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How does CDER assess bioequivalence in generic drug applications?
Answer
The Center for Drug Evaluation and Research (CDER) assesses bioequivalence (BE) in generic drug applications primarily through a combination of regulatory requirements, scientific guidelines, and statistical criteria. The process ensures that a generic drug performs in the same manner as its reference listed drug (RLD). Here is an overview of how CDER conducts this assessment:
1. Regulatory and Scientific Basis
- To be approved as a generic, a drug must be both pharmaceutically equivalent (same active ingredient, dosage form, strength, and route of administration) and bioequivalent to the RLD 1.
- Bioequivalence is defined as the absence of a significant difference in the rate and extent to which the active ingredient becomes available at the site of action when administered at the same molar dose under similar conditions 1.
2. Types of Bioequivalence Studies
- In Vivo Pharmacokinetic (PK) Studies: For most orally administered drugs, BE is demonstrated by comparing PK parameters (such as Cmax and AUC) between the generic (test) and reference products in healthy volunteers 9318.
- In Vitro Studies: For certain drug products (e.g., oral solutions, highly soluble drugs), in vitro dissolution testing may suffice if justified 27.
- Clinical Endpoint or Pharmacodynamic Studies: For drugs where blood levels do not reflect efficacy (e.g., topical products), BE may be established using clinical endpoint studies or pharmacodynamic measurements 3292.
3. Study Design and Statistical Criteria
- The standard study design is a randomized, two-period, two-sequence crossover in healthy volunteers, where each subject receives both the test and reference products 9.
- The primary PK parameters assessed are:
- Cmax (maximum plasma concentration)
- AUC (area under the plasma concentration-time curve, both to the last measurable time point and extrapolated to infinity) 3189.
- The statistical approach involves calculating the 90% confidence interval (CI) for the ratio of the geometric means (test/reference) for Cmax and AUC.
- Acceptance criteria: The 90% CI must fall within 80-125% (0.8-1.25) for both parameters 31892934.
- For some drugs (e.g., modified-release products), replicate study designs or additional PK parameters may be required 15.
4. Product-Specific Guidance and Exceptions
- CDER issues product-specific guidances that may specify additional or alternative BE requirements, such as the need for both fasting and fed studies, or in vitro-in vivo correlation studies 13637.
- For locally acting drugs (e.g., inhaled, topical), BE may rely more on in vitro testing, pharmacodynamic endpoints, or clinical studies, as systemic PK may not reflect local drug delivery 4327856.
- In some cases, waivers for in vivo studies may be granted if in vitro data are sufficient and justified 275169.
5. Completeness and Data Integrity
- A "complete" BE study is one that conforms with FDA guidance or is reasonable in design and purports to demonstrate BE to the RLD 810111213141719202122232425283031333538404143444546474850515455576162636465666768697071727374757677808182838485868891.
- Data integrity and compliance with Good Laboratory Practice (GLP) and FDA regulations (e.g., retention of study samples, proper statistical analysis) are essential for acceptance 2633538187.
6. Review and Decision
- CDER's Office of Generic Drugs (OGD) reviews the submitted BE studies for scientific validity, adherence to guidance, and statistical acceptability.
- If the studies meet all criteria, the generic drug is considered bioequivalent and eligible for approval 2357174.
Summary Table of Key Steps:
Step | Description |
---|---|
1 | Confirm pharmaceutical equivalence |
2 | Conduct appropriate BE studies (in vivo PK, in vitro, or clinical endpoint) |
3 | Analyze PK parameters (Cmax, AUC) using 90% CI for T/R ratio |
4 | Ensure 90% CI falls within 80-125% for both parameters |
5 | Address product-specific guidance and exceptions |
6 | Submit complete, compliant data for CDER review |
References:
- 1 Evaluation of Therapeutic Equivalence
- 318 ***************** CHLORIDE (FDA memoranda)
- 9 Statistical Approaches to Establishing Bioequivalence
- 4 Drug Products, Including Biological Products, that Contain Nanomaterials - Guidance for Industry
- 15 ******************* (FDA deficiency letter)
- 27 CVM GFI #171 - Demonstrating Bioequivalence for Soluble Powder Oral Dosage Form Products
- 3292 Topical Dermatologic Corticosteroids: in Vivo Bioequivalence
- 3429 GLYDO LIDOCAINE HYDROCHLORIDE; CALCIPOTRIENE CALCIPOTRIENE (FDA BE checklists)
- 7856 ***************** (FDA memoranda)
- 810111213141719202122232425283031333538404143444546474850515455576162636465666768697071727374757677808182838485868891 (FDA memoranda on ANDA completeness and BE study requirements)
- 2633538187 (FDA guidance on data integrity and compliance)
In summary, CDER assesses bioequivalence in generic drug applications by requiring scientifically valid studies (usually in vivo PK studies), applying strict statistical criteria (90% CI within 80-125% for Cmax and AUC), and ensuring compliance with regulatory and data integrity standards. Product-specific guidance and alternative approaches may be used depending on the drug and its route of administration.

