#FDA Tag

The Food and Drug Administration (FDA) has published draft guidance entitled “Medical Gases—Current Good Manufacturing Practice” to help manufacturers of medical gases comply with tailored current Good Manufacturing Practices (cGMP) requirements (codified in 21 CFR part 213), that become effective on December 18, 2025.

The conforming amendments to the cGMP requirements for combination products will take effect on February 2, 2026.

This new draft guidance amends and replaces the draft guideline entitled “Current Good Manufacturing Practices for Medical Gases” published in June 2017, and has been drafted to reflect new and revised regulations in various areas, with the aim of reducing, as appropriate, the regulatory burden for the medical gas industry.

Unlike standard pharmaceuticals, medical gases have unique production, storage, and distribution characteristics (e.g. sealed pressurised systems, reusable cylinders, and no typical ‘expiration’ concerns).

These regulations contain the minimum requirements to ensure that manufacturing processes operate according to acceptable quality standards, but are more specifically tailored to the methods of manufacturing, packaging, labeling, storage, and distribution of medical gases.

In addition to aligning with the unique nature of medical gases, the updated regulations include certification and labeling requirements (e.g., warnings statements on oxygen containers) and modified safety reporting provisions.

Comments on the draft guidance may be submitted in electronic or paper format by January 30, 2026.

 

 

SOURCES:

https://www.fda.gov/regulatory-information/search-fda-guidance-documents/medical-gases-current-good-manufacturing-practice

On October 29, 2025, the FDA published new draft guidance titled “Scientific Considerations in Demonstrating Biosimilarity to a Reference Product: Updated Recommendations for Assessing the Need for Comparative Efficacy Studies.” The draft guidance includes the recommendations of the FDA in cases where sponsors should consider a simplified approach to biosimilar development and therefore waive conducting a clinical efficacy study to support of a biosimilar application.

This draft guidance highlights recommendations for demonstrating biosimilarity to a reference product, pointing out that following comparative analytical testing, pharmacokinetic (PK) and pharmacodynamic (PD) testing, and in the presence of a clinical immunogenicity assessment demonstrating a high degree of similarity and the absence of clinically significant differences between the proposed product and the reference product, Comparative Efficacy Studies (CES) are not necessary.

The FDA advises considering a simplified approach when:

  • the reference product and proposed biosimilar product are manufactured from clonal cell lines, are highly purified, and can be well-characterized analytically;
  • the relationship between quality attributes and clinical efficacy is generally understood for the reference product, and these attributes can be evaluated by assays included in the CAA;
  • a human pharmacokinetic similarity study is feasible and clinically relevant.

Comparative efficacy studies are therefore only needed to resolve cases of “residual uncertainty” or for products for which clinical endpoints or PK data are not feasible or clinically relevant.

The new draft guidance indicates that the agency now considers comparative clinical efficacy studies to be the exception rather than the rule for biosimilar development programs, at least for therapeutic protein products.

SOURCES:

https://www.fda.gov/regulatory-information/search-fda-guidance-documents/scientific-considerations-demonstrating-biosimilarity-reference-product-updated-recommendations

 

In January 2025, the US FDA has published in the newsroom of the CDER website the article titled “Determining Recommended Acceptable Intake Limits for N-nitrosamine Impurities in Pharmaceuticals: Development and Application of the Carcinogenic Potency Categorization Approach”.

The article recaps the historical context of the development of the Carcinogenic Potency Categorization Approach (CPCA) methodology, that uses the chemical structure of a nitrosamine impurity to recommend acceptable intake (AI) limits, assigning them to one of five predicted potency categories reflecting carcinogenic risk, and provides an analysis of the the number and distribution of α-hydrogens combined with other activating and deactivating features of nitrosamines.

The complete article can be checked in the newsroom of CDER’s website.

 

SOURCES:

Determining Recommended Acceptable Intake Limits for N-nitrosamine Impurities in Pharmaceuticals: Development and Application of the Carcinogenic Potency Categorization Approach | FDA

In January 2025, the U.S. Food and Drug Administration (FDA) published a draft Guidance for Industry and Other Interested Parties entitled “Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products”.

Public comments on this draft document can be submitted until 7 April 2025 to ensure they are considered in the final development of the Guidance.

This Guidance provides recommendations to sponsors and other interested parties on the use of artificial intelligence (AI) to produce information or data intended to support regulatory decisions regarding the safety, effectiveness or quality for drugs or combination products that include a drug.

The recommendations also may be relevant  across all medical products, including medical devices intended to be used with drugs.

A key element of this guidance is the introduction of a risk-based approach to establish and assess the credibility of AI models for a specific context of use (COU).

