Contains Nonbinding Recommendations
A drug offered for import as
an MMA product without an approved supplement may be subject
to refusal of admission.
In the subsections below, FDA provides recommendations for submission of NDA supplements
and BLA supplements. Since there are some differences in the information accompanying the
submissions for each product type, and for ease in quickly identifying the applicable
recommendations for the different supplements, the sections are divided by type of application.
A. NDA Supplements
In an NDA supplement seeking to change the FDA-approved labeling for
an MMA product,
FDA recommends that the following information be submitted. The supplement should include
information to demonstrate that a product originally intended for sale in another country is the
FDA-approved product and is manufactured in accordance with the FDA-approved NDA, with
the exception of the limited labeling differences discussed in this guidance. The information
about the MMA product should also establish that the composition of the drug product, as well
as the entirety of the manufacturing process, from active pharmaceutical ingredient through
finished product, meets all of the specifications in the chemistry, manufacturing, and controls
section in the NDA for the FDA-approved drug product (21 CFR 314.50(d)(1)) and any
submission incorporated by reference (e.g., Type II drug master file). FDA expects to review the
addition of the labeling statement discussed in this guidance to ensure it does not distract from,
interrupt, or distort the required and recommended information in the labeling.
FDA recommends that the supplement include an attestation in the cover letter stating that the
MMA product has the active ingredient(s), active ingredient source (including manufacturing
facility(ies)), inactive ingredients, dosage form, strength(s), route(s) of administration, and
device constituent part(s) (as applicable) described in the NDA. The application also should
include information specifying the non-U.S. regulatory authority (Health Canada, the European
Medicines Agency, etc.) that has authorized the drug product for marketing in a non-U.S.
jurisdiction. The attestation should include the applicant’s commitment that the MMA product
will continue to meet the quality standards for marketing in its originally intended market. The
attestation should establish that the MMA product conforms to the information described in the
approved application regarding the quality of active ingredients, drug products, intermediates,
raw materials, reagents, components, in-process materials, container closure systems, and other
materials used in the production of the drug. The attestation should establish that the MMA
product, including the device constituent part (as applicable), is manufactured, packaged,
labeled, and tested at the facility(ies) approved in the NDA, including specific site(s), production
lines, and quality system(s). The attestation described above and executed batch records
described below would generally be considered an acceptable way to demonstrate in the
supplement that the MMA product is the FDA-approved product.
The supplement should include the executed batch record, including the certificate of analysis
(COA), for at least one commercial scale batch of the MMA product produced using each of the
intended manufacturing line(s). This analysis should be compared to the analysis completed for
a recently manufactured commercial batch produced and released for distribution to the U.S.
market under the approved NDA.