ANDA Submissions — Content and Format of Abbreviated New

Guidance for Industry
ANDA Submissions — Content
and Format of Abbreviated New
Drug Applications
DRAFT GUIDANCE
This guidance document is being distributed for comment purposes only.
Comments and suggestions regarding this draft document should be submitted within 60 days of
publication in the Federal Register of the notice announcing the availability of the draft
guidance. Submit electronic comments to http://www.regulations.gov. Submit written
comments to the Division of Dockets Management (HFA-305), Food and Drug Administration,
5630 Fishers Lane, rm. 1061, Rockville, MD 20852. All comments should be identified with
the docket number listed in the notice of availability that publishes in the Federal Register.
For questions regarding this draft document contact (CDER) Elizabeth Giaquinto 240-402-7930
or (CBER) Office of Communication, Outreach, and Development, 800-835-4709 or 240-4027800.
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Drug Evaluation and Research (CDER)
Center for Biologics Evaluation and Research (CBER)
June 2014
Generics
Guidance for Industry
ANDA Submissions — Content
and Format of Abbreviated New
Drug Applications
Additional copies are available from:
Office of Communications
Division of Drug Information, WO51, Room 2201
Center for Drug Evaluation and Research
Food and Drug Administration
10903 New Hampshire Ave., Silver Spring, MD 20993
Phone: 301-796-3400; Fax: 301-847-8714
[email protected]
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm
and/or
Office of Communication, Outreach and Development
Center for Biologics Evaluation and Research
Food and Drug Administration
10903 New Hampshire Ave., WO 71, Room 3128
Silver Spring, MD 20993
Phone: 800-835-4709 or 240-402-7800
[email protected]
http://www.fda.gov/BiologicsBloodVaccines/GuidanceComplianceRegulatoryInformation/Guidances/default.htm
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Drug Evaluation and Research (CDER)
Center for Biologics Evaluation and Research (CBER)
June 2014
Generics
Contains Nonbinding Recommendations
Draft — Not for Implementation
TABLE OF CONTENTS
I.
INTRODUCTION............................................................................................................. 1
II.
BACKGROUND ............................................................................................................... 2
A.
Module 1 – Administrative Information ...................................................................................... 4
1.
2.
3.
4.
5.
B.
Forms and Cover Letter ................................................................................................................... 4
Administrative Information .............................................................................................................. 4
References ........................................................................................................................................ 6
Other Correspondence ..................................................................................................................... 6
Labeling ........................................................................................................................................... 8
Module 2 – CTD Summaries....................................................................................................... 10
1. Quality Overall Summary .............................................................................................................. 10
2. Clinical Summary .......................................................................................................................... 10
C. Module 3 – Quality....................................................................................................................... 11
1.
2.
3.
4.
5.
D.
Drug Substance .............................................................................................................................. 11
Drug Product ................................................................................................................................. 13
Appendices ..................................................................................................................................... 19
Regional Information ..................................................................................................................... 20
Literature References ..................................................................................................................... 20
Module 4 – Nonclinical Study Reports....................................................................................... 20
E.
Module 5 – Clinical Study Reports............................................................................................. 21
1. Complete Study Data ..................................................................................................................... 21
2. Literature References ..................................................................................................................... 23
APPENDIX A: REFERENCED GUIDANCES ....................................................................... 24
APPENDIX B: COVER LETTER TEMPLATE ..................................................................... 27
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Guidance for Industry 1
ANDA Submissions — Content and Format of Abbreviated New
Drug Applications
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This draft guidance, when finalized, will represent the Food and Drug Administration’s (FDA’s) current
thinking on this topic. It does not create or confer any rights for or on any person and does not operate to
bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of
the applicable statutes and regulations. If you want to discuss an alternative approach, contact the FDA
staff responsible for implementing this guidance. If you cannot identify the appropriate FDA staff, call
the appropriate number listed on the title page of this guidance.
I.
INTRODUCTION
This guidance is intended to assist applicants in preparing abbreviated new drug applications
(ANDAs) for submission to the Food and Drug Administration (FDA) under section 505(j) of the
Federal Food, Drug and Cosmetic Act (the FD&C Act) (21 U.S.C. 355(j)). This guidance details
the information to be provided in each section of the Common Technical Document (CTD)
format for human pharmaceutical product applications and identifies supporting guidance
documents and recommendations issued by FDA to assist in preparing the submission. This
guidance does not address the fee structure or payment of obligations under the Generic Drug
User Fee Amendments (GDUFA) 2 and does not address the submission and assessment of drug
master files (DMFs), amendments to original ANDAs, and changes being effected or prior
approval supplements.
This guidance identifies the information an applicant should include to ensure that a complete,
high-quality application is submitted to FDA. FDA has previously published guidance on the
filing process, including the refuse-to-receive standards, which should be reviewed thoroughly to
avoid common deficiencies found in ANDA submissions (Ref. 1).
FDA’s guidance documents, including this guidance, do not establish legally enforceable
responsibilities. Instead, guidances describe the Agency’s current thinking on a topic and should
be viewed only as recommendations, unless specific regulatory or statutory requirements are
cited. The use of the word should in Agency guidances means that something is suggested or
recommended, but not required.
1
This guidance has been prepared by the Office of Generic Drugs in the Center for Drug Evaluation and Research
(CDER) at the Food and Drug Administration in cooperation with the Center for Biologics Evaluation and Research.
2
Information on fees and industry obligations is available at
http://www.fda.gov/ForIndustry/UserFees/GenericDrugUserFees/default.htm.
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II.
BACKGROUND
Procedures for ANDAs submissions are set forth in FDA’s regulations in part 314 (21 CFR part
314). An ANDA is usually 3 submitted for a drug product that is the same as an already approved
drug or listed drug. A listed drug is defined in § 314.3(b) as a new drug product that has an
effective approval under section 505(c) of the FD&C Act for safety and effectiveness or under
section 505(j) of the FD&C Act, which has not been withdrawn or suspended under section
505(e)(1) through (e)(5) or (j)(5) of the FD&C Act, and which has not been withdrawn from sale
for what FDA has determined are reasons of safety or effectiveness (§ 314.161). An applicant
submits an ANDA based on a listed drug, and the previously approved drug product on which the
ANDA relies is officially known as the reference listed drug (RLD). A reference listed drug (RLD)
is defined as the listed drug identified by FDA as the drug product upon which an applicant relies
in seeking approval of its abbreviated application (§ 314.3(b)). FDA lists approved drugs that
may be referenced in an ANDA in the Approved Drug Products with Therapeutic Equivalence
Evaluations (the Orange Book). 4 The Orange Book is updated by a monthly cumulative
supplement.
On July 9, 2012, GDUFA was signed into law by the President to speed the delivery of safe and
effective generic drugs to the public and reduce costs to industry. Under GDUFA, FDA agreed
to meet certain obligations as laid out in the GDUFA Commitment Letter. 5 Among these
obligations is FDA’s commitment to performance metrics for the review of new ANDAs that are
submitted electronically following the electronic CTD (eCTD) format. For example, FDA has
committed to review and act 6 on 90 percent of original ANDA submissions within 10 months
from the date of submission in Year 5 of the program, which begins on October 1, 2016.
To meet these performance goals, FDA is issuing this guidance to assist ANDA applicants in
improving the quality of submissions, to increase the number of original ANDAs acknowledged
for receipt upon initial submission, and to decrease the number of review cycles. FDA is
committed to providing comprehensive assistance in the early stages of the application process
so that an original ANDA will contain all information necessary for FDA to complete its review
in one review cycle.
III.
CTD FORMAT
The CTD format was developed by the International Conference on Harmonisation (ICH) in an
attempt to streamline the variability of submission requirements among Japan, the European
Union, and the United States. The CTD collects quality, safety, and efficacy information into a
common format that has been adopted by ICH regulatory authorities. As previously stated, only
3
An ANDA may be submitted for certain changes in drug product that differ from the RLD in accordance with
section 505(j)(2)(C) of the FD&C Act and § 314.93.
4
Available at http://www.accessdata.fda.gov/scripts/cder/ob/default.cfm.
5
See GDUFA Program Performance Goals and Procedures available at
http://www.fda.gov/downloads/ForIndustry/UserFees/GenericDrugUserFees/UCM282505.pdf.
6
As defined in the Commitment Letter, an action on a submission includes issuance of a complete response, an
approval letter, a tentative approval letter, or a refuse-to-receive action.
