BACKGROUND The development of FDCs is becoming increasingly high either to improve compliance or to benefit from the added effects of the two or more active drugs given together. They are being used in the treatment of a wide range of conditions and are particularly useful in the management of chronic conditions. FDCs should always be based on convincing therapeutic justification. Each fixed dose combination should be carefully justified and clinically relevant (e.g. in cases when each component of the FDC has several possible dosages, dosages that have shown benefit on clinical outcomes may be preferable). Appendix VI of Schedule Y (Drugs & Cosmetics Rules 1945) specifies the requirements for approval for marketing of various types of FDCs. The same is further elaborated to provide a detailed guidance for industry. SCOPE These guidelines apply to manufacture / import and marketing approval of FDCs as a finished pharmaceutical product considered as new drug as per Rule 122(E) of Drugs and Cosmetics Act & Rules. GENERAL CONSIDERATIONS
GUIDELINES ON DATA REQUIRED FOR APPROVAL FOR MARKETING FDCs FDCs can be divided into the following groups and data required for approval for marketing is described below: FDC - Not marketed in India & one or more active ingredient(s) is a new drug not approved in India. CLARIFICATION: Such type of FDCs can be further classified into two categories as follows: Category I: One of the ingredients of the combination is an Investigational New Drug (IND). For such FDCs to be approved for marketing, data required to be submitted will be similar as per Appendix I of Schedule Y which is similar to data required for any new chemical entity (NCE). For such FDCs the clinical trials is required to be carried out right from Phase I. For new drug permission of such FDCs the documents required to be submitted are as follows:
Chemical and pharmaceutical information including: Animal Pharmacology
Animal Toxicology
Human / Clinical pharmacology (Phase I)
Therapeutic exploratory trials (Phase II)
Therapeutic confirmatory trials (Phase III)
Special studies
Regulatory status in other countries
Prescribing information
Samples and Testing Protocol/s
NOTE: Details of Animal Pharmacology & Animal Toxicology studies required to be carried out will be as per Appendix IV & Appendix III of Schedule Y of Drugs and Cosmetics Rules respectively. Depending upon the nature of new drugs and disease(s) specific additions/deletions may be made to the above requirements. Category II: One or more of the ingredients of the combination is a New Drug not approved individually in the country however the same is approved in other country. If such FDC is marketed abroad Phase III clinical trials are required to be conducted in India. In case, such a combination is not marketed anywhere in the world, clinical trials right from Phase I as appropriate are required to be conducted in the country. For such FDCs to be approved for marketing, data to be submitted will be similar to data required for any new drug substance as mentioned in Category I above. (In case of injectable formulation, sub-acute toxicity data conducted with the applicants’ product has to be provided). FDC - Not marketed in India but the active ingredients are approved/ marketed individually & it is likely to have significant PK/PD interactions CLARIFICATION: This group of FDCs includes those in which active ingredients already approved /marketed individually are combined for the first time (for marketing in India), for a particular claim and where the ingredients are likely to have significant interaction of a pharmacokinetic or pharmacodynamic (PK/PD) nature. This can be further classified in to following, FDC - Marketed abroad CLARIFICATION: This group of FDCs includes those in which active ingredients already approved/ marketed individually are combined for the first time, for a particular claim and where the ingredients are likely to have significant PK/PD interaction, but, are being marketed abroad with an established safety and efficacy in humans. For approval of such FDCs, following documents have to be submitted,
NOTE: Names of the countries where the FDC is Approved / Marketed / Withdrawn etc should be clearly stated in the covering letter also. 9. Source of bulk drugs /raw materials (for those ingredients which are considered new drugs) - If the applicant has a manufacturing license for bulk drugs, please provide a copy of the same. Otherwise, provide the consent letter from the approved source regarding supply of material. Clarification: In case if the applicant does not have an approval from DCGI to manufacture any of the Active Pharmaceutical Ingredient (API) which is considered as new drug, applicant can,
