CERTIFICATE OF PHARMACEUTICAL PRODUCT(CPP) – AN OVERVIEW

CPP is the document that confirms a pharmaceutical product has met the quality, safety, and efficacy standards of the US FDA. CPP can be used to market pharmaceutical products in another country. Also, it helps to streamline the process by providing a summary of the technical data already reviewed and approved.

Pharmaceutical manufacturers and private label distributors who want to export their products to other countries are required to have CPP for their drugs.

Regulatory authorities in the importing countries may ask for CPP to ensure that the drug they are importing is following the regulations of the exporting country.

CPP contains the information about the product, such as its name, dosage form, and active ingredients, drug listing number, manufacturer information and the label image.

It contains a statement confirming the product’s marketing authorization status in the issuing country.

Benefits of getting CPP are getting faster registration process in other countries. Reduced costs for manufacturers by avoiding full re-evaluation of the product and improved access to essential medicines for patients in importing countries.

Liberty Management Group, a leading FDA consulting firm provides assistance with FDA drug establishment registration, drug listing and certificate to Pharmaceutical Product.

Sudha S

Regulatory Consultant

Email : office@libertymanagement.us

www.fdahelphttp://www.fdahelp.us.us

COSMETIC OR DRUG

The classification of a product as a cosmetic or a drug by the U.S. FDA depends on its intended use of the product and how it is marketed. The products are regulated differently based on the classification.

Cosmetic:

As per FDA, a cosmetic is defined as a product “intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering appearance without affecting the body’s structure or functions.” Examples include skin moisturizers, perfumes, body cleansers, haircare products, moisturizers, and other skincare products.

FDA has introduced a new regulation under Modernization of Cosmetics Regulation Act of 2022 (MoCRA) for registering the manufacturing facility with FDA and doing product listings.

Drug:

A drug is defined as a product “intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease” or “intended to affect the structure or any function of the body.” This includes over the counter (OTC) medications, prescription drugs, and even some products marketed as dietary supplements.

Drugs are subject to more stringent regulatory requirements, including pre-market approval processes. They must demonstrate safety and efficacy before being allowed on the market.

It’s important to note that the intended use of a product, as determined by its marketing claims, is a key factor in determining its regulatory classification. If a product is intended to cleanse, beautify, or enhance appearance without making drug claims, it is likely to be classified as a cosmetic. If the product claims to treat or prevent a specific condition or disease, it may be classified as a drug.

However, some products, known as “cosmeceuticals,” may have characteristics of both cosmetics and drugs. These products claim to have therapeutic benefits but are often marketed as cosmetics. The classification can sometimes be nuanced, and companies must carefully consider their product claims and formulations to ensure compliance with FDA regulations.

If a product is classified as drug, then it must comply with all applicable drug regulations including establishment registration, cGMP and drug listing.

Liberty Management Group, as a leading FDA regulatory consulting firm, can guide the companies to determine how the products are regulated and help them with the registration process.

Sudha S

Regulatory Consultant

Email : office@libertymanagement.us

www.fdahelp.us

FDA REGISTRATION RENEWAL TIMELINE

FDA registration renewal process is applicable to various FDA regulated products, including food facilities, medical devices, drugs, and more. However, specific renewal requirements and processes are needed based on the type of product or establishment.

Below are the timeline for FDA registration renewals.

Food Facilities: Food facilities must renew their FDA registrations every two years. The renewal period usually opens in October of even-numbered years. Registered food facilities need to submit a renewal registration between October 1st and December 31st of each even-numbered year.

Medical Devices: Owners or operators of establishments that manufacture, repackage, relabel, or remanufacture medical devices for commercial distribution must renew their registration annually with the FDA. This registration must be renewed between October 1st and December 31st each year and pay FDA fee.

Drug Establishments: Establishments involved in the manufacture, repackaging, relabeling, or salvaging of drugs must register with the FDA. Drug establishment registrations must be renewed annually between October 1st and December 31st every year.