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ANDA submissions made electronically following the eCTD format on the date of submission
will be subject to the review metric goals described in the GDUFA Commitment Letter. 7
Section 745A(a) of the FD&C Act, added by section 1136 of the Food and Drug Administration
Safety and Innovation Act (FDASIA) (Pub. L. 112-144), requires that submissions under section
505(b), (i), or (j) of the FD&C Act and section 351(a) or (k) of the Public Health Service Act (42
U.S.C. 262(a) or (k)) be submitted in electronic format specified by FDA, beginning no earlier
than 24 months after FDA issues a final guidance specifying an electronic submission format.
When finalized, the guidance for industry Providing Regulatory Submissions in Electronic
Format — Certain Human Pharmaceutical Product Applications and Related Submissions Using
the eCTD Specifications (Ref. 2) will implement the electronic submission requirements of
section 745A(a) of the FD&C Act by requiring the eCTD format for ANDA submissions,
among other submission types.
Applicants are reminded that any record in electronic form submitted to FDA under requirements
of the FD&C Act are subject to the provisions of 21 CFR part 11 (part 11) unless exempted. Part
11 regulations were issued in 1997 to provide criteria for acceptance of electronic records,
electronic signature and handwritten signatures executed to electronic records as equivalent to
paper records and handwritten signatures on paper (Ref. 3).
FDA has issued several guidance documents specific to the CTD and eCTD submissions.8 The
information contained in these guidances focuses on the technical aspects of filing a CTD
application and should be reviewed thoroughly prior to submitting an ANDA. This guidance
addresses the content of the CTD for an original ANDA.
The CTD is comprised of the following modules:
•
•
•
•
•
Module 1: 9 Administrative information;
Module 2: CTD Summaries;
Module 3: Quality;
Module 4: Nonclinical study reports; and
Module 5: Clinical study reports.
The sections that follow in this guidance detail the information to be submitted in the applicable
Modules, sections, and subsections.
7
See Commitment Letter at 7.
See the Drugs guidance Web page at
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm and electronic
submissions Web page at
http://www.fda.gov/Drugs/DevelopmentApprovalProcess/FormsSubmissionRequirements/ElectronicSubmissions/de
fault.htm. See the Biologics Web page at
http://www.fda.gov/BiologicsBloodVaccines/DevelopmentApprovalProcess/ucm163685.htm.
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Module 1 contains administrative information and is not considered part of the “common” application. Each
regulatory authority that accepts the CTD uses its own Module 1. The information described for Module 1 in this
guidance applies only to ANDAs submitted to the U.S. FDA. Modules 2 through 5 of the CTD are common for all
regions.
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A. Module 1 – Administrative Information
1. Forms and Cover Letter
Section 1.1 of the ANDA submission contains several forms. 10
1.1.2 Contains the completed, signed Application Form FDA 356h (§ 314.94(a)(1)). 11
Applicants should provide complete contact information, including phone and fax numbers, for
the agent stationed at each facility listed in the 356h form, along with detailed descriptions of the
type of testing performed at each, where applicable. Applicants will be notified of failure to
complete facility and testing information. Failure to provide the requested information in a
timely fashion will result in the application being refused for receipt (Ref. 1). Applicants may
use continuation pages, as necessary.
1.1.2 Also contains copy of the GDUFA user fee cover sheet (FDA Form 3794). 12
1.2 Contains a cover letter. A suggested cover letter template is attached to this guidance at
Appendix B.
1.2.1 Contains the completed, signed Form FDA 3674, Certification of Compliance Under 42
U.S.C. 282(j)(5)(B) with Requirements of ClinicalTrials.gov Data Bank (42 U.S.C. 282(j)).
2. Administrative Information
1.3.1.2 Contains a U.S. agent letter of appointment, if applicable. The U.S. agent letter of
appointment is a separate document submitted in addition to the U.S. agent’s signature on Form
356h, if applicable. If the applicant does not reside or have a place of business in the United
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FDA Forms listed in this section and other parts of this guidance are available at
http://www.fda.gov/AboutFDA/ReportsManualsForms/Forms/default.htm.
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For original (initial) applications, Field 29 should include complete information on the locations of all
manufacturing, packaging, and control sites for both drug substance and drug product. For each site, include the
establishment name, address, registration (FEI) number, Master File (MF); Drug Master File (DMF) or Biologic
Master File (BMF) number (for facilities used under a MF), and establishment DUNS number. Indicate whether the
establishment is new to the application (new establishments will have, by default, a “pending” status). If the
establishment is not new, indicate its current status (e.g., active, inactive, or withdrawn) in the appropriate box. Also
provide the name, address, phone number, fax number and email address for the contact at the site. In the section
“Manufacturing Steps, and/ or Type of Testing,” provide a brief description of the specific manufacturing steps
and/or type of testing (e.g., final dosage form, stability testing) conducted at the site (i.e., describe the type(s) of
assays or testing completed). Also, indicate whether the site is ready for inspection so that FDA can evaluate
whether the site is able to reliably perform intended operation(s) at a commercial scale. Regarding readiness for
commercial manufacturing, refer to Compliance Program Guidance Manual 7346.832. If the establishment is not
ready for inspection at the time of submission of Form 356h, indicate when it will be ready. Instructions for
completing FDA Form 356h are available at
http://www.fda.gov/downloads/aboutfda/reportsmanualsforms/forms/ucm321897.pdf.
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All applicants submitting original ANDAs, with the exception of positron emission tomography drugs (section
744B(l) of the FD&C Act), are required to pay the generic drug user fee. See Generic Drug User Fee Cover Sheet
and Payment Information available at http://www.fda.gov/forindustry/userfees/genericdruguserfees/ucm322629.htm.
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States, an agent that resides or maintains a place of business in the United States must
countersign the application (§ 314.50(a)(5)).
1.3.2 Contains the field copy certification (§ 314.94(d)(5)). The applicant will certify that the
field copy submitted to the appropriate district office is a true copy of the technical section
contained in the archival and review copies of the ANDA.
1.3.3 Contains the debarment certification required under the Generic Drug Enforcement Act of
1992 (section 306(k) and 306(a) and (b) of the FD&C Act (21 U.S.C. 335a(k) and 335(a) and
(b))). The applicant must certify that it did not and will not use the services of any debarred
persons in connection with the application. The applicant must also list all convictions described
in the FD&C Act (section 306(k) and 306(a) and (b)). The applicant may use the following
language from section 306(k)(1) for the certification required for section 1.3.3: 13
(Name of Applicant) hereby certifies that it did not and will not use in any capacity the
services of any person debarred under section 306 of the Federal Food, Drug, and
Cosmetic Act in connection with this application.
(See also Ref. 4.)
1.3.4 Contains financial certification for any clinical investigator who has no disclosable
financial interests in, or arrangements with, any applicant of the covered clinical study (FDA
Form 3454) or disclosure statement for each clinical investigator who, or whose spouse or
dependent child, had disclosable financial interests in and/or arrangements with any sponsor of
the covered clinical study (FDA Form 3455) (21 CFR part 54 and § 54.2(e)).
1.3.5 Contains patent information and certification. Applicants are required to list each patent
issued by the U.S. Patent and Trademark Office that claims the drug substance, drug product, or
that claims a use of the RLD that is cited by the ANDA (§ 314.94(a)(12)). FDA recommends
that when providing patent information, applicants include the expiration date for each patent,
whether the RLD is protected by any pediatric exclusivity, and when that pediatric exclusivity
will expire. For each patent listed, the applicant must certify to one of the following paragraphs
(§ 314.94(a)(12)(i)(A)(1) through (4)):
•
•
•
•
That the patent information has not been submitted to FDA (Paragraph I certification)
That the patent information has expired (Paragraph II certification)
The date on which the patent will expire (Paragraph III certification)
That the patent is invalid, unenforceable, or will not be infringed by the manufacture,
use, or sale of the drug product for which the ANDA is submitted (Paragraph IV
certification)
If the RLD is covered by a patent claiming a method of using the listed drug and the labeling for
the drug product for which the applicant is seeking approval does not include any indications that
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Qualifying phrases, such as “to the best of our knowledge,” should be avoided.
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are covered by the use patent, the applicant must also submit a statement explaining that the
method of use patent does not claim any of the proposed indications (§ 314.94(a)(12)(iii)).
Applicants submitting a Paragraph IV certification will provide the following language from
§ 314.94(a)(12)(i)(A)(4):
I, (name of applicant), certify that Patent No.
(is invalid, unenforceable, or
will not be infringed by the manufacture, use, or sale of) (name of proposed drug
product) for which this application is submitted.
