Guidance for Industry 
CMC Postapproval 
Manufacturing Changes To Be 
Documented in Annual Reports 
 
 
 
 
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Drug Evaluation and Research (CDER) 
 
March 2014 
CMC 
 
 
OMB Control No. 0910-0001 
Current expiration date available at https://www.reginfo.gov 
(Search ICR and enter OMB control number) 
See additional PRA statement in section VI of this guidance. 
 
  Guidance for Industry 
CMC Postapproval 
Manufacturing Changes To Be 
Documented in Annual Reports 
 
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 20993-0002 
Phone: 301-796-3400; Fax: 301-847-8714 
druginfo@fda.hhs.gov 
www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm 
 
 
 
 
 
 
 
 
 
 
U.S. Department of Health and Human Services  
Food and Drug Administration 
Center for Drug Evaluation and Research (CDER) 
 
March 2014 
CMC   
Contains Nonbinding Recommendations 
TABLE OF CONTENTS 
 
I.  INTRODUCTION............................................................................................................. 1 
II.  BACKGROUND ............................................................................................................... 2 
III.  DISCUSSION .................................................................................................................... 2 
IV.  CONTENTS OF ANNUAL REPORT NOTIFICATION .............................................. 4 
V.  RESOURCES .................................................................................................................... 5 
VI.  PAPERWORK REDUCTION ACT OF 1995 ................................................................ 6 
APPENDIX A: EXAMPLES OF CMC POSTAPPROVAL MANUFACTURING  
                           CHANGES TO BE DOCUMENTED IN ANNUAL REPORTS IF THEY  
                           HAVE A MINIMAL POTENTIAL TO HAVE AN ADVERSE EFFECT  
                           ON PRODUCT QUALITY ............................................................................... 8 
APPENDIX B: EXAMPLES OF CHANGES TO BE DOCUMENTED IN AN ANNUAL  
                           REPORT FROM FDAS SUPAC-IR, SUPAC-MR, SUPAC-SS, AND  
                           CHANGES TO AN APPROVED NDA OR ANDA GUIDANCES ................ 12 
   
Contains Nonbinding Recommendations 
Guidance for Industry1 
CMC Postapproval Manufacturing Changes  
To Be Documented in Annual Reports 
 
 
 
 
This guidance represents the Food and Drug Administrations (FDAs) 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 provides recommendations to holders of new drug applications (NDAs) and 
abbreviated new drug applications (ANDAs) regarding the types of changes to be documented  
in annual reports. Specifically, the guidance describes chemistry, manufacturing, and controls 
(CMC) postapproval manufacturing changes that we have determined will likely have a  
minimal potential to have an adverse effect on product quality2 and, therefore, should be 
documented by applicants in an annual report.3,4 
 
Appendix A lists examples of CMC postapproval manufacturing changes previously submitted 
under manufacturing supplements that we have determined generally to be of low risk to  
product quality. Appendix B provides examples of minor changes to be documented in an 
annual report that were previously published in FDAs Scale-up and Postapproval Changes 
(SUPAC) guidances and other postapproval change CMC guidances (see Section V. Resources 
for a list of those guidances). 
 
FDAs guidance documents, including this guidance, do not establish legally enforceable 
responsibilities. Instead, guidances describe the Agencys 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 Pharmaceutical Science (OPS) in the Center for Drug 
Evaluation and Research (CDER) at the Food and Drug Administration. 
2 In this guidance, the term product quality refers to drug product identity, strength, quality, purity, or potency,  
as these factors may relate to the safety or effectiveness of the drug product. 
3 See 21 CFR 314.70(d). 
4 This guidance excludes positron emission tomography (PET) drug products. See the guidance for industry, PET 
Drugs  Current Good Manufacturing Practice (CGMP), for information about PET drug products. CDER  
updates guidances periodically. To make sure you have the most recent version of a guidance, check the FDA  
Drugs guidance web page at  
www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm. 
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Contains Nonbinding Recommendations 
II.  BACKGROUND 
 
An applicant must notify FDA of a change to an approved application in accordance with all 
statutory and regulatory requirementsincluding section 506A of the Federal Food, Drug, and 
Cosmetic Act (21 U.S.C. 356a) (FD&C Act), which was added by section 116 of the Food and 
Drug Administration Modernization Act,5 and 21 CFR 314.70. Section 506A of the FD&C Act 
provides requirements for making and reporting manufacturing changes to an approved 
application and for distributing a drug product made with such changes. Under 21 CFR 314.70, 
all postapproval CMC changes beyond the variations provided for in an approved NDA and 
ANDA are categorized into one of three reporting categories: major, moderate, or minor. 
 
