Description
This guidance addresses how to comply with the final rule on postmarketing safety reporting (PMSR) requirements for combination products that FDA issued on December 20, 2016 (81 FR 92603, hereafter the "combination product PMSR final rule," "final rule," or "rule"). The rule describes how to comply with PMSR requirements for combination products that have received FDA marketing authorization. Although the PMSR regulations for drugs, devices, and biological products share many similarities, each set of regulations establishes distinct reporting requirements, including reporting triggers and timeframes. The final rule addresses the application of these regulatory requirements to combination products to ensure consistent and complete reporting while avoiding duplication.
Scope & Applicability
Product Classes
5Products 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.
Device application combination product example
Components combined or mixed and produced as a single entity like a prefilled syringe.
Separate products packaged together in a single package.
Separately packaged products intended for use only with each other.
Stakeholders
5Entity subject to the PMSR final rule for a combination product.; Entity holding the only application or all applications for a combination product; Entity responsible for safety reporting for the combination product as a whole.; Entity responsible for submitting safety reports; Entity responsible for submitting PMSR reports for combination products; Must retain PMSR records for the longest time period required under all applicable requirements.; Entity responsible for submitting combined FAR/BP
Entity responsible for submitting NDINs
Must comply with registration if meeting facility/responsible person definitions
Entity responsible for submitting NDINs
Entity subject to the PMSR final rule for a constituent part of a combination product.; Entity holding an application for a constituent part marketed by different applicants; Entity responsible for a specific part of a combination product.; Entities required to share information regarding deaths or serious injuries; Subject to separate recordkeeping and information sharing requirements.; Entity subject to the combination product PMSR final rule
Regulatory Context
Attributes
4Used to determine reporting requirements for foreign products
Time a device is expected to remain functional after being placed into use.
The mandatory timeframe for submitting a FAR after receiving reportable information.
Timeline for submitting BPDRs from the day of acquiring information
Identified Hazards
Hazards
2A condition triggering a Field Alert Report
Drug coating contaminants traced to production equipment
Related CFR Sections (19)
- 21CFR803.19§ 803.19 Are there exemptions, variances, or alternative forms of adverse event reporting requirements?
(a) We exempt the following persons from the adverse event reporting requirements in this part:Read full regulation →
- 21CFR310.305§ 310.305 Records and reports concerning adverse drug experiences on marketed prescription drugs for human use without approved new drug applications.
(a) Scope. FDA is requiring manufacturers, packers, and distributors of marketed prescription drug products that are not the subject of an approved new drug or abbreviated new drug application to establish and maintain records and make reports to FDA of all serious, unexpected adverse drug experiencRead full regulation →
- 21CFR803.56§ 803.56 If I am a manufacturer, in what circumstances must I submit a supplemental or followup report and what are the requirements for such reports?
If you are a manufacturer, when you obtain information required under this part that you did not provide because it was not known or was not available when you submitted the initial report, you must submit the supplemental information to us within 30 calendar days of the day that you receive this inRead full regulation →
- 21CFR806.20§ 806.20 Records of corrections and removals not required to be reported.
(a) Each device manufacturer or importer who initiates a correction or removal of a device that is not required to be reported to FDA under § 806.10 shall keep a record of such correction or removal.Read full regulation →
- 21CFR314.80§ 314.80 Postmarketing reporting of adverse drug experiences.
(a) Definitions. The following definitions of terms apply to this section:Read full regulation →
- 21CFR4.105§ 4.105 What are the postmarketing safety reporting recordkeeping requirements for your combination product or constituent part?
(a) If you are a constituent part applicant:Read full regulation →
- 21CFR4.102§ 4.102 What reports must you submit to FDA for your combination product or constituent part?
(a) In general. If you are a constituent part applicant, the reporting requirements applicable to you that are identified in this section apply to your constituent part, and if you are a combination product applicant, the reporting requirements applicable to you that are identified in this section aRead full regulation →
- 21CFR4.103§ 4.103 What information must you share with other constituent part applicants for the combination product?
(a) When you receive information regarding an event that involves a death or serious injury as described in § 803.3 of this chapter , or an adverse experience as described in § 314.80(a) of this chapter or § 600.80(a) of this chapter , associated with the use of the combination product, you must proRead full regulation →
- 21CFR806.10§ 806.10 Reports of corrections and removals.