Applicants submitting a Paragraph IV certification must also certify that they will provide notice
to the owner of the patent(s) and the holder of the approved application that lists the patent(s)
that is/are being challenged (§ 314.94(a)(12)(i)(A)(4)). The process for notice is provided in
section 505(j)(2)(B) of the FD&C Act and § 314.95. 14
Applicants should also submit an exclusivity statement regarding their marketing intentions.
This statement is relevant when the generic applicant intends to remove or carve out any
protected indication(s) from the labeling in order to gain market entry prior to a use’s expiry.
3. References
1.4.2 Contains the statement of right of reference for each and every DMF referenced in the
application. Applicants should submit the letter of authorization (LOA) provided to the applicant
by the DMF holder which gives authorization to rely on the information in the DMF (§
314.420(d)). 15
4. Other Correspondence
1.12.4 Contains a statement that a request for a proprietary name has been made, if applicable.
An ANDA applicant requesting a proprietary name should submit that request when the ANDA
is submitted to ensure an acceptable name is available at the time of approval. When requesting
a proprietary name, a separate electronic submission should be made and identified as a
“REQUEST FOR PROPRIETARY NAME REVIEW” (Ref. 5).
1.12.11 Must contain the basis for submission, which is the reference to the RLD
(§ 314.94(a)(3)). Applicants should review the guidance for industry Variations in Drug
Products that May Be Included in a Single ANDA (Ref. 6) to determine whether one or more
ANDAs should be submitted for variations of a specific drug product dosage form. The
applicant should provide: (1) the name of the RLD; (2) the NDA or ANDA number of the RLD;
and (3) the holder of the application for the RLD.
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Notice is to be provided only after the applicant has received a formal correspondence from FDA stating that the
ANDA has been acknowledged for receipt.
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More information on DMFs and the list of received DMFs is available at
http://www.fda.gov/Drugs/DevelopmentApprovalProcess/FormsSubmissionRequirements/DrugMasterFilesDMFs/d
efault.htm.
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For an ANDA based on an approved petition under § 10.30 (21 CFR 10.30) or § 314.93, this
section must contain the FDA docket number and a copy of FDA’s correspondence approving
the suitability petition (§ 314.94(a)(3)(iii)). If the generic drug differs from the RLD in strength,
route of administration, dosage form, or single active ingredient in a combination drug product,
applicants must first submit a suitability petition to FDA’s Division of Dockets Management to
obtain permission to file their ANDA (§ 314.93; § 10.20 (21 CFR 10.20), § 10.30). The
applicant must submit the suitability petition in accordance with the requirements of §§ 10.20
and 10.30 (§ 314.93(c)). The suitability petition must be approved before the ANDA is
submitted (§ 314.93(b)). The information to be included in the suitability petition is listed at
§ 314.93(d). FDA will review the suitability petition to determine whether the requested change
from the listed drug will have an impact on the safety and effectiveness of the generic product
and if any applicable requirements of the Pediatric Research Equity Act (PREA) may be waived
(Ref. 7). After a suitability petition is approved for a change to a drug product, any applicant
may refer to that petition as the basis of submission for an ANDA. Once an application based on
a suitability petition is approved, the suitability petition may no longer be relied upon as a basis
of submission. The approved drug product will become the RLD for the basis of submission.
When an applicant wants FDA to designate a second RLD, the request is made through a citizen
petition submitted to FDA’s Division of Dockets Management in accordance with §§ 10.20 and
10.30. An applicant may submit the application only after the citizen petition has been granted.
If an applicant refers to a listed drug that has been voluntarily withdrawn from sale in the United
States, the applicant must submit a citizen petition under § 10.25(a) (21 CFR 10.25(a)) and
§ 10.30 to FDA’s Division of Dockets Management requesting FDA to determine whether the
listed drug was withdrawn for reasons of safety or effectiveness (§ 314.122) (often referred to as
a relisting petition). A relisting petition may be submitted concurrently with the ANDA.
However, approval of the ANDA will be dependent on FDA’s response to the petition.
1.12.12 Contains information demonstrating that the generic product is the same as the RLD
(section 505(j)(2)(A) of the FD&C Act and § 314.94). Same means that the generic product has
the same active ingredient(s), dosage form, strength, route of administration, and conditions of
use as the RLD (§ 314.92(a)(1)). To demonstrate the comparison to the RLD, applicants
provide:
(1) a statement that the conditions of use for the generic product have been previously
approved for the RLD (§ 314.94(a)(4));
(2) information to show that the active ingredient(s) is the same as the RLD (§ 314.94(a)(5));
(3) information to show that the route of administration, dosage form and strength are the
same as those of the RLD (§ 314.94(a) (6)); and
(4) as applicable, information to indicate the strength of the generic drug product used in the
in vivo bioequivalence studies (fasting and fed) to demonstrate bioequivalence of the
generic drug product to the RLD.
Applicants must also identify and characterize the inactive ingredients and demonstrate that the
inactive ingredients do not affect the safety or efficacy of the proposed drug product
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(§ 314.94(a)(9)(ii)). This means that any differences in the identity or amount of an inactive
ingredient between the proposed product and the RLD product must be identified and
demonstrated as having no effect on safety or efficacy. Given that the nature of the data and
information necessary to demonstrate safety and efficacy can vary by product, applicants should
submit a controlled correspondence to [email protected], consult the FDA
Bioequivalence Recommendations for Specific Products Web site for current product-specific
data recommendations and the Biopharmaceutics guidances Web site, or contact the appropriate
CBER review division prior to submission of the application.
FDA recommends that an applicant submit within the original application all strengths that the
applicant intends to market. However, note that applicants are not able to submit a new
pharmacy bulk strength in an amendment (see Ref. 6 for more exceptions).
1.12.14 Contains the environmental assessment (EA) (21 CFR 25.20), environmental impact
statement (EIS) (21 CFR 25.22), or claim of categorical exclusion under 21 CFR 25.30 or 21
CFR 25.31 and the justification for the exclusion. Failure to provide the EA or statement for
categorical exclusion is sufficient grounds to refuse to receive the application (§ 314.101(d)(4))
(Ref. 8).
1.12.15 Contains a request to waive the requirement to submit evidence measuring in vivo
bioavailability (BA) or demonstrating in vivo bioequivalence (BE) of the generic product
(known as a biowaiver), if applicable (21 CFR 320.22). The data necessary to support a waiver
request vary by product. For this reason, applicants should submit a controlled correspondence
to [email protected], consult the FDA Bioequivalence Recommendations for Specific
Products Web site for current product-specific data recommendations and the Biopharmaceutics
guidances Web site, or contact the appropriate CBER review division prior to submission of the
application.
5. Labeling
1.14.1 Contains labeling for the generic product submitted in text-based Portable Document
Format (PDF), 16 Microsoft Word, and Structured Product Labeling (SPL) formats
(§ 314.94(a)(8)(ii) and Ref. 9). If the application is for a pharmacy bulk package product,
applicants should complete and submit the Pharmacy Bulk Package Sterility Assurance Table to
address sterility assurance of the drug product associated with the labeling and microbiological
study data that may be submitted in the application. 17
1.14.1.1 Contains the draft label and labeling for each strength and container including
package size. Applicants should ensure that label and labeling design do not contribute to
medication error (Ref. 9). Confirm if the container closure is child resistant (CRC).
16
For all PDF submissions, FDA requests that applicants submit text-based PDF files, not image-based PDF files
See the ANDA Forms and Submission Requirements page on the FDA Web site available at
http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ApprovalApplicati
ons/AbbreviatedNewDrugApplicationANDAGenerics/ucm120955.htm.
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1.14.1.2 Contains side-by-side labeling comparison of container(s) and carton(s) with the
RLD for each strength and package size. All differences should be highlighted and
annotated. Applicants should indicate the RLD version used for the side-by-side
comparison.
1.14.1.3 Contains the prescribing and patient information in text-based PDF, Microsoft
WORD and SPL formats. Applicants should identify the RLD version used for the side by
side comparison.
1.14.1.4 Contains Pharmacy Bulk Package Sterility Assurance Table, if applicable.
1.14.1.5 Contains labeling history.
Applicants are encouraged to review and use the Labeling Question-Based Review (QbR) model
when developing labels and labeling. 18 Responses to the QbR should be provided in section
1.14.1.5, as applicable.
1.14.3 Contains the RLD labeling and a comparison of that labeling to the draft labeling for the
generic product. Applicants must submit side-by-side labeling comparison(s) with all
differences highlighted and annotated (§ 314.94(a)(8)(iv)). Applicants should also submit the
RLD package insert, Medication Guide, one container label, and one outer carton, if applicable,
for each strength and package size listed in the application (§ 314.94(a)(8)(i)). Applicants are
reminded to use the most recent RLD labeling available at the [email protected] Web site.