Drug listings: All drug establishments must renew or certify their drugs listed in the previous fiscal years, between October 1st and December 31st every year. During this renewal period companies must inform FDA about any update or changes in their drug listings. If they no longer market the drugs, it must be de-listed with marketing end date.

Liberty Management Group , as a leading FDA consultant will provide assistance  with food registration biennial registration renewal, drug establishment registration renewal, medical device registration renewal and drug listing renewal.

Sudha S

Regulatory Consultant

Email: office@libertymanagement.us

www.fdahelp.us

BLANKET LISTING SUBMISSION

The FDA (U.S. Food and Drug Administration) requires drug manufacturers to submit a “blanket listing submission” for all drug products they manufacture. This listing includes information about the drug products and the facilities where they are manufactured.

A blanket listing submission is a process by which pharmaceutical companies provide the FDA with a comprehensive list of all drug products they manufacture. This includes prescription and over-the-counter drugs.

FDA uses this information to monitor and regulate drug products in the United States. It helps the FDA track the availability and safety of drug products, as well as identify manufacturing facilities and labeler codes associated with these products.

Drug manufacturers must submit/update listing every year between October 1st and December 31st even if no changes have occurred.

The submission typically includes detailed information about each drug product, such as its proprietary name, active ingredients, dosage form, route of administration, and National Drug Code (NDC) number. It also includes details about the manufacturing facilities and labeling information.

The FDA now requires electronic submission of these listings through the FDA’s Electronic Submissions Gateway (ESG) in Structured Product Labeling (SPL) format.

Failure to submit or update these listings as required can lead to regulatory action, which includes misbranding and warning letters.

Liberty Management Group Ltd, provides assistance with drugs establishment registration, NDC labeler code request, Drug listings and US agent service to foreign facilities.

Sudha S

Regulatory Consultant

office@libertymanagement.us

www.fdahelp.us

HOMEOPATHIC DRUG REGISTRATION

Homeopathic drugs are regulated differently from conventional drugs, and the regulatory framework has been shaped by the Food, Drug, and Cosmetic Act (FD&C Act) and the Homeopathic Pharmacopoeia of the United States (HPUS).

Homeopathic drugs are subject to the provisions of the FD&C Act, which outlines the legal requirements for safety, efficacy, and labeling of drugs. The FDA recognizes the HPUS as the official compendium for homeopathic drugs in the United States. The HPUS provides standards for the preparation, quality, and labeling of homeopathic products.

Homeopathic drugs must comply with certain labeling requirements, including disclosure of ingredients, indications, and proper dilution information. However, the labeling standards for homeopathic drugs may differ from those for conventional drugs.

Liberty Management Group Ltd, provides assistance with homeopathic drugs establishment registration, drug listings and US agent service to foreign facilities.

Sudha S

Regulatory Consultant

Email: office@libertymanagement.us

www.fdahelp.us

DRUG LISTING RENEWALS

Drug listing is an important regulatory requirement that helps the FDA track and monitor all drugs, including over the counter (OTC) drugs, prescription drugs, and other pharmaceutical products marketed in the United States. Drug listing renewals ensure that the FDA has accurate and up-to-date information about each drug product.

Here are the key points regarding FDA drug listing renewal:

  1. Annual Renewal: Drug listing information must be updated with the FDA annually. The renewal must be completed between October 1st and December 31st of each year for the following year .
  2. Electronic Submission: Drug listing renewal must be completed electronically through the FDA’s Electronic Submissions Gateway (ESG) or CDER direct.
  3. Information Updates: During the renewal process, drug manufacturers or sponsors are required to review and update the information related to their drug products, which includes information such as product formulation, labeling, manufacturer information, and establishment registration.
  4. Consequences of Non-Renewal: Failure to renew drug listings can have serious regulatory consequences. Any drug listing that is required to be certified but is not certified may be considered inactive and removed from the NDC Directory and other publications of listing data.
  5. NDC Assignment: The National Drug Code (NDC) is an essential part of drug listing. Manufacturers should ensure that the NDCs for their drug products are accurate and up to date while renewing their listings.