If a change is considered to be major, an applicant must submit and receive FDA approval of a 
supplemental application to the NDA or ANDA before the product made with the  
manufacturing change is distributed (also known as a prior approval supplement (PAS)). If a 
change is considered to be moderate, an applicant must submit a supplement at least 30 days 
before the product is distributed (CBE-30 supplement) or, in some cases, submit a supplement  
at the time of distribution (CBE-0 supplement).6 If a change is considered to be minor, an 
applicant may proceed with the change, but must notify FDA of the change in an annual report. 
For any change, applicants must assess the effects of the change on product quality through 
appropriate studies. For additional background information regarding the reporting categories 
for NDAs and ANDAs, see FDAs guidance for industry on Changes to an Approved NDA or 
ANDA (April 2004). 
 
In our September 2004 final report, Pharmaceutical Current Good Manufacturing Practices 
(CGMPs) for the 21st Century  A Risk-Based Approach (Pharmaceutical Product Quality 
Initiative), the Agency stated that to keep pace with the many advances in quality management 
practices in manufacturing and to enable the Agency to more effectively allocate our limited 
regulatory resources, we would implement a cooperative, risk-based approach for regulating 
pharmaceutical manufacturing. As part of this approach, the Agency determined that to  
provide the most effective public health protection, our CMC regulatory review should be  
based on an understanding of product risk and how best to manage this risk. 
 
In addition to the requirements in section 506A of the FD&C Act and 21 CFR 314.70,  
applicants are required to comply with other applicable laws and regulations, including the 
Current Good Manufacturing Practice for Finished Pharmaceuticals (CGMP) regulations in 21 
CFR Parts 210 and 211. 
 
III.  DISCUSSION 
 
The number of CMC manufacturing supplements for NDAs and ANDAs has continued to 
increase over the last several years. In connection with FDAs Pharmaceutical Product Quality 
Initiative and our risk-based approach to CMC review, we have evaluated the types of changes 
that have been submitted in CMC postapproval manufacturing supplements and determined  
 
5 Public Law 105-115. 
6 CBE is changes being effected. 
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Contains Nonbinding Recommendations 
that many of the changes being reported present low risk to the quality of the product and do  
not need to be submitted in supplements. 
 
Based on our risk-based evaluation, we developed a list (see Appendix A) to provide additional 
current recommendations to companies regarding some postapproval manufacturing changes  
for NDAs and ANDAs that may be considered to have a minimal potential to have an adverse 
effect on product quality, and, therefore, may be classified as a change to be documented in the 
next annual report (i.e., notification of a change after implementation) rather than in a 
supplement. 
 
The changes listed in Appendix A are categorized according to the type of manufacturing 
change. These changes are either additions or revisions to the CMC changes recommended for 
documentation in an annual report that were previously published in the guidance for industry  
on Changes to an Approved NDA or ANDA, the SUPAC guidances, and other related guidances 
(see Section V. Resources). Thus, before you submit a supplement based on recommendations 
provided in these previously published guidances, you also should refer to the list of risk-based 
recommendations that are provided in Appendix A of this guidance. These recommendations 
clarify whether submission of a supplement or documentation of the change in an annual report 
may be appropriate. 
 