1.14.3.1 Contains side-by-side labeling (professional insert, patient insert and Medication
Guide) comparison. All differences are highlighted and annotated. In addition, applicants
should state that a sufficient number of patient inserts will be included in each package
size. Applicants should confirm that Medication Guides will be distributed in accordance
with 21 CFR 208.24.
1.14.3.3 Contains the RLD professional and patient inserts, Medication Guide, one (1)
RLD container label, and one (1) RLD outer carton label for each strength and package
size, if applicable.
1.16.1 Contains the risk management plan (section 505-1 of the FD&C Act (21 U.S.C. 355-1))
for products that require tools to minimize risks while preserving benefits.
1.16.2 Contains the risk evaluation and mitigation strategy (REMS) and all supporting
documents, if the RLD has a REMS (Ref. 10). A REMS for an ANDA must have the same
Medication Guide and patient package insert as does the RLD (section 505-1(i)(1)(A) of the
FD&C Act). In addition, if applicable, a REMS for an ANDA must use a single, shared system
of elements to assure safe use, unless FDA waives the requirement under 505-1(i)(1)(B).
However, an ANDA REMS does not include a timetable for submission of assessments of the
REMS and does not include a communication plan (Ref. 10).
18
Id.
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B. Module 2 – CTD Summaries
1. Quality Overall Summary
2.3 Contains the Quality Overall Summary (QOS), which provides an overview of the chemistry,
manufacturing, and controls (CMC) section of the application (§ 314.50(c)(2)(iv)). The QOS
summarizes what is known about the drug substance (the active pharmaceutical ingredient (API))
in section 2.3.S and the drug product in section 2.3.P. Applicants should provide separate
information on each drug substance contained in the product in section 2.3.S. All information
provided in the summary needs to be accurate and supported by information, data, or justification
included in Module 3 or other parts of the application (Ref. 11).
Applicants should use the Question-Based Review (QbR) model when writing their summaries.
FDA introduced the QbR initiative in 2005 as a tool for the review of the CMC — Drug
Substance and Drug Product Quality — sections of the ANDA 19 and updated the QbR model to
include additional CMC questions from microbiology in 2011. The QbR model assists
applicants in developing their QOS by providing specific questions that, when answered, ensure
adequate information is submitted for FDA review. FDA has posted the QbR-QOS outlines
designed for simple dosage form products (solution or immediate-release solid oral dosage
forms) 20 and for sterility assurance of products terminally sterilized by moist heat. 21, 22 FDA has
also developed example QOS summaries for controlled-release capsules 23 and immediate-release
tablets. 24 Additionally, FDA recommends that applicants refer to the QbR Frequently Asked
Questions and the QbR for Sterility Assurance of Terminally Sterilized Products: Frequently
Asked Questions for further guidance on completing the QOS, including page limits. 25
FDA recommends that the QOS be submitted in MS Word and text-based PDF file. If the
applicant provides a scanned PDF copy of the QOS, FDA requests that the applicant also submit
the QOS in Microsoft Word.
2. Clinical Summary
2.7 Contains the submission of summary data critical to the determination of bioequivalence (21
CFR 320.21(b) and 21 CFR 320.24(b)). FDA has developed model summary tables to assist
applicants in summarizing these data. 26, 27 The tables provide a format for applicants to
19
Id.
Id.
21
Id.
22
Portions of the QbR for terminally sterilized products may also directly apply to sterile drug products that are
aseptically filled. Specifically, the P.1, P.2, P.5, P.8, Appendices A.2, and Regional Information components of
Module 2.3.P would also apply to sterile products that are aseptically filled.
23
Supra note 17.
24
Id.
25
Id.
26
See id. for the Model Bioequivalence Summary Data Tables.
27
FDA has also developed summary tables for clinical endpoint bioequivalence studies. Id.
20
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summarize various aspects of the BE submission such as the design and outcome of in vivo and
in vitro BE studies as well as the results of in vitro dissolution testing. These model tables are
available on the FDA ANDA Forms and Submission Requirements Web site. 28 In addition,
applicants should submit summary tables for all studies conducted, whether they are passing or
failed studies (Ref. 12).
2.7 Contains the completed tables in Microsoft Word and text-based PDF file.
2.7.1.1 Contains summary reports and/or data for in vivo BE studies with clinical endpoints or
skin irritation/sensitization/adhesion studies. 29
C. Module 3 – Quality
Module 3 contains all of the CMC information necessary to support the application
(§ 314.94(a)(9)(i)), including the information supporting and verifying what was summarized in
Module 2.3. The specific placement of product quality microbiology information in Module 3 is
listed in CDER’s Manual of Policies and Procedures (MAPP) 5040.1 Product Quality
Microbiology Information in the Common Technical Document 30 (see also Ref. 13 and Ref. 14).
Any analytical procedure submitted in the summaries of Module 2 should be described in
sufficient detail to allow an analyst to reproduce the conditions and obtain results comparable to
what is stated in the application (Ref. 15). FDA recommends that applicants submit a table of
contents for Module 3.
It is recommended that applicants review the following guidances for industry to assist in the
preparation of Module 3: ANDAs: Impurities in Drug Products (Ref. 16), ANDAs: Impurities in
Drug Substances (Ref. 17), and ANDAs: Stability Testing of Drug Substances and Products (Ref.
18). 31
1. Drug Substance
Section 3.2.S contains the CMC information specific to the drug substance(s) (§ 314.50(d)(1)(i)).
For a drug product containing more than one drug substance, the information requested for part
“S” should be provided in its entirety for each drug substance. To assist in preparing data for the
drug substance section, applicants should review the guidance for industry Guideline for
28
Applicants should periodically refer to the Web site as the Agency may update existing tables or expand the
number of tables to address additional study types as well as waiver requests.
29
See the FDA Data Standards Resources Web Site for current FDA data standards catalog available at
http://www.fda.gov/forindustry/datastandards/studydatastandards/default.htm.
30
See the CDER Manual of Policies and Procedures page of the FDA Web site available at
http://www.fda.gov/aboutfda/centersoffices/officeofmedicalproductsandtobacco/cder/manualofpoliciesprocedures/d
efault.htm.
31
FDA further recommends that applicants review the following guidances for industry, as applicable: Genotoxic
and Carcinogenic Impurities in Drug Substances and Products: Recommended Approaches (Ref. 19); Tablet
Scoring: Nomenclature, Labeling, and Data for Evaluation (Ref. 20); Size of Beads in Drug Products Labeled for
Sprinkle (Ref. 21); Size, Shape, and Other Physical Attributes of Generic Tablets and Capsules (Ref. 22); ANDAs:
Stability Testing of Drug Substances and Products Questions and Answers (Ref. 23) and ANDA Submissions —
Refuse-to-Receive Standards (Ref. 1).
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Submitting Supporting Documentation in Drug Applications for the Manufacture of Drug
Substances (Ref. 24).
3.2.S.1 Contains general information about the drug substance including: (1) the nomenclature,
(2) the structure, and (3) general properties. Section 3.2.S.1 should not include any references to
the DMF.
3.2.S.2 Contains information related to each drug substance manufacturer including:
(1) the name and full address of the facility(ies);
(2) contact information for an agent at the facility (phone, fax numbers and email address);
(3) function or responsibility;
(4) the Type II DMF number for the API; and
(5) the Central File Number (CFN), Facility Establishment Identifier (FEI) or Data Universal
Numbering System (DUNS) numbers, if known.
The applicant should also provide current good manufacturing practice (cGMP) and/or
Debarment Certification of the facility that matches the information provided in FDA Form
356h. Subsections 3.2.S.2.2 through 3.2.S.2.6 may refer to the DMF. If there is no DMF
referenced in the application, detailed information should be provided in these subsections (Ref.
24). For a sterile substance for use in a sterile drug product, section 3.2.S.2.2 will include the
sterilization process and any in-process controls and section 3.2.S.2.5 will contain the validation
of sterilization processes for the drug substance.
3.2.S.3 Contains characterization information for the API. FDA recommends that applicants
complete the Summary Tables for the Listing and Characterization of Impurities and Justification
of Limits in Drug Substance. 32
3.2.S.4 Contains all information about the control of the drug substance.
3.2.S.4.1 Contains the drug substance specifications. These specifications include the
tests, acceptance criteria, and references to methods in tabular form. If the application
contains a sterile substance for use in a sterile drug product, this section will also contain
the microbiological specification for the drug substance.