Liberty Management Group Ltd, provides assistance with drugs establishment registration, NDC labeler code request, Drug listing renewals and US agent service to foreign facilities.

Sudha S

Regulatory Consultant

Email : Office@libertymanagement.us

www.fdahelp.us

MEDICAL DEVICE LABELING REQUIREMENTS

US FDA regulates the labeling of medical devices to ensure the safety and effectiveness of these devices. Medical devices need to have proper labeling to provide healthcare professionals and patients with appropriate information about the devices intended use, risk, and direction of use.

Below are some of the main points in medical device labeling as per 21 CFR part 801.

  1. Labeling Requirements: The device labeling must include all written, printed, or graphic materials accompanying a device like the packaging, adequate direction for use, user manuals, and any promotional materials.
  2. Intended Use: Labeling must clearly indicate the intended use of the device which helps the healthcare professionals and patients understand its purpose and when it should be used.
  3. Unique Device Identification (UDI): Medical devices must have a unique device identifier (UDI) that allows for easy tracking and identification. The UDI system helps in product recalls, post-market surveillance, and overall device traceability.
  4. Risk Information: Labeling should include information about the device’s risks, contraindications, warnings, and precautions which is crucial for healthcare professionals and patients to understand potential adverse effects and how to mitigate them.
  5. Instructions for Use: Detailed instructions for using the device safely and effectively should be provided. These instructions may include information on device preparation, administration, maintenance, and cleaning.
  6. Storage and Handling: If specific storage conditions or handling instructions are necessary to maintain the device’s safety and effectiveness, these should be clearly outlined on the label.
  7. Language and Formatting: Labels and instructions should be in a language that is easily understood by the intended users. The formatting should be clear, legible, and user-friendly.
  8. Labeling Changes: Manufacturers must inform the FDA of any significant labeling changes to an approved medical device. These changes may require FDA review and approval.

It’s important for medical device manufacturers to follow FDA regulations to ensure the safety and effectiveness of their products. Failure to comply with labeling requirements can result in regulatory action, including product recalls and misbranding.

Manufacturers should also stay informed about any updates or changes in FDA regulations related to medical device labeling, as regulatory requirements may evolve over time.

Liberty Management Group, as leading FDA consulting firm provides assistance with FDA medical  establishment registration, device listing and medical device labeling.

Sudha S

Regulatory Consultant

Email : office@libertymanagement.us

www.fdahelp.us

OTC MONOGRAPH

An Over-the-Counter (OTC) monograph is a set of regulations established by the U.S. Food and Drug Administration (FDA) for non-prescription drugs. These monographs provide a comprehensive framework for the ingredients, labeling, and therapeutic uses of a specific category of OTC drugs. The monograph system streamlines the process for manufacturers to develop and market safe and effective OTC products without requiring approvals.

The FDA categorizes OTC drugs into various therapeutic classes (e.g., antacids, cough and cold products, pain relief, sunscreens) based on their intended use and active ingredients.

For each therapeutic class, the FDA develops a monograph that outlines the active ingredients, their permitted concentrations, labeling requirements, dosing instructions, and any other relevant specifications. The monograph serves as a standard for products within that category.

The monograph also specifies which active ingredients are generally recognized as safe and effective (GRASE) for treating specific conditions.

The monograph sets labeling requirements, with drug facts which includes use, warnings, and other information that must be included on the product’s packaging. It may also outline testing requirements to ensure product quality and consistency.

Manufacturers looking to create an OTC product within a specific therapeutic class must formulate their product according to the monograph’s specifications. If the product adheres to the monograph’s requirements, it can be marketed without requiring individual FDA approval.