We expect NDA and ANDA holders to evaluate the specific change that they are planning to 
make in the context of their particular circumstances to determine whether the proposed change 
would present a minimal potential to have an adverse effect on product quality. When a risk- 
based evaluation shows that the proposed change would have a minimal potential to have an 
adverse effect on product quality, the change can be documented in the next annual report. An 
NDA or ANDA holder may, based on their specific circumstances, decide that a change 
described in Appendices A and B would more appropriately be submitted as a supplement  
rather than in an annual report. In such cases, changes should be reported to the Agency 
according to the results of the risk-based evaluation and 21 CFR 314.70. Accordingly, we 
consider this guidance to provide recommendations for changes that are appropriately 
documented in an annual report rather than to establish a requirement to document these  
changes in annual reports pursuant to 21 CFR 314.70(a)(3).7 
 
To the extent that a recommendation in this guidance to document a single change in an annual 
report is found to be inconsistent with previously published FDA guidances, the reporting 
category recommended in this guidance would apply, assuming that the applicants proposed 
change would present a minimal potential to have an adverse effect on product quality. For 
changes not addressed in this guidance, or for multiple related changes implemented 
simultaneously, applicants should refer to other CDER guidances (see Section V. Resources),  
as well as Appendix B, to determine the appropriate reporting categories (i.e., PAS, CBE-30, 
CBE-0, or annual report) for notifying the Agency of the changes. 
 
 
7 Under 21 CFR 314.70(a)(3), an applicant is required to make a change in accordance with a regulation or  
guidance that provides for a less burdensome notification of the change. In this guidance, we are asking applicants  
to use scientific data from appropriate studies and risk analysis to determine whether changes should be submitted  
in a PAS, CBE-30, CBE-0, or annual report. 
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Contains Nonbinding Recommendations 
Applicants should note FDAs recommendations for active pharmaceutical ingredient 
manufacturing that are provided in the guidance for industry, Q7A Good Manufacturing  
Practice Guidance for Active Pharmaceutical Ingredients (August 2001). CGMP regulations  
for finished pharmaceuticals contain specific requirements relevant to the types of changes 
addressed in this guidance, and compliance with the CGMP regulations is required regardless  
of how the change is reported to the Agency. CGMP requirements include establishing and 
following appropriate written procedures reviewed and approved by the quality unit, qualifying 
equipment as suitable for its intended use, using validated test methods, scientifically 
establishing the commercial manufacturing process, and ensuring the manufacturing processs 
ongoing state of control (which may include additional process validation and stability studies 
depending on the nature of the change).8 
 
If you have specific questions associated with whether or not the change should be submitted to 
the Agency in a supplement or documented in an annual report, we recommend that you  
contact the appropriate CDER review division in the Office of New Drug Quality Assessment, 
the Office of Generic Drugs, or OPSs New Drug Microbiology Staff. 
 
IV.  CONTENTS OF ANNUAL REPORT NOTIFICATION 
 
To document changes in an annual report in accordance with 21 CFR 314.81(b)(2)(iv)(b) and 
314.70(d)(3), the applicant must include a full description of the CMC changes that were made 
that the applicant believes did not require a supplemental application under sections 314.70(b) 
and (c). This description should include: 
 
  A list of each change and the date each change was implemented; and 
 
  Relevant summary of data from studies and tests performed to assess the effects of each 
change on product quality, including (where applicable) a list of cross-references to 
change control and change validation protocols and standard operating procedures 
(SOPs) that were used to assess or demonstrate the effect of the change. 
 
The description also should include: 
 
  The name(s) of one or more drug products affected or involved in the change (e.g., 
different label strengths/product presentations); or 
 
  Reference to any previously approved grouped supplements if the change affected 
multiple products. 
 
Executed batch records, SOPs, and data from studies and tests performed to assess the effects  
of each change should be kept on file and made available to the Agency on request (e.g., during 
an inspection). The applicant should describe each change in an annual report in enough detail  
to allow the Agency to efficiently determine whether the appropriate reporting category has  
 
8 See 21 CFR 210 and 211. 
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Contains Nonbinding Recommendations 
been used. If the submitted change is inappropriate for documentation in an annual report, the 
applicant will be notified of the correct category and additional information may be requested. 
 
V.  RESOURCES 
 
Provided below are other FDA guidances that discuss reporting of CMC postapproval changes. 
They should be referred to in addition to this guidance. 
 
  FDA guidances applicable to the CMC section of a drug application: 
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm 
064979.htm 
 
In prior CMC postapproval changes guidance documents, recommendations are provided for 
changes in components and composition, manufacturing sites, manufacturing process, 
specifications, container/closure system, labeling, miscellaneous changes, and multiple related 
changes. 
 
  PAC-ATLS: Postapproval Changes  Analytical Testing Laboratory Sites, dated 
April 28, 1998, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM070582.pdf. 
 