3.2.S.4.2 Contains the description of analytical procedures (compendial and/or in-house).
If the application contains a sterile substance for use in a sterile drug product, this section
will also contain the microbiological analytical procedures used to test the drug
substance.
3.2.S.4.3 Contains the validation of analytical procedures including:
(1) full validation reports for in-house methods and their equivalence to United States
Pharmacopeia (USP) procedures if available for the drug substance;
(2) verification of USP <1226> or DMF procedures, when referenced;
32
Supra note 17.
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(3) legible spectra and chromatograms for reference standards and test samples; and
(4) Sample Statement(s) of Availability and identification of the drug substance,
along with associated lot numbers (Ref. 15). 33
If the application contains sterile substance for use in a sterile drug product, this section
will also contain the validation of the microbiological analytical procedures used to test
the drug substance.
3.2.S.4.4 Contains the batch analysis including the Certificates of Analysis (COAs) from
both the drug substance manufacturer (s) and drug product manufacturer for the batches
used to produce the exhibit batch(es) of the drug product.
3.2.S.4.5 Contains the justification of the specifications including, but not limited to,
references to compendia (e.g., USP, European Pharmacopeia (EP), and the Japanese
Pharmacopeia (JP)), ICH, and/or RLD analysis. FDA recommends that applicants
complete the Summary Tables for the Listing and Characterization of Impurities and
Justification of Limits in Drug Substance. 34
3.2.S.5 Contains information about the reference standards or materials. Appropriate
certification, characterization, and qualification information should be provided for the reference
standards of the drug substance and impurities. Reference to the DMF alone is inadequate.
3.2.S.6 Contains information about the container closure systems (Ref. 25). If the application
contains a sterile substance for use in a sterile drug product, this section will also contain a
description of the container closure system used for the drug substance and the validation of the
container closure integrity.
3.2.S.7 Contains stability data including the retest date or expiration date of the API.
Information provided should include the retest date or expiration date of the API at both the drug
product manufacturing site and the drug substance manufacturing site (Refs. 18 and 23).
2. Drug Product
Section 3.2.P contains detailed information known about the drug product (§ 314.50(d)(1)(ii)).
During the development of the application, applicants should review the guidances for industry
Q8(R2) Pharmaceutical Development (Ref. 26) and Submission Documentation for Sterilization
Process Validation in Applications for Human and Veterinary Drug Products (Ref. 13) and the
product-specific CMC guidances for industry (e.g., metered dose inhalers, nasal spray) as
applicable. A drug product supplied with a reconstitution diluent should include a separate
Module 3.2.P with the diluent information.
33
34
Method validation/verification reports for all analytical methods are to be provided in section 3.2.S.4.3.
Supra note 17.
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3.2.P.1 Contains the description and composition of the drug product. For each strength, 35
provide:
(1) the quantitative composition and function of each component in the drug product; include
solvents and processing aids that are used during manufacture, as applicable;
(2) information related to the physical description of the product (tablet size, scoring) and
comparison to the RLD (Refs. 20 and 22);
(3) the quality standards (e.g., USP, National Formulary (NF)) of components; composition
of colors, flavors, 36 and imprinting ink, if applicable;
(4) amounts of inactive ingredients that are appropriate per the Inactive Ingredient
Database 37 (per dose or unit dose) and justification (FDA recommends that applicants
provide the justification in a tabular format);
(5) conversion from percentage to milligram (mg)/dose values for all components, as
applicable;
(6) identification and justification of any formulation overages or overfills that appear in the
final product;
(7) daily elemental iron calculation or statement of adherence to 21 CFR 73.1200; 38
(8) if the RLD is packaged with a specific diluent, demonstration that the diluent is
qualitatively and quantitatively the same (Q/Q same) as that packaged with the RLD;
(9) a calculation of the amount of phenylalanine (mg per dosage unit) for products that
contain aspartame (21 CFR 201.21);
(10) for OTC products that contain potassium calcium, magnesium, and/or sodium: the
calculation for potassium, calcium, magnesium and/or sodium content of a single
maximum recommended dose;
(11) a calculation of absolute alcohol in terms of percent volume (v/v) for products that
contain alcohol (21 CFR 201.10(d)(2)); and
(12) for antibiotics that contain sodium: the calculation for sodium content (per
tablet/capsule, per unit dose).
For sterile products, this section will contain a description of the primary container closure
system information for each configuration.
For drug products containing inactive ingredient changes permitted in accordance with
§ 314.94(a)(9)(iii)-(v), applicants must also identify and characterize the differences and provide
information that demonstrates the change(s) does/do not affect the safety or efficacy of the drug
product. This means that any differences in the identity or amount of an inactive ingredient
between the proposed product and the RLD product must be identified and demonstrated as
35
One 3.2.P section should encompass all strengths. ICH guidance documents indicate that the information for all
strengths should be combined and presented together in one Drug Product section. If the quality information is the
same between all strengths, the data should only appear once.
36
Flavor manufacturers can provide the composition information directly to the reviewer if the information is not
available to ANDA applicants due to proprietary reasons.
37
The Inactive Ingredient database is available at http://www.fda.gov/Drugs/InformationOnDrugs/ucm080123.htm.
38
FDA recommends that applicants provide a calculation of elemental iron intake based on the maximum daily dose
of the drug product.
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having no effect on safety or efficacy. Given that the nature of the data and information
necessary to demonstrate safety and efficacy can vary by product, applicants should submit a
controlled correspondence to [email protected] or consult the FDA Bioequivalence
Recommendations for Specific Products Web site for current product-specific data
recommendations prior to submission of the application.
3.2.P.2 Contains information on the pharmaceutical development of the drug product including
the pharmaceutical development report and the microbial attributes — the container closure
integrity testing report for sterile product, antimicrobial effectiveness testing for multi-dose
sterile products, and if the sterile drug product is packaged, as single-use/dose/multi-dose and/or
pharmacy bulk. If the applicant has moved toward a Quality by Design (QbD) approach, 39
applicants may demonstrate their methods in section 3.2.P.2. Applicants are encouraged to
review FDA’s information on Quality by Design for ANDAs: An Example for Modified Release
Dosage Forms and An Example for Immediate-Release Dosage Forms. 40 For sterile products
that are reconstituted (or further diluted) and stored prior to administration, the applicant should
provide microbiological studies to support the worst case postconstitution or postdilution storage
times, diluents, and conditions stated in the product package insert labeling. The study should be
a risk assessment that shows adventitious microbial contamination does not grow (generally
accepted as not more than (NMT) 0.5log10 growth) under the specified storage conditions. 41
3.2.P.3 Contains information about the manufacture of the drug product including:
(1) the name and full address of the facility(ies);
(2) contact information for an agent at the facility (phone and fax numbers, email address);
(3) function or responsibility; 42
(4) cGMP certification for both the applicant and the drug product manufacturer if different
entities; and
(5) the CFN, FEI, or DUNS numbers, if known.
The information provided in this section should match the information provided in Form FDA
356h for the finished dosage manufacturer and all outside contract testing laboratories.
3.2.P.3.2 Contains the batch formula for the drug product including: (1) amounts of
components including processing aids, if any, that come into contact with the drug
substance or product during any stage of manufacture (quantitative comparison between
the pilot scale and commercial scale in a tabular form recommended) and (2) indication
and justification of any overage(s) or weight adjustment(s) used.
3.2.P.3.3 Contains a description of the manufacturing process and controls including:
39
Pharmaceutical Quality by Design (QbD) is defined as systematic approach to development that beings with
predefined objectives and emphasizes product and process understanding and process control, based on sounds
science and quality risk management (Ref. 26).
40
Supra note 17.
41
See MAPP 5016.1 Applying ICH Q8(R2), Q9, and Q10 Principles to CMC Review, Supra note 33.
42
Applicants are encouraged to provide the complete testing description if the facility performs testing on either the
drug substance, the drug product, or both.
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(1) a description of the manufacturing process and facility;
(2) manufacturing process flow chart showing controls;
(3) master production batch record(s) for the largest intended production runs (i.e.,
commercial batch records);
(4) master packaging records for intended marketing container(s);
(5) indication whether the drug product is a sterile product; and
(6) reprocessing statement pursuant to 21 CFR 211.115 submitted by the applicant, at
a minimum.
3.2.P.3.3.1 For sterile products, this section contains: (1) a description of the
manufacturing process for the drug product, including sterilization processes and any inprocess controls, and (2) the sterilization information including the sterilization and
depyrogenation of packaging components and equipment.
