Question & AnswerQ&A (FDA CIRCULAR NO. 2011-002)
Pharmaceutical companies are required to submit a Certified True Copy of valid Certificate of Product Registration (CPR), the previously approved insert, clinical data justifying the changes or revisions, and a tabulated list of proposed changes with sections of the application tagged and labeled.
Applications that include any indication not previously approved by the FDA shall be subject to appropriate FDA sanctions as deemed applicable.
Indications approved by the FDA should be stated exactly as worded in the application submitted for the indication.
Three (3) clinical studies must be submitted to justify changes made, particularly those related to new dosages and new routes of administration.
Any changes in the Core Data Sheet or Basic Succinct Statements must be previously approved by the FDA before any product insert revision is undertaken.
Companies are required to submit three (3) copies of the approved product insert within 30 days of receipt of the approval letter.
Companies may apply to revise or update the package insert or labels, patient leaflet information, prescribing information, Core Data Sheet (CCDS), and basic succinct statement.
Sections of the application must be tagged and labeled to clearly identify proposed changes.
Ensuring submissions and supporting documents are in order is important for strict compliance and to avoid sanctions or delays in approval processes by the FDA.