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What Is an Abbreviated New Drug Application (ANDA)?

What Is an Abbreviated New Drug Application (ANDA)?

Abbreviated New Drug Application (ANDA) Definition

An Abbreviated New Drug Application (ANDA) is a regulatory submission to the US Food and Drug Administration (FDA) for generic drugs. An ANDA must provide information that demonstrates a proposed generic drug is the same as an already approved reference listed drug (RLD) in terms of safety, efficacy, and quality.

This information includes details about the active ingredients, conditions of use, method of administration, form (e.g. tablet, capsule), potency, and labeling of the drug, as well as evidence of the drug’s bioavailability, which is a crucial factor in demonstrating bioequivalence between a generic drug and its reference listed drug (RLD). The FDA requires that generic drugs have comparable bioavailability to the RLD in order to be approved and sold in the market.

However, the application may include certain differences from an RLD, such as changes granted through a suitability petition or other acceptable variations, as long as clinical trials are not required to demonstrate the safety or efficacy of the drug product being proposed in the ANDA. Differences include things like inactive components, labeling, or container closure systems.

It is important to note that an ANDA cannot be submitted if clinical trials are necessary to establish the safety and effectiveness of the proposed drug product. In such cases, the drug product must undergo additional testing and evaluation before an ANDA can be submitted to the FDA.

Historically, the Drug Price Competition and Patent Term Restoration Act of 1984, commonly known as the Hatch-Waxman Act, established the ANDA process to streamline the approval of generic drugs, adding sections 505(b)(2) and 505(j) to the Federal Food, Drug, and Cosmetic Act, or FD&C Act.

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The act aimed to increase competition and reduce the cost of prescription drugs by allowing generic drug manufacturers to skip some of the more expensive clinical trials required for new medicines as long as the generic drug is considered equivalent to an already approved drug.

This has increased the availability of lower-cost generic drugs, which has played a significant role in making prescription drugs more affordable for millions of people, and reflects Congress’s efforts to strike a balance between expanding access to generic drugs and providing new incentives for drug development through exclusivities and patent term extensions.

As a result, the FD&C Act now outlines two distinct pathways for drug approval : New Drug Applications (NDAs) and Abbreviated New Drug Applications.

ANDAs can be divided into two categories:

  1. ANDA Application: This application is submitted and approved under section 505(j) of the FD&C Act for a drug identical to a previously approved drug. The ANDA relies on the FDA’s previous determination that the reference listed drug (RLD) is safe and effective.
  2. Petitioned ANDA: This type of ANDA is for a drug that differs from the RLD in terms of its dosage form, route of administration, strength, or active ingredient. In this case, the FDA has determined, in response to a petition submitted under section 505(j)(2)(C) of the FD&C Act, that additional studies are not necessary to establish the safety and effectiveness of the proposed drug. A petitioned ANDA is expected to have the same therapeutic effect as the reference listed drug.

NDAs can also be classified into two types:

  1. Stand-alone NDA: This application is submitted under section 505(b)(1) of the FD&C Act, which contains complete reports of investigations into the safety and effectiveness of the drug. These investigations were conducted by the applicant or for which the applicant has a right to reference or use.
  2. 505(b)(2) Application: This type of NDA is submitted under section 505(b)(1) of the FD&C Act and includes complete reports of investigations into the safety and effectiveness of the drug. In this case, some of the information required for approval may come from studies that were not conducted by or for the applicant. Furthermore, the applicant might need to have a right to reference or use the studies.

How Do You Submit an ANDA?