For products sterilized by terminal moist heat, this section will include a description of
the:
(1) autoclave process and performance specifications; autoclave loading patterns;
(2) methods and controls to monitor production cycles;
(3) requalification of production autoclaves;
(4) reprocessing; and
(5) environmental monitoring, including a bulk drug solution bioburden action level
prior to sterilization.
For products sterilized by aseptic processing, this section will include a description of
the:
(1) building and facilities;
(2) overall manufacturing operation;
(3) sterilization and depyrogenation of containers, closures, equipment, and
components; and
(4) environmental monitoring, including a bulk drug solution bioburden action level
prior to sterilization. (Ref. 14 and MAPP 5040.1)
3.2.P.3.4 Contains the controls of critical steps and intermediates including: (1)
acceptance criteria and test results for the exhibit batch(es); (2) comparison of controls
and equipment between the pilot and commercial-batch manufacture; and (3) information
about holding periods.
3.2.P.3.5 Contains process validation information to demonstrate that the manufacturing
process produces a dosage form that meets product specifications including evaluation of
data generated for the critical material attributes and critical process parameters that were
found to meet the established scale-up guideline and/or acceptance criteria (Ref. 27).
For a terminally sterilized product, this information includes: (1) validation of the
production terminal sterilization process; (2) validation of depyrogenation of all product
container and closures; and (3) holding periods.
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For an aseptically filled product, this information includes:
(1) validation (bacterial retention studies) of sterilizing grade filters;
(2) validation of the sterilization of sterile bulk drug or product contact equipment;
(3) validation of sterilization and depyrogenation of product containers and closures;
(4) validation of aseptic filling process/line/room (media fills/process simulations);
(5) holding periods; and
(6) actions taken after a media fill failure. (Ref. 14 and MAPP 5040.1)
3.2.P.4 Contains information on the controls of excipients including the identity of the source of
inactive ingredients and the grades (e.g., compendial or noncompendial).
3.2.P.4.1 Contains the testing specifications including retest schedule and the excipient
manufacturer’s or supplier’s COA.
3.2.P.4.2 Contains the analytical procedures for the testing.
3.2.P.4.3 Contains the validation data of the analytical procedures.
3.2.P.4.4 Contains the justification of the specifications and includes: (1) the applicant’s
or drug product manufacturer’s COA(s); (2) residual solvents statement(s) from
manufacturer(s); and (3) bovine spongiform encephalopathy (BSE), transmissible
spongiform encephalopathy (TSE), and melamine certifications, as applicable (Ref. 28).
3.2.P.5 Contains information supporting the controls of the drug product.
3.2.P.5.1 Contains the specifications for the drug product. These specifications include
the tests, acceptance criteria, and references to methods in a tabular form. For sterile
products, this section will contain the release specifications for the drug product (sterility,
bacterial endotoxins, etc.). In cases where a USP monograph reports an endotoxins
specification for a parenteral or intrathecal drug product, the applicant should
alternatively propose a bacterial endotoxins specification based on the maximum patient
dosage prescribed in the package insert labeling, not the USP monograph. The
acceptance criteria for the maximum endotoxins dose to a patient are established in USP
<85>.
3.2.P.5.2 Contains the description of analytical procedures (compendial and/or in-house).
For sterile products, this section will contain methods for product release tests (sterility,
bacterial endotoxins (if applicable), etc.)
3.2.P.5.3 Contains the validation of the analytical procedure including:
(1) full validation reports for in-house methods and their equivalence to USP
procedures if available for the drug product;
(2) verification of USP <1226> procedures, when referenced;
(3) legible spectra and chromatograms for reference standards and test samples; and
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(4) the Sample Statement(s) of Availability and Identification of (a) the finished
dosage form and (b) the lot numbers and strength of the drug products. 43
For sterile products, this section will contain a summary of validation procedures and
results for analytical procedures (sterility, bacterial endotoxins (if applicable), etc.).
3.2.P.5.4 Contains the batch analysis including the executed COAs for all presentations
and/or strengths of the finished dosage form.
3.2.P.5.5 Contains the characterization of impurities. FDA recommends controlling all
potential degradation products (Ref. 16) and processing solvents if used during
manufacture in the finished dosage form. FDA recommends that applicants complete the
Summary Tables for the Listing and Characterization of Impurities and Justification of
Limits in Drug Substance and Drug Products. 44
3.2.P.5.6 Contains the justification of the specifications including but not limited to
references to compendia (e.g., USP, JP), ICH, and/or RLD analysis. FDA recommends
that applicants complete the Summary Tables for the Listing and Characterization of
Impurities and Justification of Limits in Drug Products. 45
3.2.P.6 Contains information about the reference standards or materials.
3.2.P.7 Contains information on the container closure system including:
(1) a summary of the container closure system (including data for any new resin used and
technical diagrams/drawings of the container closure components, a statement whether
the closure for each proposed packaging configuration is child resistant or non-child
resistant and a description of markings on the cap/ferrule overseals (USP General
Chapters <1> Injections));
(2) components specification and test data;
(3) packaging configuration and size;
(4) container closure testing pursuant to USP <661> and <671> (testing should be
conducted; for liquid drug products contained in plastic containers, applicants should
also provide test data for leachables and/or extractables); and
(5) the source of supply and the supplier’s address (Ref. 25).
For controlled substances, provide a description of the tamper-evident properties of the container
closure system as described in 21 CFR 1302.06. For OTC products, the applicant should
confirm if the container closure system meets the requirements of 21 CFR 211.132.
43
Method validation/verification reports for all analytical methods are to be provided in section 3.2.P.5.3
Supra note 17.
45
Id.
44
18
Contains Nonbinding Recommendations
Draft — Not for Implementation
708
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714
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748
3.2.P.8 Contains the stability data (Refs. 18 and 23). 46
3.2.P.8.1 Contains the stability and conclusions for the finished dosage form including:
(1) preapproval stability protocol;
(2) proposed expiration dating period for marketing packaging;
(3) proposed expiration dating period for bulk packaging, if applicable; and
(4) storage temperature statement.
3.2.P.8.2 Contains the postapproval stability protocol and stability commitment. If the
applicant and drug product manufacturer are different entities, both will provide stability
commitments. For sterile products, this section contains analytical procedures and testing
schedule for maintenance of microbial product quality (e.g., container closure
integrity/sterility, bacterial endotoxins, and microbial limits) (Ref. 29).
3.2.P.8.3 Contains stability data including:
(1) accelerated, long-term, and intermediate stability data, if applicable;
(2) batch numbers on stability records that are the same as the test batch;
(3) the date the stability studies were initiated; and
(4) the date the stability sample(s) were removed from the stability chamber for each
testing time point (Ref. 18).
For liquid or semisolid products, applicants should submit accelerated stability data
reflecting the worst-case storage conditions (related to orientation), at minimum. The
following information and data can also be included in this section:
(1) one-time special stability studies conducted to confirm quality of constituted drug
products (for example parenterals and/or powders reconstituted with diluents
and/or drug admixtures) per labeling instructions;
(2) one-time thermal cycling studies (freeze-thaw/heat-cool), as applicable; and
(3) one-time in-use stability studies for oral liquids as applicable (e.g., a solution to
be used within a certain period of opening the container per labeling instructions,
compatibility with a dropper when provided as part of the container closure
system).
3. Appendices
3.2.A.2 Contains an appendix for Adventitious Agents Safety Evaluation for sterile products.
This section will contain a description of the processes used to control for potential
contamination with adventitious agents (e.g., TSEs, viruses). These processes may include
assays to detect adventitious agents, actions taken to avoid them, as well as procedures to
eliminate or inactivate them.
46
FDA recommends three pilot-scale batches or two pilot-scale batches plus one small-scale batch with both
accelerated and long-term data provided for each batch covering a period of no less than 6 months.
19
Contains Nonbinding Recommendations
Draft — Not for Implementation
749
750
751
752
753
754
755
756
757
758
759
760
761
762
763
764
765
766
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769
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778
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781
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783
784
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786
787
788
789
790
791
792
793
4. Regional Information
Section 3.2.R contains regional information for the drug substance and the drug product
(§ 314.50(d)(1)(ii)(b)).
3.2.R.1.S Contains the executed batch records and blank master batch records. Applicants can
refer to the DMF(s) for this information. If no DMF is referenced in the application, applicants
should provide the executed and blank master batch records.
3.2.R.2.S Contains the comparability protocols (Ref. 30).
3.2.R.3.S Contains the methods validation package. This information may also be placed in
section 3.2.S.4.3.