10. Copy of proposed Package Insert (generic name of all active ingredients; composition; dosage form/s, indications; dose and method of administration; use in special populations; contra-indications; warnings; precautions; drug interactions; undesirable effects; overdose; pharmacodynamic and pharmacokinetic properties; incompatibilities; shelf-life; packaging information; storage and handling instructions) and draft Label / Carton etc. FDC - Not marketed anywhere but individual components used concomitantly CLARIFICATION: FDC is not marketed anywhere in the world, but the individual components [active drug(s)] are already in use concomitantly (not as an FDC but individually) for the said claim. For approval of such FDCs, following documents have to be submitted, 1. Form 44 2. Treasury Challan of INR 15,000 if all the active ingredients are approved in India for more than one year, or INR 50,000 in case any of the active ingredients is approved for less than one year. 3. Complete chemical and pharmaceutical data (As per Annexure I) 4. Rationale for combining them in the proposed ratio and therapeutic justification along with supporting literature. 5. Summary of Drug-Drug-Interactions (known and/or expected) among the active ingredients present in the FDC, along with its implications. This should be prepared and signed by a competent person on behalf of applicant. 6. Summary of available pharmacological, toxicological and clinical data on the individual ingredients 7. Clinical data showing safety and efficacy of the FDC / Concomitant use of the ingredients, in the same strength, including published data. If enough supportive literatures are not available, then ‘adequate evidence’ on safe and effective concomitant use of the ingredients should be provided. 8. In case of injectable formulation, sub-acute toxicity data conducted with the applicants’ product has to be provided. 9. Source of bulk drugs /raw materials (for those ingredients which are considered new drugs) - If the applicant has a manufacturing license for bulk drugs, please provide a copy of the same. Otherwise, provide the consent letter from the approved source regarding supply of material. Clarification: In case if the applicant does not have an approval from DCGI to manufacture any of the API which is considered as new drug, he can
10. Copy of proposed Package Insert (generic name of all active ingredients; composition; dosage form/s, indications; dose and method of administration; use in special populations; contra-indications; warnings; precautions; drug interactions; undesirable effects; overdose; pharmacodynamic and pharmacokinetic properties; incompatibilities; shelf-life; packaging information; storage and handling instructions) and draft Label / Carton etc. FDC - Not marketed and individual components are not used concomitantly CLARIFICATION: In case the FDC is not marketed anywhere in the world and the individual components are not concomitantly used in routine clinical practice and the ingredients are likely to have significant PK/PD interaction, clinical trials may be required. For obtaining permission to carry out Bio-availability/Bioequivalence (BA/BE) studies (when applicable) followed by Clinical trial in Indian subjects with such FDCs, following documents have to be submitted to this office, A. Form 44 (Application for manufacture and market New FDC, BA/BE study and clinical trial application) B. Treasury Challan of INR 15,000 in case all the active ingredients are approved in India for more than one year, or INR 50,000 in case any of the active ingredients is approved for less than one year. C. Appropriate chemical and pharmaceutical data (As per Annexure I a) D. Rationale for combining them in the proposed ratio and therapeutic justification along with supporting literature. E. Summary of Drug-Drug-Interactions (expected interactions, based on the pharmacology of active ingredients) among the active ingredients present in the FDC, along with its implications. This should be prepared and signed by a competent person on behalf of applicant. F. Acute toxicity data (LD 50) and pharmacological data should be submitted. G. In case of injectable formulation, sub-acute toxicity data conducted with the applicants’ product has to be provided. H. Source of bulk drugs /raw materials (for those ingredients which are considered new drugs) - If the applicant has manufacturing license for bulk drugs, please provide a copy of the same. Otherwise provide the consent letter from the approved source regarding supply of material. Clarification: In case if the applicant does not have approval from DCGI to manufacture any of the API which is considered as new drug, he can
