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Postapproval Changes to Drug Substances Guidance for Industry

DraftCenter for Drug Evaluation and Research Center for Biologics Evaluation and Research Center for Veterinary Medicine09/11/2018

Description

This guidance provides recommendations to holders of approved new drug applications (NDAs), abbreviated new drug applications (ANDAs), new animal drug applications (NADAs), and abbreviated new animal drug applications (ANADAs) and holders of drug master files (DMFs) and veterinary master files (VMFs) who want to make a change to the drug substance manufacturing process during the drug product application’s postapproval period.It does not address holders of biologics license applications (BLAs) or holders of any master files cross-referenced in BLAs.

Scope & Applicability

Product Classes

7
Synthetic drug substances

Guidance applies to synthetic drug substances

Semisynthetic Drug Substance

Produced by fermentation and synthesis or from natural precursors.

Modified-release products

Complex dosage forms that may require one batch per strength for evaluation

Oral suspensions

Category of dosage forms where physical properties may be critical

Solid oral dosage forms

Category of dosage forms where physical properties may be critical

Semisynthetic drug substances

Guidance applies to synthetic steps in semisynthetic drug substances

Complex Product

Products with complex active ingredients or formulations

Stakeholders

7
Holder

Holders of approved applications or master files

Drug substance manufacturer

Responsible for managing changes and qualifying vendors

Regulatory project manager

Contact the regulatory project manager assigned to the application

contract manufacturer

When a contract manufacturer is used, a quality agreement should ensure that changes in equipment are reported

Vendor

outsourced operation provider

Application Holder

Entity responsible for the approved NDA or ANDA; entity responsible for risk assessment

Master File Holder

Entity responsible for maintaining the DMF

Regulatory Context

Attributes

10
Physical Properties

Equivalence of physical properties; Evaluation of physical properties for drug substance; Properties likely to influence drug product manufacturability; Attributes such as physical state, melting point, solubility, and density.

Historical Data

Data on impurities or physical attributes from three or more consecutive batches.

Polymorphism

Occurrence of different crystalline forms of the same drug substance.

Particle Size Distribution

A measurement of the relative proportion of particles in a sample as a function of size.

Retest/expiry date

commitment to continue the stability study through the retest/expiry date

Solubility

Property used in the decision tree for in-vitro testing

Tapped density

Physical property of drug substance affecting manufacturability

Flowability

Physical property of drug substance affecting manufacturability

Particle size

Physical property of drug substance affecting manufacturability

Impurity Profile

levels of existing and new impurities; Characteristic of drug substance that may change with starting material redesignation; A comparison of the impurity profile of pre- and post-modification material to establish equivalence; Evaluation of the impurity profile for intermediates or drug substance; Potential to adversely affect drug substance quality; A description of the identified and unidentified impurities present in a drug substance.; The description of identified and unidentified impuritie

Identified Hazards

Hazards

4
Adverse Impact on Quality

Risk to identity, strength, quality, purity, or potency

Genotoxic impurity

Introduction of impurities that may cause genetic mutations

Carryover of impurities

Risk when the number of steps from the end of the process is reduced

Bioavailability

risk affected by particle size changes

Related CFR Sections (7)

Related Warning Letters (5)

  • False & Misleading Claims/Misbranded

    Novo Nordisk Inc.

    2025-09-16
  • False & Misleading Claims/Misbranded

    Eli Lilly and Company

    2025-09-16
  • False & Misleading Claims/Misbranded

    Sprout Pharmaceuticals, Inc.

    2025-06-10
  • False & Misleading Claims/Misbranded

    Sarfez Pharmaceuticals, Inc.

    2025-05-20
  • False & Misleading Claims/Misbranded

    CooperSurgical, Inc.

    2021-02-23

See Also (8)