Date: 2025-02-24Category: Not ApplicableState: Union GovernmentCountry: India
Evaluation of certain pre 1988 permitted Fixed Dose Combinations (FDCs) de novo for manufacture for sale in the country without due approval from Central Licensing Authority 24 Feb 2025
**Executive Summary:**
The Central Drugs Standard Control Organization (CDSCO) addresses the evaluation of pre-1988 Fixed Dose Combinations (FDCs) manufactured and sold without Central Licensing Authority approval. Manufacturers holding licenses from State Licensing Authorities (SLA) before 01.10.2012 for certain FDCs are required to submit applications and data. The policy outlines required documentation, timelines, and actions for both existing and new manufacturers, with a final deadline for application submissions for category d FDCs set within 3 months of the letter's issuance date (24FEB 2025).
**Key Points / Main Content:**
* **Background:**
* Concerns exist regarding FDCs manufactured and sold without Central Licensing Authority approval.
* An Expert Committee was formed to examine pre-1988 FDCs licensed by State Licensing Authorities (SLA) without DCGI approval.
* The Committee recommended data generation for specific FDCs, including Phase IV Clinical Trials or Active Post Marketing Surveillance (PMS).
* **Requirements for Existing Manufacturers (License before 01.10.2012):**
* Must submit applications for Phase IV Clinical Trial protocol or Active Post Marketing Surveillance to the Directorate.
* Deadline for application submission for category d FDCs is within 3 months from the date of issuance of the letter (24FEB 2025).
* Required documents include Form CT21, fees, FDC name and composition, Product Permission from SLA, manufacturing license, and Phase IV trial or PMS protocol commitment.
* Failure to submit applications may result in regulatory action from CDSCO.
* **Requirements for New Manufacturers:**
* Required documents include Form CT21, fees, FDC name and composition, Product Permission from SLA, manufacturing license, stability studies data, test specifications, and Phase IV trial or PMS protocol commitment.
* **General Requirements:**
* Manufacturers must comply with the Expert Committee's recommendations regarding prescribing information/label revisions.
* Manufacturers who held licenses before 01.10.2012 and did not apply to DCGI are required to submit their applications to this Directorate at the earliest but not later than 6 months, failing which their applications will not be considered and their licenses will be considered as without legal validity (from 41 JAN 202-).
**Impact Analysis:**
* **State/UT Drugs Controllers**
* *Impact:* Responsible for notifying concerned manufacturers/stakeholders in their state about the application requirements and deadlines.
* *Action Required:* Inform manufacturers to submit applications within the specified timeframe and follow the outlined procedures.
* **Manufacturers/Stakeholders (Existing License Holders):**
* *Impact:* Must comply with the application requirements to continue manufacturing and selling pre-1988 FDCs. Failure to comply may result in regulatory action, including license invalidation.
* *Action Required:* Submit required documentation within the specified timeframe (3 months from the date of the letter for category d FDCs, and the earliest but not later than 6 months to avoid invalidation of licenses) and comply with expert committee recommendations.
* **New Manufacturers:**
* *Impact:* Must comply with the application requirements to start manufacturing and selling FDCs.
* *Action Required:* Submit required documentation.
* **CDSCO Zonal and Sub-Zonal Offices**
* *Impact:* Required to monitor compliance and potentially take regulatory action against non-compliant manufacturers.
* *Action Required:* Ensure compliance with the policy and implement regulatory measures as needed.
Key Entities Referenced
Fixed Dose Combinations (FDCs): A combination of two or more active pharmaceutical ingredients in a single dosage form, subject of the evaluation and regulation described in the policy.
Central Drugs Standard Control Organization (CDSCO): The national regulatory body for pharmaceuticals and medical devices in India, responsible for approving and regulating drugs, including FDCs.
State Licensing Authorities (SLA): State-level authorities responsible for issuing manufacturing licenses for drugs, including FDCs, prior to a specified date.
Drugs Controller General India (DCGI): Head of the Central Drugs Standard Control Organization (CDSCO) and responsible for approving new drugs and regulating drug-related matters in India.
Ministry of Health and Family Welfare: The government ministry responsible for public health in India, overseeing the CDSCO and related regulations.
