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Determining Whether to Submit an ANDA or a 505(b)(2) Application

FinalCenter for Drug Evaluation and Research05/10/2019

Description

This guidance is intended to serve as a foundational guidance to assist applicants in determining which one of the abbreviated approval pathways under the Federal Food, Drug, and Cosmetic Act (FD&C Act) is appropriate for the submission of a marketing application to FDA. Many potential drug product developers are not familiar with the different abbreviated approval pathways for drug products under the FD&C Act — the abbreviated approval pathways described in section 505(j) and 505(b)(2) of the FD&C Act (21 U.S.C. 355(j) and 21 U.S.C. 355(b)(2), respectively) — or the types of data and information that are permitted to support approval under those pathways. In order to familiarize potential drug product developers with these abbreviated pathways, this guidance highlights criteria for submitting applications under the abbreviated approval pathways described in section 505(j) and 505(b)(2), identifies considerations to help potential applicants determine whether an application would be more appropriately submitted under section 505(j) or pursuant to section 505(b)(2) of the FD&C Act, and provides direction to potential applicants on requesting assistance from FDA in making this determination.

Scope & Applicability

Product Classes

5
Reference Listed Drug

The drug product identified by the applicant for comparison; Comparison of ANDA product to RLD for pH adjuster differences

Parenteral drug products

Must generally contain the same inactive ingredients as the RLD

Ophthalmic drug products

Generally must be Q1/Q2 same as the RLD

Otic drug products

Generally must be Q1/Q2 same as the RLD

Combination Product

Products combining drug, device, or biological constituents; Generally recommended for Enhanced Documentation; Requires 14971-based framework incorporating ICH Q9; A drug-device combination where the device constituent part detects ingestion.

Stakeholders

2
applicant

entity submitting marketing applications

Manufacturer

Entity responsible for submitting NDINs

Regulatory Context

Attributes

8
active ingredient

criteria for sameness evaluation between proposed drug and RLD

Pharmacokinetics

PK data used to evaluate drug pharmacology.

Bioavailability

Biological property that may be altered by manufacturing changes; safety narrative should address bioavailability of the ingredients

Expiration date

should be based on appropriate supportive stability data

dosage form

The physical form of the drug product.

strength

requirement for sameness between generic and RLD

active ingredient sameness

Requirement for ANDA products to be the same as the RLD

Q1/Q2 same

Qualitatively and quantitatively the same formulation

Related CFR Sections (7)

See Also (8)