I. BA/BE study protocol (when applicable), and Clinical study protocol as per Appendix X of Schedule Y J. Patient Information Sheet and Informed Consent Form (ICF) as per Appendix V of Schedule Y K. Copy of ‘Ethics Committee’ approval letters (if available) L. Case Record Form (CRF) M. Undertaking by Investigator(s) as per Appendix VII of Schedule Y and CV N. Certificate of analysis of study drug(s) O. Summary of available pharmacological, toxicological and clinical data on the individual ingredients should be submitted along with any published data. After the successful completion of clinical trial(s) following documents have to be submitted to complete the marketing application, 1. Complete chemical and pharmaceutical data (As per the Annexure I) 2. Source of bulk drugs /raw materials (for those ingredients which are considered new drugs) - If the applicant has obtained permission for manufacturing of bulk drugs provide a copy of the same, otherwise provide the consent letter from the approved source, regarding supply of material. Clarification: In case if the applicant did not have approval from DCGI to manufacture any of the API which is considered as new drug, he should submit all required data for grant of permission to Import /manufacture of the API. 3. BA/BE study report and Clinical Study Report conducted in Indian population as per Appendix II of Schedule Y. The study report should be certified by each of the participating investigator(s) in the study and the certification should acknowledge the contents of the report, the accurate presentation of the study as-undertaken, and express agreement with the conclusions. Each page should be numbered. 4. Copy of proposed Package Insert (generic name of all active ingredients; composition; dosage form/s, indications; dose and method of administration; use in special populations; contraindications; warnings; precautions; drug interactions; undesirable effects; overdose; pharmacodynamic and pharmacokinetic properties; incompatibilities; shelf-life; packaging information; storage and handling instructions) and draft Label / Carton etc. FDC - Marketed in India but some changes are sought CLARIFICATION: This group of FDCs includes those which are already marketed, but now it is proposed either to change the ratio of active ingredients or to make a new therapeutic claim or a new dosage form. For approval of such FDCs, following documents have to be submitted, 1. Form 44 2. Treasury Challan of INR 15,000 in case all the active ingredients are approved in India for more than one year, or INR 50,000 in case any of the active ingredients is approved for less than one year 3. Complete chemical and pharmaceutical data (As per Annexure I) 4. Rationale for combining them in the proposed ratio/new dosage form and therapeutic justification along with supporting literature. 5. Summary of Drug-Drug-Interactions (known and/or expected) among the active ingredients present in the FDC, along with its implications. This should be prepared and signed by a competent person on behalf of applicant. 6. Clinical trials data showing safety and efficacy of the FDC with the proposed new claims including published data. 7. In case of injectable formulation, sub-acute toxicity data conducted with the applicants’ product has to be provided. 8. The regulatory status of the FDC with the proposed new claims, in other countries.
9. Copy of earlier approval from the DCGI for the FDC for which new claim is being proposed as new strength / indications / dosage form etc. In case the applicant is not having the approval for the said FDC, then the applicant has to provide details on source of bulk drugs /raw materials (for those ingredients which are considered new drugs) - If the applicant has manufacturing license for bulk drugs, please provide a copy of the same. Otherwise, provide the consent letter from the approved source regarding supply of material. Clarification: In case if the applicant does not have approval from DCGI to manufacture any of the API which is considered as new drug, he can
10. Copy of proposed Package Insert (generic name of all active ingredients; composition; dosage form/s, indications; dose and method of administration; use in special populations; contraindications; warnings; precautions; drug interactions; undesirable effects; overdose; pharmacodynamic and pharmacokinetic properties; incompatibilities; shelf-life; packaging information; storage and handling instructions) and draft Label / Carton etc. NOTE: Permission will be granted depending upon the nature of the claim and data submitted. A clinical trial/ BABE study may be required if the justification provided for the new claim(s) is not satisfactory. FDC - Only for convenience CLARIFICATION: This group of FDC includes those whose individual active ingredients (or drugs from the same class) have been widely used in a particular indication(s) for years, their concomitant use is often necessary and no claim is proposed to be made other than convenience and should have demonstrated stability with no significant PK/PD interaction among the ingredients. For approval of such FDCs, following documents have to be submitted, 1. Form 44 2. Treasury Challan of INR 15,000 if all the active ingredients are approved in India for more than one year, or INR 50,000 in case any of the active ingredients is approved for less than one year. 3. Complete chemical and pharmaceutical data (As per Annexure I) 4. Rationale for combining them in the proposed ratio and therapeutic justification along with supporting literature. 