Format and Content for the CMC Section of an Annual Report

Administrative guidance, not enacted legislation. This captured publisher edition preserves the listed document and attachments; later developments are not independently consolidated.

Guidance for Industry
Format and Content for the
CMC Section of an Annual
Report
Center for Drug Evaluation and Research (CDER)
September 1994

This guidance has been prepared under the auspices of the Chemistry Manufacturing Controls
1
Coordinating Committee (CMC CC) of the Center for Drug Evaluation and Research at the Food and
Drug Administration. Although this guidance does not create or confer any rights for or on any person
and does not operate to bind FDA or the industry, it does represent the agency’s current thinking on the
submission of chemistry, manufacturing, and controls information in an annual report. For additional
copies of this guidance, contact the Division of Communications Management, HFD-210, CDER, FDA,
5600 Fishers Lane, Rockville, MD 20857 (Phone: 301-594-1012). Send one self-addressed adhesive
label to assist the offices in processing your request. An electronic version of this guidance is also
available via Internet using FTP, Gopher or the World Wide Web (WWW). For FTP, connect to the
CDER anonymous FTP server at CDVS2.CDER.FDA.GOV and change to the “guidance” directory. For
Gopher, connect to the CDER Gopher server at GOPHER.CDER.FDA.GOV and select the “Industry
Guidance” menu option. For WWW, connect to the FDA Home Page at WWW.FDA.GOV/CDER.
GUIDANCE FOR INDUSTRY1
FORMAT AND CONTENT
FOR THE CMC SECTION OF AN ANNUAL REPORT
I. PURPOSE
To describe the information requested by the Center for Drug Evaluation and Research
(CDER) in an Annual Report to a New Drug Application (NDA), Abbreviated New Drug
Application (ANDA), or Abbreviated Antibiotic Application (AADA) submitted pursuant
to 21 CFR 314.81(b)(2).
The primary objective is to ensure consistency and completeness of information in the
Annual Reports submitted by the pharmaceutical industry and to standardize the
general format.
II. BACKGROUND
The FDA regulations for the submission of Annual Reports are described in 21 CFR
314.70(d) and 21 CFR 314.81(b)(2). In the past, the reports submitted under these
regulations have exhibited wide variability from firm to firm, and at times the information
submitted has been inconclusive or insufficient.
This guidance addresses information that should be included in an Annual Report. It
may also be helpful to consult other Center guidances for information on the depth of
technical information requested. For example, CDER's Guideline for Submitting
Documentation for the Stability of Human Drugs and Biologics provides information on
the design of stability protocols, the amount of stability data that should be provided to
support specific changes to the application (e.g., packaging changes submitted under

314.70(d)(6)), and guidance on the extension of the expiration dating period. Complete
information submitted in an easy to follow format will assist the reviewer in conducting
an efficient review.
CDER encourages the applicant to contact the appropriate office or division if there is
uncertainty whether the information should be submitted in an annual report or as a
supplemental change to the approved application.
III. POLICY
The NDA/ANDA/AADA holder should follow the procedure outlined in Form FDA 2252
when filing an Annual Report. Annual Reports should be filed for all approved NDA's,
ANDA's and AADA's (including those for bulk antibiotic drugs), regardless of their
activity status. For NDA's filed with the Offices of Drug Evaluation I or II, applicants
should submit sufficient copies of the Annual Report for the jacket of each affected
discipline so as to assure concurrent review.
The applicant should follow the format described below and include all information
when preparing an Annual Report. If no changes were made in a particular section
during the reporting period, the applicant should state "No changes were made during
the reporting period." Please note that even though the format described below may
not be entirely complete, the firm remains responsible for complying with all
requirements under current regulations.
IV. FORMAT
SECTION I. SUMMARY OF NEW INFORMATION
The firm should include a brief summary of all changes made to the application during
the reporting period, including changes made in accordance with approved
supplements under 21 CFR 314.70(b) and special supplements under 21 CFR
314.70(c). All changes should be highlighted or annotated within the Annual Report
and should be included in the list of approved chemistry, manufacturing and control
information described in Section IV of this document.
SECTION II. DISTRIBUTION DATA [21 CFR 314.81(b)(2)(ii)]
The firm should provide:
A. The quantity distributed of each currently approved strength by package
size (e.g. number of 30's, 100's for drug products or kg for bulk antibiotic
drugs), or

B. The statement "None distributed" along with the corresponding approved
package size(s) if there is no distribution for that package size.
C. Quantities distributed for domestic use and quantities distributed for
foreign use.
D. For bulk antibiotic drug AADA's, a current list of all persons authorized to
reference the application and any person whose authorization has been
withdrawn.
Distribution information should be distributor-specific.
SECTION III. LABELING [21 CFR 314.70(d), 21 CFR
314.81(b)(2)]
Generally, any labeling change submitted in an Annual Report should include
supportive documentation (e.g. submission of a statement of the currently approved
composition to support upgrading insert labeling to include previously unlisted inactive
ingredients).
Information submitted under 21 CFR 314.81(b)(2)(iii), should include the following:
A. All currently used labeling, including a representative sample of package
labels. This should include all package inserts and examples of the
immediate container labels. It may be useful to include labels of
distributors. Samples of all labeling which has undergone a change
during the reporting period, including immediate container labels, carton
labeling, and insert labeling, should be provided in the Annual Report.
B. A summary of any changes made in the labels/labeling since the last
Annual Report, listed chronologically by implementation date.
SECTION IV. CHEMISTRY MANUFACTURING AND CONTROLS CHANGES
CDER requests that a current list of approved chemistry, manufacturing and control
information be provided yearly in the Annual Report to better document the changes
occurring in applications. This index is not for review purposes, but will serve as a
reviewer aid. The list should include all information shown in Attachment 1 and the use
of the format in the attachment is encouraged. The information should include the
type and date of each change to each component, the type of submission used to
report the change (Original, Supplemental or Annual Report), and the date the change
was reported and approved, if it was.