The COU defines the specific role and scope of the AI model used to address a question of interest.

The guideline highlights the importance of clarity in defining the context of use through the collection of credibility evidence for each AI model, as this provides the basis for the evaluation of the AI model outputs.

 

A Risk-Based Credibility Assessment Framework

The risk-based credibility assessment framework described in the Guidance  comprises seven step process to establish and assess the credibility of an AI model output for a specific COU:

  • Step 1: Define the question of interest that will be addressed by the AI model.
  • Step 2: Define the COU for the AI model.
  • Step 3: Assess the AI model risk.
  • Step 4: Develop a plan to establish the credibility of AI model output within the COU.
  • Step 5: Execute the plan.
  • Step 6: Document the results of the credibility assessment plan and discuss deviations from the plan.
  • Step 7: Determine the adequacy of the AI model for the COU.

 

Special Consideration: Life Cycle Maintenance of the Credibility of AI Model Outputs in Certain Contexts of Use

The Guide underlines the importance of ongoing monitoring and maintenance of AI models to ensure that they remain suitable for use over the life cycle of the medical product for its Contexts of Use. This includes regular monitoring of model performance and documenting of any changes that could affect model outputs.

 

SOURCE:

Guidance for Industry and Other Interested Parties ‘Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products’

The draft document “Data Integrity for In Vivo Bioavailability and Bioequivalence Studies” was published on the US FDA website at the beginning of April 2024. The document aims to assist applicants and marketing authorisation holders on achieving and maintaining data integrity for the clinical and bioanalytical part of bioavailability (BA) and bioequivalence (BE) studies for INDs (investigational new drug applications) submission, NDAs (new drug applications), ANDAs (abbreviated new drug applications), for the bioanalytical part of the clinical studies of BLAs (biologic licence applications) as well as for supplements and amendments to these marketing authorisations.

In addition, the recommendations in this guidance apply to the bioanalytical portion of nonclinical studies. The FDA also encourages applicants and testing sites to take these recommendations into consideration when conducting in vitro, pharmacology and toxicology studies.

 

SOURCES:

https://www.fda.gov/media/177404/download

The draft guidance document “Handling and Retention of Bioavailability and Bioequivalence Testing Samples” is being distributed at March 2024

The guidance is intended to provide recommendations for study sponsors and/or drug manufacturers, contract research organizations (CROs), site management organizations (SMOs), clinical investigators, and independent third parties regarding the procedure for handling reserve samples from relevant bioavailability (BA) and bioequivalence (BE) studies, as required by 21 CFR 320.38 and 320.63.

The guidance highlights

  1. how the test article and reference standard for BA and BE studies should be distributed to the testing facilities,
  2. how testing facilities should randomly select samples for testing and material to maintain as reserve samples,
  3. how the reserve samples should be retained
  4. addresses the requirement at 21 CFR 320.38 (c) to retain sufficient quantity of reserve samples to allow FDA to perform five times all the release tests required in an application or supplemental application
  5. describes the conditions under which the Agency does not generally intend to take enforcement action against an applicant or CRO for retaining less than the quantity of reserve samples of the test article and reference standard that were used in the BA or BE study as specified in 21 CFR 320.38(c)

The guidance also clarifies the points addressed in §§ 320.38 and 320.63.

 

SOURCES:

https://www.fda.gov/media/71393/download

  • FDA has published the draft guidance “Conducting Remote Regulatory Assessments Questions and Answers Draft Guidance for Industry” to describe the Agency’s current thinking on the use of remote regulatory assessments (RRAs). FDA has used RRAs to conduct surveillance, reduce risk, meet critical public health needs, and help maximize compliance of FDA-regulated products. This draft guidance provides answers to frequently asked questions about what RRAs are, when and why FDA may use them, and how FDA may conduct them, among others.

    The term “RRA”, as defined in the Question and Answers section, include activities for which the FDA may use different terminologies, such as “remote interactive evaluations” and “remote record reviews“. RRAs were mainly used to support submissions or applications assessments of FDA-regulated products and to reduce delays.

    In the presence of travel restrictions during the COVID-19 pandemic, FDA utilized RRAs to assess establishments and their compliance with applicable FDA requirements.

    Based on this experience, FDA has noted the value of RRAs and concluded that, under certain circumstances, they should be retained for some scenarios outside the COVID-19 pandemic for all types of FDA-regulated products.

    The Agency is also issuing this guidance to promote greater consistency in the way RRAs are conducted, explaining the processes for responding to an RRA request and outlining the factors to consider in assessing whether an establishment has responded timely and appropriately to a mandatory request.

