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How to Prepare a Pre-Request for Designation (Pre-RFD): Guidance for Industry

FinalOffice of the Commissioner,Office of the Chief Medical Officer,Office of Combination Products11/06/2025

Description

This guidance is intended to assist sponsors in obtaining a preliminary assessment from the U.S. Food and Drug Administration (FDA or Agency) through the Pre-Request for Designation (Pre-RFD) process.  Specifically, this guidance explains the Pre-RFD process at the Office of Combination Products (OCP) and helps a sponsor understand the type of information to provide in a Pre-RFD.

Scope & Applicability

Product Classes

4
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.

Drug

Defined in section 201(g) of the FD&C Act; Articles intended for use in diagnosis, cure, mitigation, treatment, or prevention of disease; Product classification based on chemical action or specific intended uses like altering pH

Device

Defined in section 201(h) of the FD&C Act; Instrument or apparatus which does not achieve primary purpose through chemical action; Product classification based on primary intended purpose and chemical action

Biological Product

Regulated under section 351(i) of the PHS Act; Virus, therapeutic serum, toxin, vaccine, or protein applicable to prevention or treatment; Alternative regulation category for products meeting device definition

Stakeholders

1
Sponsor

Entity responsible for submitting applications under section 524B

Regulatory Context

Attributes

2
Non-binding

The legal status of Pre-RFD feedback

Mechanism of Action

How the product achieves its intended purpose.

Related CFR Sections (5)

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See Also (8)

How to Prepare a Pre-Request for Designation (Pre-RFD): Guidance for Industry | Guideline Explorer | BioRegHub