(a) Each device manufacturer or importer shall submit a written report to FDA of any correction or removal of a device initiated by such manufacturer or importer if the correction or removal was initiated:Read full regulation →
- 21CFR606.171§ 606.171 Reporting of product deviations by licensed manufacturers, unlicensed registered blood establishments, and transfusion services.
(a) Who must report under this section? You, a licensed manufacturer of blood and blood components, including Source Plasma; an unlicensed registered blood establishment; or a transfusion service who had control over the product when the deviation occurred, must report under this section. If you arrRead full regulation →
- 21CFR600.14§ 600.14 Reporting of biological product deviations by licensed manufacturers.
(a) Who must report under this section?Read 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 →
- 21CFR803.3§ 803.3 How does FDA define the terms used in this part?
Some of the terms we use in this part are specific to medical device reporting and reflect the language used in the statute (law). Other terms are more general and reflect our interpretation of the law. This section defines the following terms as used in this part:Read full regulation →
- 21CFR3.2§ 3.2 Definitions.
For the purpose of this part:Read full regulation →
- 21CFR4.100§ 4.100 What is the scope of this subpart?
(a) This subpart identifies postmarketing safety reporting requirements for combination product applicants and constituent part applicants.Read full regulation →
- 21CFR4.101§ 4.101 How does the FDA define key terms and phrases in this subpart?
Abbreviated new drug application (ANDA) has the same meaning given the term “abbreviated application” in § 314.3(b) of this chapter .Read full regulation →
- 21CFR600.80§ 600.80 Postmarketing reporting of adverse experiences.
(a) Definitions. The following definitions of terms apply to this section:Read full regulation →
- 21CFR803.53§ 803.53 If I am a manufacturer, in which circumstances must I submit a 5-day report?
You must submit a 5-day report to us with the information required by § 803.52 in accordance with the requirements of § 803.12(a) no later than 5 work days after the day that you become aware that:Read full regulation →
- 21CFR803.50§ 803.50 If I am a manufacturer, what reporting requirements apply to me?
(a) If you are a manufacturer, you must report to us the information required by § 803.52 in accordance with the requirements of § 803.12(a) , no later than 30 calendar days after the day that you receive or otherwise become aware of information, from any source, that reasonably suggests that a deviRead full regulation →
Related Warning Letters (10)
- 2025-11-25
Compounding Pharmacy/Adulterated Drug Products
Wells Pharma of Houston, LLC
- 2025-10-28
CGMP/QSR/Medical Devices/Adulterated/Misbranded
Royal Philips
- 2025-09-30
Medical Device Reporting/Misbranded
Insung Medical Co. Ltd.
- 2025-09-16
False & Misleading Claims/Misbranded
Novo Nordisk Inc.
- 2025-09-16
False & Misleading Claims/Misbranded
Eli Lilly and Company
- 2025-08-05
CGMP/QSR/Medical Devices/Adulterated/Misbranded
Visgeneer, Inc
- 2025-07-08
Medical Device Reporting/Misbranded
Insightra Medical Inc.
- 2025-06-24
CGMP/QSR/Medical Devices/Adulterated
Aju Pharm Co., Ltd.
- 2025-06-10
False & Misleading Claims/Misbranded
Sprout Pharmaceuticals, Inc.
- 2025-06-03
CGMP/QSR/Medical Devices/Adulterated
DFI Co., Ltd.
See Also (8)
- Medical Device Reporting for Manufacturers : Guidance for Industry and Food and Drug Administration Staff (Status: Final)
- Electronic Submission of IND Safety Reports Technical Conformance Guide : Guidance for Industry (Status: Final)
- Providing Submissions in Electronic Format — Postmarketing Safety Reports (Status: Final)
- Sponsor Responsibilities - Safety Reporting Requirements and Safety Assessment for IND and Bioavailability/Bioequivalence Studies: Draft Guidance for Industry (Status: Draft)
- Postmarketing Adverse Event Reporting for Medical Products and Dietary Supplements During a Pandemic (Status: Final)
- Specifications for Preparing and Submitting Electronic ICSRs and ICSR Attachments (Status: Final)
- Adverse Event Reporting for Outsourcing Facilities Under Section 503B of the Federal Food, Drug, and Cosmetic Act (Status: Final)
- Providing Submissions in Electronic Format — Postmarketing Safety Reports for Vaccines: Guidance for Industry (Status: Final)