New Drugs and Clinical Trials Rules 2019: A set of rules governing the approval and regulation of new drugs and clinical trials in India. It is relevant to the fees specified for applications related to FDCs.
Phase IV Clinical Trial: Post-marketing surveillance studies conducted to gather additional information about a drug's effects in various populations and any side effects associated with long-term use. Manufacturers of certain FDCs are required to conduct these trials.
Dr. M. S. Bhatia: Professor and Head, Department of Psychiatry, University College of Medical Sciences, New Delhi; Chairman of the Expert Committee constituted to examine certain pre-1988 FDCs.
F. No. 04-01/2013-DC (Misc. 13-PSC) (Pt. Il) (Sub Part-1)
Government of India
Directorate General of Health Services
Central Drugs Standard Control Organization
(FDC Division)
FDA Bhawan, Kotla Road,
New Delhi
Dated:
24FEB 2025
To
All State/UT Drugs Controllers,
Subject:- Evaluation of certain pre 1988 permitted Fixed Dose Combinations (FDCs)
de novo for manufacture for sale in the country without due approval from
Central Licensing Authority -regarding.
Sir,
This is in continuation to this Directorate notice of even number dated 11.01.2024. As
per this said letter, manufacturers who are already holding licenses from State Licensing
Authorities for such FDCs before 01.10.2012 and did not apply to DCG (I) were required to
submit their applications for Phase IV Clinical Trial protocol / Active Post Marketing
Surveillance to this Directorate. The date for filing such applications expired on 11.07.2024
and already passed approximate 12 months from the date of above mentioned notice.
However, it is observed that most of the firms have not submitted their application to
this Directorate. It has been decided that the manufacturers/stakeholders who were holding
license prior to 01.10.2012 may submit their applications w.r.t category ‘d’ FDCs within 03
months from the date of issuance of this letter.
In view of above, without prejudice to legal validity of such product licenses, all the
concerned manufacturers/stakeholders may be requested to submit their application within
03 months from the date of issuance of this letter, failing which appropriate regulatory action
will be recommended from CDSCO.
Yours faithfully
(Dr. gh Raghuvanshi)
Drugs Controller General (India)
Copy to:-
ep PS to JS(R), Ministry of Health and family Welfare, Nirman Bhawan, New Delhi
CDSCO Zonal and Sub-Zonal offices
Indian Drug/Pharmaceuticals Association Forum
Website of CDSCO
=File No. 4-01/2013-DC (Misc. 13-PSC) (Pt. Il) (Sub Part-1)
Govt. of India
Directorate General of Health Services
Central Drugs Standard Control Organization
(FDC Division)
Dated:
41 JAN 202
NOTICE
Subject: Evaluation of certain pre 1988 permitted Fixed Dose Combinations
(FDCs) de novo for manufacture for sale in the country without due
approval from Central Licensing Authority -regarding.
This is with reference to this office letter dated 15.01.2013 whereby all the
State/UT Drugs Controllers were requested to ask the concerned manufacturers
in their State to prove the safety and efficacy of FDCs within 18 months which
were permitted by State Licensing Authorities without due approval from the office
of DCG(I).
In continuation to Hon'ble Supreme Court order dated 15.12.2017 and
14.02.2019, Accordingly, Ministry of Health & Family Welfare vide order No.
X11035/53/2014-DFQC (Part-IV) dated 02.02.2021 constituted an Expert
Committee under the Chairmanship of Dr. M. S. Bhatia, Professor & Head, D/o
Psychiatry, University College of Medical Sciences, New Delhi for examining
certain pre-1988 FDCs denovo licensed for manufacturing for sale in the country
without due approval from Central Licensing Authority.
The Expert Committee submitted its report accordingly on these 19 FDCs claimed
to be pre-1988 after holding a series of meetings as well as by providing hearing
to the stakeholders wherein, the Committee after detailed deliberation
recommended for generation of data w.r.t. following 03 FDCs:-
Sr.No. | Name of FDC as per the | Recommendations
public notice
1. Paracetamol IP 500mg +/The committee recommended for
Phenylephrine continued manufacturing and marketing
Hydrochloride IP 10mg + | of the FDC with the condition to generate
Caffeine Anhydrous’ IP | safety and efficacy data by way of
32mg tablets conducting Phase IV Clinical Trial.
