug products
Reporting category for minor changes like removing a color additive
Attributes
2Defined as a pharmaceutically acceptable intake of residual solvents; The maximum acceptable intake per day of residual solvent.
Field B.2.2.2 describing the physical form of the VMP
Technical Details
Substances
4Drug product components subject to compliance expectations
Differences in excipients may affect product stability
examples of such components include but are not limited to the active moiety (API)
Analytes tested by ICP-OES or ICP-MS
Testing Methods
1Procedures for measuring elemental impurities; Methods used to determine the amount of elemental impurities
Standards & References
External Standards
6Elemental Impurities – Procedures; Instrumental methods for elemental impurities
Elemental Impurities – Limits
Heavy Metals test previously described in USP; Non-specific heavy metals test method
Former chapter on Heavy Metals replaced by <232> and <233>
Elemental Impurities—Procedures; Describes analytical procedures for elemental impurities
Elemental Impurities Limits
Specifications
3Levels used to decide if routine testing is required
Defined as 30% of the established PDE; Defined as 30% of the PDE; compare the measured or predicted levels in the drug product to the control threshold
Chronic PDE values derived for BHT and Erucamide.
ICH References (2)
Validation of Analytical Procedures: Text and Methodology
Elemental impurities and interaction with storage containers
Related CFR Sections (3)
- 21CFR211.165§ 211.165 Testing and release for distribution.
(a) For each batch of drug product, there shall be appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release. Where sterility and/or pyrogen testing are conducted on sRead full regulation →
- 21CFR314.81§ 314.81 Other postmarketing reports.
(a) Applicability. Each applicant shall make the reports for each of its approved applications and abbreviated applications required under this section and section 505(k) of the act.Read full regulation →
- 21CFR314.70§ 314.70 Supplements and other changes to an approved NDA.
(a) Changes to an approved NDA.Read full regulation →
Enforcement Impact
Deficiencies cited in Warning Letters referencing the same regulations
Recent Cases
- 2026-02-24
CGMP/Finished Pharmaceuticals/Adulterated
AQ USA Inc., d.b.a Ross Healthcare Inc.
- 2026-02-24
Compounding Pharmacy/Adulterated Drug Products
MedisourceRx
- 2026-02-24
CGMP/Finished Pharmaceuticals/Adulterated
A. Nelson & Co. Ltd.
- 2026-02-17
CGMP/Finished Pharmaceuticals/Adulterated
Cosmetic Manufacturers Pty Ltd.
- 2025-12-23
CGMP/Finished Pharmaceuticals/Adulterated
SV Labs Corporation
Related Warning Letters (10)
- 2026-02-24
CGMP/Finished Pharmaceuticals/Adulterated
AQ USA Inc., d.b.a Ross Healthcare Inc.
- 2026-02-24
Compounding Pharmacy/Adulterated Drug Products
MedisourceRx
- 2026-02-24
CGMP/Finished Pharmaceuticals/Adulterated
A. Nelson & Co. Ltd.
- 2026-02-17
CGMP/Finished Pharmaceuticals/Adulterated
Cosmetic Manufacturers Pty Ltd.
- 2025-12-23
CGMP/Finished Pharmaceuticals/Adulterated
SV Labs Corporation
- 2025-12-23
CGMP/Finished Pharmaceuticals/Adulterated
Guangdong Renhe Guozhuang Biotechnology Co., Ltd.
- 2025-12-23
CGMP/Finished Pharmaceuticals/Adulterated
Medinatura New Mexico, Inc.
- 2025-12-16
CGMP/Finished Pharmaceuticals/Adulterated
Sklar Personal Care Inc.
- 2025-12-16
CGMP/Deviations/Biologics License Application (BLA)
Microvascular Tissue, Inc.
- 2025-12-11
CGMP/Finished Pharmaceuticals/Adulterated
Catalent Indiana, LLC
Related MFDS Guidelines
Korean regulatory guidelines covering similar topics
See Also (8)
- Sterile Drug Products Produced by Aseptic Processing — Current Good Manufacturing Practice: Guidance for Industry (Status: Final)
- Content and Review of Chemistry, Manufacturing, and Control (CMC) Information for Human Somatic Cell Therapy Investigational New Drug Applications (INDs): Guidance for FDA Reviewers and Sponsors (Status: Final)
- Residual Solvents in Drug Products Marketed in the United States: Guidance for Industry (Status: Final)
- Potency Tests for Cellular and Gene Therapy Products: Final Guidance for Industry: (Status: Final)
- Analytical Procedures and Methods Validation for Drugs and Biologics (Status: Final)
- Recommendations for Microbial Vectors Used for Gene Therapy: Guidance for Industry (Status: Final)
- Human Gene Therapy for Retinal Disorders: Guidance for Industry (Status: Final)
- Human Gene Therapy for Hemophilia: Guidance for Industry (Status: Final)