    SOURCES:

    https://www.fda.gov/media/160173/download

The U.S. Food and Drug Administration (FDA) has organized a stakeholder call to discuss the DSCSA implementation, which took place on 29 November 2023.

The Drug Supply Chain Security Act (DSCSA) drug supply chain security requirements, ten years after its implementation, are intended to improve the FDA’s ability to detect and remove potentially dangerous drugs, whether: counterfeit, stolen, contaminated or otherwise, from the supply chain.

Among the topics covered:

  • 10-year anniversary of DSCSA implementation
  • Stabilization period and expectations for trading partners to achieve interoperable, electronic tracing of products at the package level
  • Recent key guidances for industry related to supply chain security requirements
  • Looking ahead

Also in late November, the FDA announced that the CDER NextGen Portal (CDER NextGen) includes a DSCSA portal that enables the FDA and trading partners to communicate when the FDA requests information related to investigations of suspect or illegitimate products or during a recall.

The DSCA portal is used to:

  • Confirm basic information and points of contact for trading partners
  • Notify trading partners when they have messages from the FDA
  • Enable trading partners to respond to FDA messages and upload documents

Additionally, the DSCSA enables to:

After the FDA had already published an initial discussion paper addressing Artificial Intelligence (AI) in the manufacturing of medicinal products, in early 2023, the EMA issued a draft reflection paper outlining the current thinking on the use of artificial intelligence (AI) to support the safe and effective development, regulation and use of human and veterinary medicines, on 19 July 2023.

This paper reflects on principles relevant to the application of AI and machine learning (ML) at any step of a medicines’ lifecycle, from drug discovery to the post-authorisation setting and reports the experience of the EMA in this context, in which scientific knowledge is rapidly evolving.

Recently the success of ChatGPT and related reporting have made the topic of Artificial Intelligence accessible to a wide audience.

 

General considerations

In general, it is mentioned that AI and ML, if used correctly, can effectively support the acquisition, transformation, analysis and interpretation of data within the medicinal products lifecycle.

A risk-based approach to the development, implementation and performance monitoring of AI and ML tools should enable developers to proactively define the risks to be managed during the life cycle of AI and ML tools.

AI and ML tools, when used properly, can effectively support the acquisition, transformation, analysis and interpretation of data within the medicinal product lifecycle. Section 5 of the document lists some guidelines and documents that may provide useful recommendations for implementing AI/ML applications.

It is essential to highlight that the marketing authorisation applicant or MAH is responsible for ensuring that the algorithms, models, datasets, etc. used are fit for purpose and meet ethical, technical, scientific and regulatory standards.

 

Content of the document

The document addresses the following topics:

  • AI in the lifecycle of medicinal products
    • Drug discovery
    • Non-clinical development
    • Clinical trials
    • Precision medicine
    • Product information
    • Manufacturing
    • Post-authorisation phase
  • Regulatory interactions
  • Technical aspects
    • Data acquisition and augmentation
    • Training, validation, and test data
    • Model development
    • Performance assessment
    • Interpretability and explainability
    • Model deployment
  • Governance
  • Data protection
  • Integrity aspects
  • Ethical aspects and trustworthy AI

 

Conclusion

The quickly developing field of AI and ML shows great promise for enhancing all phases of the medicinal product lifecycle.

Finally, the use of AI in the lifecycle of medicines should always comply with existing legal requirements, considering ethics and its underlying principles, and with due respect for fundamental rights. A human-centred approach should be adopted in the development and use of AI and ML.

SOURCES:

The Mutual Recognition Agreement (MRA) between Switzerland and the United States in Good Manufacturing Practice (GMP) for medicinal products has entered into force from 27 July 2023.

This agreement in principle establishes a mechanism whereby each country recognises GMP inspections carried out by the regulatory authority of the other, i.e. Swissmedic for Switzerland and the Food and Drug Administration (FDA) for the United States.

Both authorities are thus able to mutually use GMP inspections and their results in order to avoid duplicate inspections.

A significant aspect of this MRA is that it is not only limited to human medicines, but also includes veterinary medicines

In addition to the FDA and Swissmedic, the Office of the U.S. Trade Representative and the State Secretariat for Economic Affairs of Switzerland had also signed the agreement. These institutions play an important role in facilitating negotiations and cooperation between the two nations to ensure the proper implementation of the agreement.

The Mutual Recognition Agreement is based on the Food and Drug Administration Safety and Innovation Act, enacted in 2012, which allows the FDA to enter into agreements with other regulatory authorities to recognise inspections performed by them. This regulatory environment has created a favourable environment for international collaboration and mutual exchange of information.

SOURCES:

https://www.swissmedic.ch/swissmedic/en/home/news/mitteilungen/inkrafttreten-mra-swissmedic-fda.html