Accordingly, Phase IV Clinical Trial is
required to be conducted to generate the
data within time frame of one year.2. Caffeine Anhydrous IP + The committee recommended _ for
Paracetamol IP + continued manufacturing and marketing
Phenylephrine of FDC with following conditions:
Hydrochloride IP + a. FDC shall be sold by retail
on the prescription of a
Chlorpheniramine Maleate
R.M.P. only
IP (15mg + 500mg + 5mg +
b. Package insert should also
2mg, 30mg + 500mg +
mention caution for patients
5mg + 2mg, 30mg + 500mg
suffering from
+ 10mg + 2mg, 30mg +
cardiovascular diseases.
500mg + 10mg + 4mg &
c. Dose of Paracetamol in the
30mg + 650mg + 10mg +
FDC should be minimum
2mg) tablets
500mg
The Committee also recommended to
conduct a Randomized comparative,
Phase IV Clinical Trial comparing the
FDC with the individual ingredients
present in the FDC.
Accordingly, Phase IV Clinical Trial is
required to be conducted to generate the
data within time frame of one year.
3 Paracetamol IP 250mg + The committee recommended _ for
Propyphenazone 150mg + continued manufacturing and marketing
Caffeine 30mg tablets of the FDC for mild to moderate
Headache with the conditions that:
a. FDC shall not be taken more than
5 to 7 days
b. FDC to be sold by retail on the
prescription of a R.M.P. only’.
c. Further, the firm(s) shall conduct
Active PMS study to generate
safety and efficacy data on the
FDC.
Accordingly, Active Post Marketing
Surveillance is required to be conducted
to generate the data within time frame of
one year.
With the approval of Ministry, it has been now decided to follow the pathway for
clearance of such subsequent applications as under:-
1. Documents required in case of manufacturers already holding licenses from
State Licensing Authority (SLA) before 01.10.2012 for the proposed FDCs
shall at least contains:-
a) Form CT-21 (duly filled, signed and stamped)
b) Fees as specified in sixth schedule of New Drugs and Clinical Trials
Rules 2019 through Bharatkosh.
c) Name and composition of the FDC
d) Product Permission issued by SLA
e) Copy of Manufacturing license in Form 25/28f) Phase IV trial protocol / commitment. for conducting Active Post
Marketing Surveillance study protocol, as the case may be.
2. Documents required in case of new manufacturers for the proposed FDCs
shall at least contain:-
a) Form CT-21 (duly filled, signed and stamped)
b) Fees as specified in sixth schedule of New Drugs and Clinical Trials
Rules 2019 through Bharatkosh.
c) Name and composition of the FDC
d) Product Permission issued by SLA in Form 29
e) Copy of Manufacturing license in Form 25/28
f) Stability studies data (06 months accelerated)
g) Test Specifications of the FDC alongwith Method of Analysis
h) Phase IV trial protocol / commitment for conducting Active Post
Marketing Surveillance study protocol, as the case may be.
3. All the manufacturers who are already holding licenses from State Licensing
Authorities for such FDCs before 01.10.2012 and did not apply to DCG (I) are
required to submit their applications to this Directorate at the earliest but not
later than 6 months, failing which their applications will not be considered and
their licenses will be considered as without legal validity.
4. Manufacturers shall comply with the recommendation of the expert committee
w.r.t. revision of the prescribing information/label.
In view of above, all concerned stakeholders are required to follow above
procedure for clearance of such cases.
Yours/faithfully
Qu)
(Dr. Rajeev Singh Raghuvapyishi)
Drugs Controller General (Ifidia)
To:-
All State/UT Drugs Controllers/All Zonal/Sub Zonal offices of CDSCO.
Copy to:-
1. PPS to Secretary/AS(F&D)/JS(R), Ministry of Health and Family Welfare,
Nirman Bhawan, New Delhi.
2. Indian Drug & Pharmaceuticals Associations/Website of CDSCO.