  SUPAC-IR: Immediate Release Solid Oral Dosage Forms: Scale-up and 
Postapproval Changes: Chemistry, Manufacturing, and Controls, In Vitro 
Dissolution Testing, and In Vivo Bioequivalence Documentation, dated November 
1995, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM070636.pdf. 
 
  SUPAC-IR Questions and Answers about SUPAC-IR Guidance, dated February 
18, 1997, 
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm 
124826.htm. 
 
  SUPAC-IR/MR: Immediate Release and Modified Release Solid Oral Dosage 
Forms Manufacturing Equipment Addendum, dated January 1999, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM070637.pdf. 
 
  SUPAC-MR: Modified Release Solid Oral Dosage Forms Scale-up and 
Postapproval Changes: Chemistry, Manufacturing, and Controls; In Vitro 
Dissolution Testing and In Vivo Bioequivalence Documentation, dated September 
1997, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM070640.pdf. 
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Contains Nonbinding Recommendations 
  SUPAC-SS: Nonsterile Semisolid Dosage Forms; Scale-Up and Postapproval 
Changes: Chemistry, Manufacturing, and Controls; In Vitro Release Testing 
and In Vivo Bioequivalence Documentation, dated May 1997, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM070930.pdf. 
 
  SUPAC-SS: Nonsterile Semisolid Dosage Forms Manufacturing Equipment 
Addendum, dated December 1998, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM070928.pdf. 
 
  Changes to an Approved NDA or ANDA: Questions and Answers, dated 
January 2001, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM122871.pdf. 
 
  Changes to an Approved NDA or ANDA, Revision 1, dated April 2004, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM077097.pdf. 
 
  Changes to an Approved NDA or ANDA; Specifications  Use of Enforcement 
Discretion for Compendial Changes, dated November 2004, 
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Gui 
dances/UCM070544.pdf. 
 
VI.  PAPERWORK REDUCTION ACT OF 1995 
 
This guidance contains information collection provisions that are subject to review by the  
Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1995 (44 
U.S.C. 3501-3520). The expiration of the OMB control number will be updated periodically. 
 
The total number of supplements submitted per year is estimated to reduce based on the 
recommendations in the guidance because certain changes submitted as supplements would  
now be documented in annual reports. Therefore, for such changes, the information collection 
with respect to the submission of supplements will be reduced. Because the number of 
supplements per year is estimated to reduce, the total number of hours for preparing  
supplements would correspondingly reduce. Send comments regarding this burden estimate or 
suggestions for reducing this burden to: 
 
The Office of Pharmaceutical Science, Center for Drug Evaluation and Research, Food and  
Drug Administration, 10903 New Hampshire Ave., Bldg. 51, Rm. 4178, Silver Spring, MD 
20993-0002. 
 
This guidance also refers to previously approved collections of information found in FDA 
regulations: (1) The submission of supplements to FDA for certain changes to an approved 
application in accordance with 21 CFR 314.70 and 314.71; (2) the submission of annual reports 
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Contains Nonbinding Recommendations 
to FDA (Form FDA 2252) in accordance with  314.81(b)(2); (3) the submission of  
supplements to an approved ANDA for changes that require FDA approval; and (4) other post- 
marketing reports for ANDAs in accordance with  314.98(c), of which the estimate for annual 
reports is included under  314.81(b)(2). FDA currently has OMB approval for these  
collections of information under OMB Control Number 0910-0001. 
 
An agency may not conduct or sponsor, and a person is not required to respond to, a 
collection of information unless it displays a currently valid OMB control number.  The 
OMB control number for this information collection is 0910-0001.  The current 
expiration date is available at https://www.reginfo.gov (search ICR and enter OMB 
control number). 
 
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Contains Nonbinding Recommendations 
APPENDIX A: EXAMPLES OF CMC POSTAPPROVAL MANUFACTURING 
CHANGES TO BE DOCUMENTED IN ANNUAL REPORTS IF THEY 
HAVE A MINIMAL POTENTIAL TO HAVE AN ADVERSE EFFECT 
ON PRODUCT QUALITY 
1.  Components and Composition 
 
1.1.  Elimination or reduction of an overage from the drug product manufacturing batch 
formula that was previously used to compensate for manufacturing losses. 
 