Regulatory specifications and analytical methods for the drug substance and drug
product should be listed individually as illustrated below:
III. SPECIFICATIONS AND METHODS FOR THE DRUG SUBSTANCE
Test Specification Method (#, Reference)
Description Clear, Colorless Visual (CZT2001,
Liquid Original[2-3-86])
Assay 98 - 102% HPLC (CZT2019,
S-003[4-11-81])
* * *
Examples of chemistry, manufacturing and controls changes that should be reported
include but should not be limited to the following information:
A. Compendial Changes [21 CFR 314.70(d)(1)]
Changes made to comply with changes in an official compendium should
include:
(1) Full description of changes in test methods and limits.
(2) Data demonstrating the suitability of the compendial change for the
drug product.
B. Formulation [21 CFR 314.70(d)(4)]
Deletion of an ingredient intended only to affect the color of the drug
product should be reported and include:
(1) A comparative component and composition statement, with all
changes highlighted or annotated.
(2) A statement of the current component and composition in
subsequent Annual Reports, including reference to the change (i.e.
date, Annual Report Number, or Supplement Number).

(3) Revised labeling as required by 21 CFR 314.70(d)(2) reflecting the
change in formulation.
C. Expiration Period [21 CFR 314.70(d)(5)]
Extension of the expiration dating period should be accompanied by full
shelf-life stability data for the proposed expiry dating on a minimum of
three production lots and a justification for the change in the expiration
date. The data should be obtained using the stability protocol approved
in your application.
D. Container/Closure [21 CFR 314.70(d)(6)]
Changes within the approved container and closure system for a solid
oral dosage form may be included in the annual report (e.g., one HDPE to
another HDPE). The description of this change should be accompanied
by the following information:
(1) Components and manufacturer. Letters of authorization allowing
reference to other documents (e.g., DMFs) should be included if
appropriate.
(2) Testing results that demonstrate the equivalency of the changed
container and closure system to the original system in accordance
with compendial requirements or a protocol approved in the
application.
(3) A Statement of Commitment to place the drug product using the
changed container and closure system in stability studies using the
approved stability protocol.
E. Test Methods [21 CFR 314.70(d)(7)]
The applicant should submit the following information for the addition or
deletion of an alternate method:
(1) A brief statement explaining the reason for the deletion.
(2) Data demonstrating the suitability and validation of the new
alternate method compared to the reference method. The data
should demonstrate the alternate method is equivalent or superior
to the current regulatory method.

F. Container/Closure [21 CFR 314.70(d)(8)]
A change in the size of a container for a solid oral dosage form, without a
change from one container and closure system to another, should be
consistent with the Center for Drug Evaluation and Research Guideline
for Submitting Documentation for the Stability of Human Drugs and
Biologics.
G. Status Report [21 CFR 314.81(b)(2)(vii)]
CDER strongly recommends that the stability report format for the Annual
Report include the following information along with the data accumulated
from your ongoing stability studies:

STABILITY REPORT
NAME/STRENGTH: BATCH #/STUDY #: BATCH/SIZE:
DATE MANUFACTURED: MANUFACTURING SITE: CONTAINER SIZE/SUPPLIER:
DATE PACKAGED: PACKAGER/SITE: CONTAINER RESIN:
DATE STUDY STARTED: PURPOSE OF STUDY: CLOSURE/SUPPLIER:
DATE OF EXPIRY: STORAGE CONDITIONS SEAL/SUPPLIER:
(INCLUDE ORIENTATION):
DRUG SUBSTANCE
MANUFACTURER/SITE/LOT#:
FILLER:
ATTRIBUTES METHODS SPECIFICATIONS TIME (MONTHS)
SOP# (LOW/HIGH)
0 3 6 9 12 18 ...
APPEARANCE
ASSAY
PURITY
DEG PROD A
DEG PROD B
DEG PROD C
pH
ETC...
ACTUAL TEST xxxxxxxxx xxxxxxxxxxxxxxx
DATES
The actual date that the sample(s)were tested should be included in the bottom
row of the table.
If there was no product distribution during the reporting period, the firm should
state the status of the ongoing stability program as stated in the approved
protocol.

Approved by CMC CC:
__________________________ __________________________
Charles Kumkumian, Ph.D. Roger L. Williams, M.D.

ATTACHMENT 1
NDA/ANDA/AADA ######
INDEX OF APPROVED CHEMISTRY, MANUFACTURING AND CONTROLS
INFORMATION
SUBMISSION APPROVAL
TYPE DATE DATE
I. DRUG SUBSTANCE
A. Manufacturer(s) ________
B. Method(s) of Manufacture ________
C. Container and Closure ________
D. Stability Protocol ________
E. Specifications and Analytical Methods *
II. DRUG PRODUCT
A. Composition ________
B. Manufacturer(s) ________
C. Method(s) of Manufacture and Packaging ________
D. Specifications and Analytical Methods *
E. Container(s) and Closure(s) ________
F. Expiration Dating Period Months ________
G. Stability Protocol ________
Please attach a complete listing of the Specifications and Analytical	*
Methods for the drug substance and drug product in the format provided.

III. SPECIFICATIONS AND METHODS FOR THE DRUG SUBSTANCE
TEST SPECIFICATION METHOD ( #, Reference)
IV. RELEASE SPECIFICATIONS AND METHODS FOR THE DRUG PRODUCT
TEST SPECIFICATION METHOD ( #, Reference)