The steps involved in submitting an Abbreviated New Drug Application (ANDA) for FDA approval include the following:

  1. Pre-ANDA Preparation: In this step, the sponsor should gather information on the reference listed drug, including its chemical and pharmacological properties, formulation, labeling, and regulatory history. This information determines if the generic drug is the same as the reference-listed drug.
  2. Preparation of the ANDA: The sponsor then prepares the ANDA, which includes data on the chemical, pharmacological, and clinical properties of the generic drug. This information demonstrates the generic drug’s similar to the reference listed drug. The ANDA also includes information on the manufacturing process, quality control, and proposed labeling.
  3. Submission of the ANDA: Once the ANDA is complete, the sponsor submits it to the FDA’s Center for Drug Evaluation and Research (CDER). You must submit the ANDA electronically through the FDA’s electronic submissions gateway.
  4. FDA Review: The FDA reviews the ANDA to determine if it meets the regulatory requirements for approval. The review process typically takes around 30 months, although the FDA can expedite the review of drugs that treat severe conditions or address unmet medical needs.
  5. FDA Decision: Once the review is complete, the FDA either approves or denies the ANDA. If approved, the sponsor can start selling the generic drug.

The time required for each step of the ANDA process can vary depending on the complexity of the drug and the availability of information. Pre-ANDA and ANDA preparation can take several months to a year, while the FDA review process typically takes around 30 months.

Furthermore, the time between submission and decision can vary depending on the type of drug and the FDA’s workload.

How to Determine Whether to Submit an ANDA or 505(b)(2) Application

The decision to submit an ANDA or a 505(b)(2) application depends on several factors, including the type of product under development (its specific characteristics) and the availability of existing information about the product.

As stated, a sponsor submits an ANDA to the FDA for evaluation, which leads to the approval or rejection of a generic drug that is similar to a brand-name drug that has been approved already. The approval is based on the safety and efficacy data of the previously approved drug, only requiring supplementary data to prove its equivalence to the benchmark product.

On the other hand, a 505(b)(2) application is used for the approval of new drug products that are not identical to a previously approved drug but rely on information from a previously approved drug for some, but not all, of the required safety and efficacy data. A 505(b)(2) application may be appropriate for developing new drug products with a different formulation, dosing regimen, or route of administration than an already approved drug.

A thorough evaluation of the drug product and its development history is necessary to determine the appropriate regulatory pathway.

Resources for ANDA Submissions

If you’re interested in submitting an ANDA, there are a number of resources available that help with your ANDA application and submission. They can help ensure that ANDA submissions are complete, accurate, and meet all regulatory requirements.

ANDA Forms & Submissions Requirements

One of the most extensive resources for ANDA submissions is the FDA’s ANDA Forms & Submission Requirements page. It provides information on the ANDA process and the forms required for submission to the FDA.

The submission requirements for ANDA include various forms, including cover letter, application form, labeling, and scientific information. The page on the agency’s website acts like a directory that you can use to access documentation or resources that provide guidance for the ANDA process and submission requirements.

Guidance Documents for ANDA Submissions

One major resource is the FDA’s guidance documents search page, found on its website. This search engine makes it easier for individuals and drug companies to find the exact guidelines they’re interested in.

Each document provides specific information and regulatory guidance for the various drug approval applications the FDA reviews. They are an essential resource for anyone who is preparing an ANDA submission and wants to understand the statutory and regulatory requirements.

Additionally, you can search for specific guidance documents for ANDA submissions by searching via the Generic Drugs Guidance page, using the search term “Generics” or “Biopharmaceutics” under topics; and you can search via the Product-Specific Guidances for Generic Drug Development page.

You can review the Good ANDA Submission Practices Guidance for Industry page or the Good Guidance Practices regulation PDF to learn more about good practices for application preparation and submission.

There is guidance information regarding amendments to ANDAs Under the Generic Drug User Fee Amendments (GDUFA) as well, which explains to sponsors the application of the review goals established by the GDUFA Reauthorization of 2017 (known as GDUFA II) and covers amendment classifications and categories and their impact on application review goal dates.

Additionally, the guidance outlines how the FDA should assess amendments submitted to ANDAs and Post Approval Studies (PASs) programs received before October 1, 2017, the effective date of GDUFA II review goals.

Electronic Submissions Gateway

The FDA’s Electronic Submissions Gateway is an essential resource you can use to learn more about ANDAs. It’s the primary way sponsors can submit ANDA applications and other regulatory applications to the agency for review.