1.2.  Change in coating formulation for immediate-release solid dosage forms if the coating 
material and quantity have been approved for another similar product9 and the change 
does not alter release of the drug, specification (i.e., tests, analytical procedures, and 
acceptance criteria for test results), or stability. 
 
1.3.  In instances where the supplier of an inactive ingredient was specified in an approved 
application, change to a new supplier of that inactive ingredient (e.g., change from  
one drug master file (DMF) holder to other DMF holder or change to a new qualified 
supplier). This is applicable only if the inactive ingredients specification remains 
unchanged. 
 
2.  Manufacturing Sites 
2.1.  Minor structural modifications made in the sterile product manufacturing facility 
approved in an application that do not affect a product manufacturing area or sterility 
assurance and do not change product quality or specification. 
2.2.  In the manufacturing of sterile products, the addition of barriers within a conventional 
fill area to prevent routine in-process human intervention in an existing filling or 
compounding area that is qualified and validated by established procedures. 
 
3.  Manufacturing Process, Batch Size, and Equipment 
3.1.  The following process changes: 
 
3.1.1.  Addition of a sieving step(s) for aggregates removal if it occurs under  
nonaseptic conditions. 
 
3.1.2.  Changes in mixing times (for blending powders, granules) for immediate-release 
solid oral dosage forms and solution products.10  
 
3.1.3.  Changes in drying times for immediate-release solid oral dosage forms. 
 
9 See the Inactive Ingredient Database, available on FDAs web site at 
www.accessdata.fda.gov/scripts/cder/iig/index.cfm. 
10 Note the requirement for finished pharmaceuticals to establish and follow procedures regarding adequacy of 
mixing to assure uniformity and homogeneity for appropriate dosage forms per 21 CFR 211.110(a). 
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Contains Nonbinding Recommendations 
3.2.  Manufacturing batch size or scale change that results from combining previously 
separated batches (or lots) of in-process material to perform the next step in the 
manufacturing process if all combined batches meet the approved in-process control 
limits, the next step remains unaffected, and appropriate traceability is maintained. 
 
3.3.  For equipment used in aseptic manufacturing processes (e.g., new filling line, new 
lyophilizer), replacement of equipment with that of the same design and operating 
principle, when there is no change in the approved process methodology or in-process 
control limits. 
 
3.4.  Addition of identical processing lines that operate parallel to each other in the drug 
substance and drug product manufacturing process with no change in in-process control 
limits or product specification. 
 
3.5.  For sterile drug products, addition of, deletion of, or change in a reprocessing protocol 
for refiltrations to control bioburden because of filter integrity test failures. 
 
3.6.  Decrease in the number of open handling steps or manual operation procedures, when  
it reduces risk to product and there is no other change to the process (e.g., 
implementation of aseptic connection devices to replace flame protection procedures). 
 
3.7.  For sterile drug products, changes to the ranges of filtration process parameters (such  
as flow rate, pressure, time, or volume, but not pore size) that are within currently 
validated parameters ranges and therefore would not warrant new validation studies for 
the new ranges. 
3.8.  In the manufacture of sterile drug products, change from a qualified sterilization 
chamber (ethylene oxide (EtO), autoclave) to another of the same design and  
operating principle for the preparation of container/closure systems, sterilization of 
change parts for processing equipment, and terminal sterilization of product, when  
the new chamber and load configurations are validated to operate within the  
previously validated parameters. This does not include situations that change the 
validation parameters. 
4.  Specifications 
 
4.1.  Addition of a new test to the specification for an excipient 
 
4.2.  Change to the specification for a drug substance, drug product, or pharmacopeial 
excipient that is made to comply with the official compendia if it is a change that does 
not relax an acceptance criterion or delete a test. 
 
Specification changes not suitable for documentation in an annual report include 
changes to an assay, tests for impurities, degradation products, product-related 
substances, or biological activities that are approved in NDAs and ANDAs. Such 
changes should be submitted in a supplement. 
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Contains Nonbinding Recommendations 
 
4.3.  Change in the approved analytical procedure if the revised method maintains the 
original test methodology and provides equivalent or increased assurance that the drug 
substance or drug product will have the characteristics of identity, strength, quality, 
purity, or potency that it claims to have or is represented to possess and the acceptance 
criteria remain unchanged (e.g., change in the flow rate or sample preparation for a high 
performance liquid chromatography (HPLC) method). 
 