The FDA periodically reviews and updates OTC monographs to reflect new scientific information, safety concerns, and changes in industry standards. Manufacturers are required to adjust their products to comply with updated monograph requirements.

In some cases where a manufacturer wishes to market an OTC product with an ingredient or use that is not covered by an existing monograph, they can pursue an OTC New Drug Application (NDA) or a New Dietary Ingredient (NDI) Notification, depending on the nature of the product.

It’s important for manufacturers to carefully follow the monograph guidelines when developing and marketing OTC drugs to ensure compliance with FDA regulations.

OTC drug manufacturers are required to comply with FDA drug regulations which includes establishment registration, drug listing, label compliance and cGMP regulations.

Liberty Management Group , as a leading FDA consultant with provide assistance  with drug establishment registration, drug listing and label review.

Sudha S

Regulatory Consultant

Email : Office@libertymanagement.us

www.fdahelp.us

MEDICAL DEVICES PRODUCT CLASSIFICATION

Medical devices are categorized into different classes based on their risk level and intended use. These classifications of U.S. Food and Drug Administration (FDA) to ensure the safety and effectiveness of these devices. Below are the classification of medical devices by FDA.

Class I: Low Risk

  1. These are considered low-risk devices, typically involving minimal potential harm to the user.
  2. Examples include elastic bandages, examination gloves, and most manual surgical instruments.
  3. General controls are sufficientto provide reasonable assurance of safety and effectiveness.

Class II: Moderate Risk

  1. These devices have a higher level of risk than Class I devices and require greater regulatory controls.
  2. Examples include syringes, infusion pumps, and some diagnostic tests.
  3. Special controls, such as performance standards, post-market surveillance, and patient registries, may be necessary to ensure safety and effectiveness.

Class III: High Risk

  1. Class III devices pose the highest level of risk to patients and usually support or sustain human life, are implanted, or present potential unreasonable risk of illness or injury.
  2. Examples include implantable pacemakers, heart valves, and automated external defibrillators.
  3. These devices require pre-market approval (PMA) applications to demonstrate their safety and efficacy.

Before marketing a medical device, manufacturers must ensure they comply with the relevant regulatory requirements for the intended market. This might involve submitting various documentation, conducting testing, and obtaining the appropriate approvals or clearances from regulatory agencies.

Liberty Management Group, a leading FDA consulting group in the United States provides assistance with classification of devices and establishment registration, device listing, medical device label review, UDI listings and US agent service for foreign drug establishment firms.

Sudha S

Regulatory Consultant

Email: office@libertymanagement.us

www.fdahelp.us

GUDID (GLOBAL UNIQUE DEVICE IDENTIFICATION DATABASE)

GUDID stands for the Global Unique Device Identification Database. It is a publicly accessible database maintained by the U.S. FDA. The GUDID contains information about medical devices that are labeled with a Unique Device Identifier (UDI).

The UDI system was established by the FDA to improve the identification and tracking of medical devices throughout their lifecycle, from manufacturing to distribution to patient use. The UDI consists of a unique numeric or alphanumeric code that is encoded in both human-readable form and machine-readable form (usually in a barcode or RFID tag).

Manufacturers of medical devices are required to submit information about their devices, including the UDI, to the GUDID. This information typically includes details about the device’s manufacturer, brand name, model number, expiration date, and other relevant attributes. The GUDID serves as a central repository of this information, allowing healthcare providers, regulators, and the public to access accurate and up-to-date information about medical devices.

The GUDID plays a crucial role in enhancing patient safety, facilitating device recalls, improving supply chain management, and supporting post-market surveillance of medical devices. It provides a standardized and comprehensive database that enables better traceability and identification of medical devices, contributing to the overall quality and safety of healthcare.

Liberty Management Group, a leading FDA consulting group in the United States, provides assistance with UDI account creation, selection of Accrediting agency, GUDID submission.

Sudha S

Regulatory Consultant

Office@libertymanagement.us

www.fdahelp.us