5. Summary of data showing NO significant PK/PD interaction among the ingredients. This should be prepared and signed by a competent person on behalf of applicant. 6. Summary of available pharmacological, toxicological and clinical data on the individual ingredients 7. Data showing safety, efficacy and convenience in use of the FDC has to be provided. If enough supportive literatures are not available, then ‘adequate evidence’ on its convenience to users has to be demonstrated. 8. In case of injectable formulation, sub-acute toxicity data conducted with the applicants’ product has to be provided. 9. Source of bulk drugs /raw materials (for those ingredients which are considered new drugs) - If the applicant has a manufacturing license for bulk drugs, please provide a copy of the same. Otherwise, provide the consent letter from the approved source regarding supply of material. Clarification: In case if the applicant does not have an approval from DCGI to manufacture any of the API which is considered as new drug, he can
10. Copy of proposed Package Insert (generic name of all active ingredients; composition; dosage form/s, indications; dose and method of administration; use in special populations; contraindications; warnings; precautions; drug interactions; undesirable effects; overdose; pharmacodynamic and pharmacokinetic properties; incompatibilities; shelf-life; packaging information; storage and handling instructions) and draft Label / Carton etc. NOTE: No additional animal or human data are generally required FDC - Subsequent approvals after the approval of primary applicant’s FDC CLARIFICATION: FDCs which are of same strength/ratio, formulation and indication(s) of the already approved FDC of a primary applicant, the following documents are required to be submitted for subsequent approval of such FDCs for other applicants, 1. Form 44 2. Treasury Challan of INR 15,000 if all the active ingredients are approved in India for more than one year, or INR 50,000 in case any of the active ingredients is approved for less than one year. 3. Complete chemical and pharmaceutical data (As per Annexure I) 4. Regulatory status of the FDC including the details of various companies marketing the FDC 5. Bioavailability/Bioequivalence as required. When an FDC falling under Appendix VI(b)(i) of Schedule Y, is already approved in other country, for manufacture and marketing in India, applicant is required to submit chemical, pharmaceutical and clinical data generated abroad with the FDC. The guideline does not require conduct of BE study with the applicant’s original formulation. Based on same principle, if an FDC is approved in India for first time, for subsequent approval applicant is required to submit chemical and pharmaceutical for the FDC. However, if any of the individual ingredients are approved for less than 4 years in India and a BE study is required for the single ingredient formulation, a BE study is required to be conducted with the proposed FDC also). 6. In case of injectable formulation, sub-acute toxicity data conducted with the applicants’ product has to be provided. 7. Source of bulk drugs /raw materials (for those ingredients which are considered new drugs) - If the applicant has a manufacturing license for bulk drugs, please provide a copy of the same. Otherwise, provide the consent letter from the approved source regarding supply of material. Clarification: In case if the applicant does not have an approval from DCGI to manufacture any of the API which is considered as new drug, he can Import the API : Applicant has to file separate application in Form- 44 alongwith Treasury Challan of requisite fees and all relevant documents and comply with further requirements for import of API Manufacture the API: Applicant has to file separate application in Form-44 alongwith Treasury Challan of requisite fees and all relevant documents and comply with further requirements for manufacture of API Obtain the API from another manufacturer which is not yet approved by DCGI: In such case the respective manufacturer