4.4.  Replacement of a nonspecific identity test with a discriminating identity test that 
includes a change in acceptance criteria (e.g., replacing SDS-PAGE11 with peptide 
map). 
 
4.5.  Addition of an in-process test. 
 
4.6.  Replacement of blend uniformity and in-process homogeneity tests with other 
appropriate testing that ensures adequacy of mix. 
 
4.7.  Revision of tablet hardness (e.g., acceptance criterion for test result or change to a 
different analytical procedure and its associated acceptance criterion for test result) if 
there is no change in the approved dissolution analytical procedure, criteria, or 
associated dissolution profile. 
 
4.8.  Addition of a test for packaging material to provide increased assurance of quality. 
4.9.  Tightening of an approved acceptance criterion for a drug substance, a drug product, 
drug product formulation components, and in-process material. 
5.  Container/Closure System 
5.1.  A change in the container/closure system for the storage of a nonsterile drug substance 
(solid, semisolid, or liquid) when the proposed container/closure system has no 
increased risk of leachable substances in the extractable profile (for semisolids and 
liquids) and equivalent protection properties for the packaged material. 
5.2.  Use of or transfer to a contract manufacturing organization (CMO) for the washing, 
drying, or/and siliconization of a drug product stopper or any part of a container closure 
system, provided the applicant certifies that the CMOs processes have been validated 
and the CMOs site has been audited and found CGMP compliant by the applicant (or 
by another party sponsored by the applicant).. 
 
5.3.    For solid oral dosage forms, when the change is to use another suitable primary 
packaging component used in any other CDER-approved drug product: 
 
5.3.1.  Change in type of desiccant to another desiccant that was previously used in 
another approved product and is suitable for its intended use. 
 
11 SDS-PAGE stands for sodium dodecyl sulfate polyacrylamide gel electrophoresis. 
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Contains Nonbinding Recommendations 
5.3.2.  Elimination of a bottle filler, such as a fibrous material (e.g., suitable type of 
cotton, rayon, polyester, etc.) that is used to fill empty or void space in the 
finished product container. 
 
5.4.  For parenteral drug products, a change in glass supplier without a change in glass type 
or coating and without a change in container/closure dimensions. 
 
5.5.  Changes to a crimp cap (ferrule and flip cap/overseal), provided that there are no 
changes to the color and that the container and closure integrity have been 
demonstrated using a validated test method. Note, however, that a change in the flip 
cap/overseal color to make it consistent with an established color coding system for that 
class of drug products is to be documented in an annual report. 
 
5.6.  Change to delete the company trademark or other markings on the crimp cap (ferrule 
and flip cap/overseal) to comply with the official compendium. 
 
6.    Labeling Changes 
 
6.1.  Revision in drug product labeling to reflect the qualitative change in inactive 
ingredient(s) of coating formulation, as recommended in 1.2 above. The final 
Structured Product Labeling (SPL) reflecting the qualitative change should be 
submitted to the Agency when implementing this change to allow for maintenance of 
the current product information in eLIST.12 This will help ensure the safe and effective 
use of the drug product. 
 
6.2.  A change in the drug product labeling to revise information related to CMC changes 
discussed in this guidance. If the change involves associated revision of drug product 
labeling, 6.1 above would apply. 
 
7.    Miscellaneous Changes 
 
7.1.  Extension of the drug substance retest dating period or drug product expiration dating 
period based on real-time stability data from pilot-scale or larger/commercial-scale 
batches following an approved stability protocol. 
7.2.  For immediate release solid oral dosage forms, if a dissolution test is performed, 
elimination of a test for identity or hardness from an approved stability protocol. 
 
