Combination products, which integrate drugs, devices, and/or biological products, have revolutionized healthcare by offering innovative therapeutic solutions. However, their unique nature presents significant Regulatory challenges. This comprehensive guide explores the intricate landscape of combination product regulation and provides strategies for successfully navigating these complex pathways.Understanding Combination Products and Their Regulatory FrameworkCombination products are medical products that combine two (2) or more regulated components - drugs, devices, or biologics - into a single entity. These innovative products can take various forms, such as drug-eluting stents, prefilled syringes, or transdermal patches. The Regulatory framework for combination products is primarily governed by the U.S. Food and Drug Administration (FDA) in the United States, with similar approaches adopted by Regulatory bodies worldwide.The FDA's Office of Combination Products (OCP) plays a crucial role in determining a combination product's primary mode of action (PMOA), which determines the Regulatory pathway and the lead FDA center responsible for review. The Center for Drug Evaluation and Research (CDER), Center for Devices and Radiological Health (CDRH), and Center for Biologics Evaluation and Research (CBER) collaborate in the review process, emphasizing the need for an integrated approach to ensure combination product safety and efficacy.Determining the Regulatory PathwayOne (1) of the most critical steps in developing a Regulatory strategy for combination products is determining the appropriate Regulatory pathway. This decision is primarily based on the product's PMOA. Here are key considerations:Primary Mode of Action (PMOA): Identify the single mode of action that provides the most important therapeutic action of the combination product.Lead Center Assignment: Based on the PMOA, the product will be assigned to CDER, CDRH, or CBER for primary review.Regulatory Submission Type: Depending on the lead center, the submission may take the form of a New Drug Application (NDA), Biologics License Application (BLA), or Premarket Approval (PMA).Request for Designation (RFD): If the PMOA is unclear, sponsors can submit an RFD to the OCP for a formal determination.Pre-Request for Designation (Pre-RFD): The OCP can receive a Pre-RFD for informal, non-binding feedback on classification and jurisdictional questions.
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