3.2.R.1.P.1 Contains the executed batch records including: (1) a copy of the executed batch
record(s) with equipment specified and packaging records (the packaging and labeling
procedures); (2) the batch reconciliation and label reconciliation for the theoretical yield, the
actual yield, and the packaged yield; and (3) the bulk package reconciliation for all bulk
packaging considered a commercial container. The bulk package reconciliation is recommended
if bulk packaging is used to achieve the minimum package requirement. As part of the bulk
package reconciliation recommendation, the applicant should submit bulk package stability data
in section 3.2.P.8.3. If bulk is to be shipped, the applicant should submit accelerated stability
data at 0, 3, and 6 months; if the bulk is only warehoused for repackaging, the applicant may
provide real time stability data at 0, 3, and 6 months. Provide bulk package container and
closure information in section 3.2.P.7.
3.2.R.1.P.2 Contains information on components including and not limited to applicants’
and suppliers’ COAs for drug substance lots, inactive ingredients lots, and packaging
components lots contained in the exhibit batches of the drug product
3.2.R.2.P Contains comparability protocols, if applicable (Ref. 30).
3.2.R.3.P Contains the methods validation package. This information may also be placed in
section 3.2.P.5.3.
5. Literature References
3.3 Contains copies of any documents referred to in the application. The documents may include
published articles, official meeting minutes, or other regulatory guidance or advice provided to
the applicant. FDA recommends that the documents be provided in text-based PDF.
D. Module 4 – Nonclinical Study Reports
ANDAs generally do not contain data that are required for Module 4.
20
Contains Nonbinding Recommendations
Draft — Not for Implementation
794
795
796
797
798
799
800
801
802
803
804
805
806
807
808
809
810
811
812
813
814
815
816
817
818
819
820
821
822
823
824
825
826
827
828
829
830
831
E. Module 5 – Clinical Study Reports
Module 5 contains all of the clinical study report data needed to support the application and
demonstrate that the generic is bioequivalent to the RLD (§ 314.94(a)(7)). To facilitate the
submission of complete data, FDA develops product-specific guidances, 47 summary data tables
(as referenced in section III.B.2 of this guidance), 48 and multiple guidances on
biopharmaceutics. 49 Applicants should use an eCTD Study Tagging File for each study
submitted. 50
1. Complete Study Data
5.2 Contains the tabular listing of the clinical studies submitted in the module.
5.3 Contains the clinical study reports and related information.
5.3.1 Contains the complete study data for the biopharmaceutic studies (Ref. 31) and the lot
numbers and strength of products used in the BE study(ies); and documents the study type. The
section will also contain information of in vivo and in vitro studies including, but not limited
to: 51
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Synopsis
Study report
Protocol and amendments
All case report forms
List of independent ethics committees (IECs) or institutional review boards (IRBs) and
consent and/or assent forms
IRB approval letters for protocol, amendments, and consent/assent forms
List and description of investigators and sites
Number of subjects enrolled in each site
Signatures of principal or coordinating investigator(s) or sponsor’s responsible medical
officer
Listing of subjects receiving test drug(s) from specified batch
Randomizations scheme
Audit certificates and reports
Documentation of statistical methods and interim analysis plans
Documentation of interlaboratory standardization methods of quality assurance
procedures if used 52
Publications based on the study53
47
See the Bioequivalence Recommendations for Specific Products guidances on the FDA Drugs guidance Web
page.
48
Supra note 17.
49
See the Biopharmaceutics guidances on the CDER Guidances Web page.
50
See ICH M2 EWG: The eCTD Backbone File Specification for Study Tagging Files (June 2008).
51
See the FDA Data Standards Resources Web Site for current FDA data standards catalog. Supra note 29.
52
Supra note 17.
21
Contains Nonbinding Recommendations
Draft — Not for Implementation
832
833
834
835
836
837
838
839
840
841
842
843
844
845
846
847
848
849
850
851
852
853
854
855
856
857
858
859
860
861
862
863
864
865
866
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Important publications referenced in the report 54
Discontinued patients including specific reason for discontinuation 55
List of subjects included in the PP (per protocol), (M)ITT (modified/intent-to treat), and
safety populations 56
List of subjects excluded from the PP, (M)ITT, and safety populations 57
Reason for exclusion from the PP, (M)ITT, and safety populations for each subject 58
Protocol deviations including specific reason for deviation
Demographic data
Drug concentration data
Treatment compliance rate data
Individual subject’s response scores/data per visit
Adverse event listings
Concomitant medication listings
Listing of individual laboratory measurements by subject
Site (identifier)
Individual subject data listings
In vivo and/or in vitro BE study datasets
Summary dataset containing a separate line listing for each subject 59
Analysis dataset containing a separate line listing for each visit per subject 60
Individual Analysis datasets (e.g., adverse events, concomitant medications etc.) 61
Analysis programs
Annotated case report form (CRF)
Annotated ECG waveform datasets
Image files
Narrative safety reports for serious adverse events
Source documents
Clinical raw data/medical records
5.3.1.2 Contains the comparative BA and BE study reports (e.g., fasting studies, fed studies).
5.3.1.3 Contains in vitro-in vivo correlation study reports (e.g., comparative dissolution data).
5.3.1.4 Contains reports of bioanalytical and analytical methods provided in individual study
reports. If a method is used in multiple studies, the method and its validation should be included
once in section 5.3.1.4 and then referenced in individual study reports.
53
Id.
Id.
55
Id.
56
Id.
57
Id.
58
Id.
59
Id.
60
Id.
61
Id.
54
22
Contains Nonbinding Recommendations
Draft — Not for Implementation
867
868
869
870
871
872
873
874
875
876
877
878
879
The data provided in all of these sections support the summary tables submitted in section 2.7.
All comparative dissolution data from the in vitro-in vivo correlation study reports should be
placed in section 5.3.1.3, while the dissolution summary tables should be placed in section 2.7.
2. Literature References
5.4 Contains copies of any documents referred to in the application. The documents may include
published articles, official meeting minutes, or other regulatory guidance or advice provided to
the applicant. One copy of all important references cited in the QOS or individual technical
reports provided in section 5.3 will also be submitted in this section (Ref. 31). FDA
recommends that the documents be provided in text-based PDF.
23
Contains Nonbinding Recommendations
Draft — Not for Implementation
880
881
882
883
884
885
886
887
888
889
890
891
892
893
894
895
896
897
898
899
900
901
902
903
904
905
906
907
908
909
910
911
912
913
914
915
916
917
918
919
920
921
922
923
924
APPENDIX A: REFERENCED GUIDANCES
The following documents have been referenced in this guidance document and may be relevant
to applicants developing or considering development of an ANDA. This is not a comprehensive
list of available information from CDER. All guidances documents listed here are available on
the Drugs guidance Web page
(http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm).
1. Draft Guidance for Industry ANDA Submissions — Refuse-to-Receive Standards (Issued
by CDER, October 2013).
2. Draft Guidance for Industry Providing Regulatory Submissions in Electronic Format —
Certain Human Pharmaceutical Product Applications and Related Submissions Using
the eCTD Specifications (Issued jointly by CDER and CBER, January 2013 Rev. 3).
3. Guidance for Industry Part 11, Electronic Records; Electronic Signatures — Scope and
Application (Issued by CDER, CBER, CDRH, CFSAN, CVM, ORA, August 2003).
4. Draft Guidance for Industry Submitting Debarment Certification Statements (Issued by
CDER, CBER, and CVM, September 1998).
5. Guidance for Industry Contents of a Complete Submission for the Evaluation of
Proprietary Names (Issued jointly by CDER and CBER, February 2010).
6. Guidance for Industry Variations in Drug Products that May Be Included in a Single
ANDA (Issued by CDER, December 1998).
7. Draft Guidance for Industry How to Comply with the Pediatric Research Equity Act
(Issued jointly by CDER and CBER, September 2005).
8. Guidance for Industry Environmental Assessment of Human Drug and Biologics
Applications (Issued jointly by CDER and CBER, July 1998).
9. Draft Guidance for Industry Safety Considerations for Container Labels and Carton
Labeling Design to Minimize Medication Errors (Issued by CDER, April 2013).
10. Guidance for Industry Format and Content of Proposed Risk Evaluation and Mitigation
Strategies (REMS), REMS Assessments, and Proposed REMS Modifications (Issued by
CDER, September 2009)
11. Guidance for Industry ICH M4Q: The CTD — Quality (Issued by CDER, August 2001).
12. Guidance for Industry Submission of Summary Bioequivalence Data for ANDAs (Issued
by CDER, May 2011).