7.3.For changes in an application that are fully consistent in scope and requirements with 
changes previously approved in a grouped supplement (also defined as a Bundled 
Supplement), the same applicant can make the same change to similar drug products.13  
 
12 See www.fda.gov/downloads/ForIndustry/DataStandards/StructuredProductLabeling/UCM164094.pdf. 
13 See MAPP 5015.6, Review of the Same Supplemental Change to More Than One NDA or ANDA in More Than 
One Review Division, January 2000, 
www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofMedicalProductsandTobacco/CDER/ManualofPolici 
esProcedures/ucm079567.pdf. 
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Contains Nonbinding Recommendations 
APPENDIX B: EXAMPLES OF CHANGES TO BE DOCUMENTED IN AN ANNUAL 
REPORT FROM FDAS SUPAC-IR, SUPAC-MR, SUPAC-SS, AND 
CHANGES TO AN APPROVED NDA OR ANDA GUIDANCES 
1. Components and Composition 
 
1.1.  Any change made to comply with the official compendium, except relaxation of an 
acceptance criterion or deletion of a test (see 21 CFR 314.70(c)(2)(iii)). 
 
1.2.  Complete or partial deletion of an ingredient intended to affect only the color, flavor,  
or fragrance of the drug product without change in other approved specification. Note 
that a deletion or change in color, flavor, or fragrance also may affect the appearance 
and other noticeable organoleptic properties (visual appearance, taste, flavor, odor, or 
fragrance) of the dosage form. These changes may affect the How the Drug Product  
is Supplied section of labeling. In such cases, reporting of revision or change as 
described in Appendix A, 6. Labeling Changes, also would apply. 
 
1.3.  Change in nonrelease controlling excipients, expressed as percentage (w/w) of total 
formulation approved in the original application, less than or equal to the following 
percent ranges: Filler  5%, Disintegrant (Starch 3%, Other  1%), Binder 0.5%, 
Lubricant (Calcium or Magnesium Stearate 0.25%, Other  1%), Glidant (Talc 1%, 
Other 0.1%), and Film Coat 1%. 
 
1.4.  Change in the supplier of an excipient, where the technical grade and specification for 
the excipient remain the same. 
1.5.  Changes in release controlling excipients less than or equal to 5% expressed as a 
percentage (w/w) of total release controlling excipients approved in the original 
application of a modified-release solid oral dosage form. After the change, the total 
weight of the dosage form and its specification would remain the same as originally 
approved. 
 
2. Manufacturing Site 
2.1.  When the new site has a satisfactory CGMP inspection status for the type of  
operation14 involved, the following changes can be documented in an annual report: 
 
2.1.1.  A move to a different manufacturing site for secondary packaging, labeling, ink 
imprinting on a solid oral dosage form, and manufacture or processing of drug 
substance intermediates other than the final intermediate. 
 
2.1.2.  Change in location of manufacturing (including terminal sterilization of finished 
product) within the same facility or site for both company-owned and contract 
manufacturers that do not include any scale-up changes, changes in 
manufacturing process or equipment, or changes in components and  
 
14 See the guidance to industry, Changes to an Approved NDA or ANDA, Appendix B. 
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Contains Nonbinding Recommendations 
composition of drug product.  The standard operating procedures, personnel with 
suitable experience with the manufacturing processes, environmental conditions 
and controls, and manufacturing batch records will remain the same except for 
administrative information and the location within the same facility or site. 
 
3. Manufacturing Process 
 
3.1.  For drug products, change to equipment of the same design and operating principles, 
capacity, and/or batch size (increase or decrease), except for natural protein drug 
substances and natural protein drug products. 
 
3.2.  Change in the order of addition of drug product components for solution dosage forms 
(except active pharmaceutical ingredients) or change in the order of ingredients added  
to solutions used in unit operations (e.g., granulation solutions). 
 
4. Specifications 
 
4.1.  For drug substance and drug product, the addition or revision of an alternative 
analytical procedure that provides the same or increased assurance of the identity, 
strength, quality, purity, or potency of the material being tested as the analytical 
procedure described in the approved application or deletion of an alternative  
analytical procedure. 
 
4.2.  A change in an analytical procedure used for testing raw materials used in drug 
substance synthesis, starting materials introduced prior to the final drug substance 
intermediate, in-process materials prior to the final intermediate, or drug substance 
intermediates (excluding final intermediate) that provides the same or increased 
assurance of the identity, strength, quality, purity, or potency of the material being 
tested as the analytical procedure described in the approved application. 
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