of the API has to file separate application in Form-44 alongwith Treasury Challan of requisite fees and all relevant documents. Such application will be processed simultaneously with the application for the FDC. Approval of the FDC will considered after approval of the API. 8. Copy of proposed Package Insert (generic name of all active ingredients; composition; dosage form/s, indications; dose and method of administration; use in special populations; contraindications; warnings; precautions; drug interactions; undesirable effects; overdose; pharmacodynamic and pharmacokinetic properties; incompatibilities; shelf-life; packaging information; storage and handling instructions) and draft Label / Carton etc. ANNEXURES ANNEXURE I CHEMICAL AND PHARMACEUTICAL INFORMATION FOR MARKETING PERMISSION Information on active ingredients: Drug information (Generic Name, Chemical Name or INN) & Physicochemical Data including: i. Chemical name and Structure - Empirical formula, Molecular weight ii. Physical properties - Description, Solubility, Rotation, Partition coefficient, Dissociation constant iii. Analytical Data: Elemental analysis, Mass spectrum, NMR spectra, IR spectra, UV spectra, Polymorphic identification iv. Complete monograph specification including: Identification, Identity/quantification of impurities, Enantiomeric purity, Assay v. Validations: Assay method, Impurity estimation method, Residual solvent/other volatile impurities (OVI) estimation method vi. Stability Studies as per Appendix IX of Schedule Y (format of stability reports should be as per Annexure II): Final release specification, Reference standard characterization, Material safety data sheet. Data on Formulation: i. Dosage form ii. Composition iii. Master manufacturing formula iv. Details of the formulation (including inactive ingredients) v. In process quality control check vi. Finished product specification & Method of Analysis vii. Excipient compatibility study viii. Validation of the analytical method ix. Comparative evaluation with international brand(s) or approved Indian brands, if applicable x. Pack presentation xi. Dissolution xii. Assay xiii. Impurities xiv. Content uniformity xv. pH xvi. Force degradation study xvii. Stability evaluation in market intended pack at proposed storage conditions (format of stability reports should be as per Annexure II), xviii. Packing specifications xix. Process validation ANNEXURE Ia CHEMICAL AND PHARMACEUTICAL INFORMATION FOR CLINICAL TRIAL PERMISSION Information on active ingredients: Drug information (Generic Name, Chemical Name or INN) & Physicochemical Data including: i. Chemical name and Structure - Empirical formula, Molecular weight ii. Analytical Data: Elemental analysis, Mass spectrum, NMR spectra, IR spectra, UV spectra, Polymorphic identification iii. Stability Studies: Data supporting stability in the intended containerclosure system for the duration of the clinical trial. Data on Formulation: i. Dosage form, ii. Composition, iii. Master manufacturing formula, iv. Details of the formulation (including inactive ingredients), v. In process quality control check, vi. Finished product specification & Method of Analysis, vii. Excipient compatibility study, viii. Validation of the analytical method. ix. Stability Studies: Data supporting stability in the intended containerclosure system for the duration of the clinical trial. Note: While adequate chemical and pharmaceutical information should be provided to ensure the proper identity, purity, quality & strength of the investigational product, the amount of information needed may vary with the Phase of clinical trials, proposed duration of trials, dosage forms and the amount of information otherwise available. ANNEXURE II FORMAT FOR SUBMITTING THE RESULTS OF STABILITY STUDY OF NEW DRUGS Stability testing: Summary sheet Results of stability testing should be presented as shown below. A separate form should be completed for each pharmaceutical preparation tested: Accelerated/real-time studies Name of drug product Manufacturer Address Active ingredient (INN) Dosage form Packaging Batch Number Date of manufacturing Expiry date 1. 2. 3. Shelf-life Batch Size Type of batch (experimental, pilot plant, production) 1. 2. 3. Samples tested (per batch) Storage/test conditions: Temperature C Humidity % Results: 1. Chemical findings 2. Microbiological and biological findings 3. Physical findings 4. Conclusions Signature of competent / authorized personnel Name:…………… Designation:………………… Date:………… Note: Detailed stability study data / results in tabular form should also be enclosed along with the above summary sheet. | | ||
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Tuesday, July 10, 2012
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