24
Contains Nonbinding Recommendations
Draft — Not for Implementation
925
926
927
928
929
930
931
932
933
934
935
936
937
938
939
940
941
942
943
944
945
946
947
948
949
950
951
952
953
954
955
956
957
958
959
960
961
962
963
964
965
966
967
968
969
970
13. Guidance for Industry Submission Documentation for Sterilization Process Validation in
Applications for Human and Veterinary Drug Products (Issued jointly by CDER and
CVM, November 1994).
14. Guidance for Industry Sterile Drug Products Produced by Aseptic Processing — Current
Good Manufacturing Practice (Issued jointly by CDER and CBER, September 2004).
15. Draft Guidance for Industry Analytical Procedures and Methods Validation for Drugs
and Biologics (Issued jointly by CDER and CBER, February 2014).
16. Guidance for Industry ANDAs: Impurities in Drug Products (Issued by CDER,
November 2010).
17. Guidance for Industry ANDAs: Impurities in Drug Substances (Issued by CDER, June
2009).
18. Guidance for Industry Abbreviated New Drug Applications: Stability Testing of Drug
Substances and Products (Issued by CDER, June 2013).
19. Draft Guidance for Industry Genotoxic and Carcinogenic Impurities in Drug Substances
and Products: Recommended Approaches (Issued by CDER, December 2008).
20. Guidance for Industry Tablet Scoring: Nomenclature, Labeling, and Data for Evaluation
(Issued by CDER, March 2013).
21. Guidance for Industry Size of Beads in Drug Products Labeled for Sprinkle (Issued by
CDER, May 2012 Rev. 1).
22. Draft Guidance for Industry Size, Shape, and Other Physical Attributes of Generic
Tablets and Capsules (Issued by CDER, December 2013).
23. Guidance for Industry ANDAs: Stability Testing of Drug Substances and Products
Questions and Answers (Issued by CDER, May 2014).
24. Guidance for Industry Guideline for Submitting Supporting Documentation in Drug
Applications for the Manufacture of Drug Substances (Issued by CDER, February 1987).
25. Guidance for Industry Container Closure Systems for Packaging Human Drugs and
Biologics (Issued jointly by CDER and CBER, May 1999).
26. Guidance for Industry ICH Q8(R2) Pharmaceutical Development (Issued jointly by
CDER and CBER, November 2009).
27. Guidance for Industry Process Validation: General Principles and Practices (Issued
jointly by CDER, CBER and CVM, January 2011 Rev. 1).
25
Contains Nonbinding Recommendations
Draft — Not for Implementation
971
972
973
974
975
976
977
978
979
980
981
982
983
984
985
986
987
988
989
990
991
992
993
994
995
996
997
998
999
1000
1001
1002
1003
1004
1005
1006
1007
1008
1009
1010
1011
1012
1013
28. Guidance for Industry Pharmaceutical Components at Risk for Melamine Contamination
(Issued jointly by CDER and CVM, August 2009).
29. Guidance for Industry Container and Closure System Integrity Testing in Lieu of Sterility
Testing as a Component of the Stability Protocol for Sterile Products (Issued by CBER,
CDER, CDRH, and CVM, February 2008).
30. Draft Guidance for Industry Comparability Protocols -- Chemistry, Manufacturing, and
Controls Information (Issued by CDER, CBER and CVM, February 2003).
31. Guidance for Industry ICH M4E: The CTD — Efficacy (Issued by CDER, August 2001).
See also:
Draft Guidance for Industry Providing Regulatory Submissions in Electronic Format —
Submissions Under Section 745A(a) of the Federal Food, Drug, and Cosmetic Act
(Issued by CDER and CBER, February 2014).
Draft Guidance for Industry Providing Regulatory Submissions in Electronic Format —
Standardized Study Data (Issued by CDER and CBER, February 2014 Rev. 1).
26
Contains Nonbinding Recommendations
Draft — Not for Implementation
1014
1015
1016
1017
1018
1019
1020
1021
1022
1023
1024
1025
1026
1027
1028
1029
1030
1031
1032
1033
1034
1035
1036
1037
1038
1039
1040
1041
1042
1043
1044
1045
1046
1047
1048
1049
1050
1051
1052
1053
1054
1055
1056
1057
1058
1059
APPENDIX B: COVER LETTER TEMPLATE
Date
Office of Generic Drugs (HFD-600)
Center for Drug Evaluation and Research
Food and Drug Administration
Metro Park North VII,
7620 Standish Place
Rockville, MD 20855
Heading:
Provide pre-assigned ANDA number, if applicable
Indicate that the submission is an Original Application
Indicate that expedited review is being requested by providing the statement,
“Expedited Review Request”
Reference:
Provide the name of generic product name and strengths
Dear Sir or Madam:
Paragraph 1: Provide the name of the applicant
Provide the name of the generic drug product and strengths
Provide the drug product packaging description as single-use or single dose, multi
dose and/or pharmacy bulk.
Paragraph 2: Provide the RLD NDA or ANDA number
Provide brand and generic drug product name and strengths
Provide the name of the RLD holder
Paragraph 3: Indicate whether the GDUFA fee has been paid and provide the amount paid
Provide User Fee Payment ID Number
Indicate that a copy of the Generic Drug User Fee Cover Sheet is contained in the
application at Module 1.2
Paragraph 4: Indicate whether Controlled Correspondence were used to develop this
application
Provide the Controlled Correspondence numbers and indicate that copies are
provided in Module 1.2
Indicate whether Meeting Minutes are contained in this application
Indicate that the Meeting Minutes are provided in Module 1.2
Indicate whether FDA reviewed any protocols or conducted telephone
conferences with the applicant during development of the application
27
Contains Nonbinding Recommendations
Draft — Not for Implementation
1060
1061
1062
1063
1064
1065
1066
1067
1068
1069
1070
Indicate whether a Suitability Petition was approved in relation to this application
Provide the docket number and a copy of FDA’s approval letter in Module
1.12.11
Indicate whether a Citizen Petition was filed and/or granted in relation to this
application
Provide the docket number, a copy of the petition, FDA’s response (if applicable)
in Module 1.12.11
Paragraph 5: Indicate that Letters of Authorization for DMFs enclosed in section 1.4.1
List all DMFs referenced in the application
Product name
1071
1072
1073
1074
DMF holder and
address
FEI/DUNS
Fee status
Indicate whether any approved ANDAs are referenced
List all ANDAs referenced in the application
Product name
1075
1076
1077
1078
1079
1080
1081
1082
1083
1084
1085
1086
1087
1088
1089
1090
1091
1092
1093
1094
1095
1096
1097
1098
1099
DMF number
ANDA number
ANDA holder
and address
FEI/DUNS
Fee status
Paragraph 6: Indicate whether any information or data in the application should be highlighted
for a specific discipline’s review
Indicate the method of sterilization for the drug product (e.g., aseptic processing
or terminal sterilization) if applicable
Indicate whether the application contains pharm/tox data for review in Module
3.2.P.1.
Paragraph 7: Identify the sites where the ANDA batches were manufactured (including FEI or
DUNS number)
Identify the sites where the marketed product will be manufactured for marketing
(including FEI or DUNS number)
Paragraph 8: Indicate the proposed drug product expiration date and the basis for the request in
Module 3.2.P.8.1
Paragraph 9: Provide the basis for the expedited review request (if applicable)
Paragraph 10: Indicate whether the ANDA was compiled and submitted pursuant to FDA’s
guidance on electronic submissions
Paragraph 11: Indicate whether a letter of Non-Repudiation Agreement for digital signatures has
been submitted to the FDA and provide the date of that submission
Paragraph 12: Indicate the file structure of the labeling
28
Contains Nonbinding Recommendations
Draft — Not for Implementation
1100
1101
1102
1103
1104
1105
1106
1107
1108
1109
1110
1111
1112
1113
1114
1115
1116
1117
1118
1119
Paragraph 13: Indicate whether the RLD has a REMS
Indicate whether information on the proposed REMS has been submitted in
Module 1.16
Paragraph 14: Provide information related to the physical description of the product (tablet size,
scoring) and comparison to the RLD in Module 3.2.P.1
Provide information about the tamper-resistant properties of a controlled
substance in Module 3.2.P.7 if applicable.
Paragraph 15: Provide a summary table of subsections applicable to the ANDA
Paragraph 16: Provide the name and contact information for a technical point of contact (for
electronic submissions)
Paragraph 17: Provide the signatory’s contact information
Signature
29