Drug Information Portal

The FDA’s Drug Information Portal is another valuable resource for ANDA submissions. It provides access to information on all FDA-approved drugs, including generic drugs. You can use the portal to gather information on a reference listed drug, including its regulatory history and labeling, which is essential for preparing an ANDA submission.

Organizations & Associations

Several industry organizations, such as the Association for Accessible Medications (AAM), formerly known as the Generic Pharmaceutical Association (GPhA), provide information and support to companies developing and selling generic drugs. These organizations often offer educational resources, regulatory updates, and advocacy services, which can be very useful for sponsors preparing ANDA submissions.

Consultants & Consulting Firms

A number of consultants and consulting firms specialize in the ANDA process (a Google search for “ANDA consultants” typically gives you decent results). These consultants may be able to provide expertise on the regulatory and scientific aspects of ANDA submissions and help sponsors navigate the submission process.

MaPPs

The agency’s Manual of Policies and Procedures (MaPPs) can also be used as a resource to learn more. MaPPs offer official directives for the internal practices and procedures implemented by the staff at the Center for Drug Evaluation and Research (CDER), which are used to standardize the ANDA, NDA, and Investigational New Drug application (IND) evaluation process. The FDA’s MaPP Index provides access to all CDER MaPPs.

Laws & Regulations

ANDAs are subject to various laws and regulations in the United States. The primary law that governs ANDA is the FD&C Act, which provides the legal framework for the approval and regulation of drugs in the US. The application is also governed by the rules outlined in Title 21 of the Code of Federal Regulations (CFR).

The FD&C Act’s purpose is to assure consumers that food products are pure, safe for consumption, and produced under hygienic conditions. It is also used to ensure that drugs and medical devices are safe and effective for their intended use. Furthermore, it also governs cosmetics and ensures that cosmetic products are made of safe ingredients and are safe for use. The act also assures all labeling and packaging accurately reflects the product, is informative, and does not mislead the consumer.

These laws and regulations provide specific requirements for the content and format of an ANDA submission and the standards for generic drug equivalence and labeling.

Code of Federal Regulations (CFR)

The Code of Federal Regulations (CFR) is a compilation of the United States federal regulations the Office of the Federal Register publishes annually. The CFR contains the text of rules issued by federal agencies and is organized by subject matter into 50 titles.

Title 21 of the CFR pertains to food and drugs and includes the regulations that govern the approval and regulation of ANDAs. Title 21 establishes the requirements for ANDA submissions, including the content and format of applications and the standards for generic drug equivalence and labeling. The CFR provides guidance for the ANDA process and helps ensure that generic drug products are safe, effective, and of high quality.

In other words, the CFR is a critical source of regulatory information for the ANDA process and provides the legal framework for the approval and regulation of generic drug products in the United States.

What Types of Equipment are Used to Develop Generic Drugs?

The pharmaceutical industry needs to meet extremely high quality standards, making compliance with Good Manufacturing Practice (GMP) essential for all pharmaceutical manufacturing equipment.

The equipment used in different processes encompasses a broad range of items, from capsule fillers and x-ray inspection systems to spray drying components. To guarantee accurate manufacturing and formulation development, automation is often utilized extensively, resulting in equipment playing a role in almost every step of the process.

While we’d love to get more specific, the types of equipment used in the development of generic drugs really depend on the type of product being developed and manufactured, as well as the specific processes involved in manufacturing the product and the production scale. Some standard pieces of equipment used in the pharmaceutical industry for drug development and production include:

  • Reactors, bioreactors, and mixing vessels for chemical synthesis
  • Various centrifuges for separation and purification of drug substances
  • Filters and filtering systems for removing impurities
  • Drying equipment for removing moisture from the final drug product
  • Various mills and granulators for size reduction of the drug substance
  • Homogenizers for processing fluids for particle size reduction and cell lysis
  • Agitators for mixing liquids and promoting chemical reactions
  • Inspection machines for visual inspection of the product
  • Tableting presses for compressing the drug into tablets
  • Capsule-filling machines for encapsulating the drug substance
  • Packaging equipment for packaging the final drug product into its final packaging.

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