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What kinds of mouthwashes have been approved by the FDA / EMA and which regulatory pathways have they taken?
Answer
Based on the provided FDA and EMA datasets, the following summarizes the types of mouthwashes approved and the regulatory pathways they have taken:
1. Mouthwashes Approved as Medical Devices (FDA 510(k) Pathway)
These products are typically classified as medical devices and are cleared via the FDA's 510(k) premarket notification process. They are often "substantially equivalent" to predicate devices already on the market.
A. Dry Mouth Relief / Artificial Saliva Mouthwashes
- Examples:
- Biotene Dry Mouth Oral Rinse 2241939
- Oral-B Dry Mouth Oral Rinse 59505672
- SmartMouth DryMouth Oral Rinse 73454
- TheraBreath Dry Mouth Oral Rinse 11123361
- Oral7 Moisturizing Mouthwash 6465962
- GuruNanda Dry Mouth Oral Rinse 31
- Hydris Oral Rinse 28294078
- GUM HYDRAL Dry Mouth Oral Rinse 14
- Moisyn Dry Mouth Oral Rinse 1558
- Dr. Fresh Dry Mouth Mouthwash 11730
- Regulatory Pathway: FDA 510(k) clearance as "saliva, artificial" (Product Code: LFD), typically unclassified or Class II medical devices. These products are reviewed for substantial equivalence to predicate devices and are subject to general controls (registration, labeling, GMP, etc.) 22457111415283134465056586272.
B. Desensitizing Mouthwashes
- Examples:
- Colgate Desensitizing Mouthwash / Sensitive Pro-Relief 82341
- LISTERINE Sensitivity Defense Mouthrinse 33651
- Regulatory Pathway: FDA 510(k) clearance, typically as "cavity varnish" (21 CFR 872.3260, Product Code: LBH), Class II devices. These are cleared based on substantial equivalence to predicate devices for the management of sensitive teeth 3823364151.
C. Oral Wound and Mucositis/Stomatitis Rinses
- Examples:
- Aftamed Mouthwash 4162126
- MuGard Mucoadhesive Oral Wound Rinse 42
- OraMagicRx Oral Wound Rinse 27
- OraMagic Plus Oral Wound Rinse 74
- Regulatory Pathway: FDA 510(k) clearance, often as "hydrogel wound dressing" or "mucositis/stomatitis oral rinse" (Product Code: MGQ), unclassified or Class II devices 4162126274274.
D. Plaque/Gingivitis Reduction Rinses (Non-drug)
- Examples:
- Decapinol Oral Rinse 2535
- Regulatory Pathway: FDA 510(k) clearance as "oral rinse to reduce adhesion of dental plaque" (21 CFR 872.5580, Product Code: NTO), Class II devices with special controls 2535.
2. Mouthwashes Approved as Drugs (FDA NDA/ANDA Pathway)
Some mouthwashes, especially those with active pharmaceutical ingredients (APIs) like chlorhexidine gluconate or sodium fluoride, are regulated as drugs and require New Drug Applications (NDA) or Abbreviated New Drug Applications (ANDA).
A. Antimicrobial Mouthwashes (Chlorhexidine Gluconate)
- Examples:
- Peridex (chlorhexidine gluconate 0.12%) 4455606375
- ********* (chlorhexidine gluconate 0.12%)* 22475564656668697077
- Regulatory Pathway: FDA NDA or ANDA approval. These are prescription (Rx) drugs. ANDA approvals require the generic product to be qualitatively and quantitatively (Q1/Q2) the same as the reference listed drug, and bioequivalence waivers are often granted due to the topical (oral cavity) use 224455606365667075.
B. Anticaries/Antiplaque/Antigingivitis Mouthwashes (Fluoride, Triclosan)
- Examples:
- Colgate Total (sodium fluoride 0.24%, triclosan 0.30%) 203848577173
- Regulatory Pathway: FDA NDA approval (505(b)(1)), as these are considered new drugs due to their active ingredients and claims. The review includes efficacy and safety data for anti-caries and anti-gingivitis indications 203848577173.
3. EMA (European Medicines Agency) Approvals
- The provided sources do not contain direct evidence of EMA approvals for mouthwashes. Some products are manufactured by European companies (e.g., Sinclair Pharmaceuticals, Bioplax Limited), but the regulatory pathway described is for FDA clearance, not EMA approval 18253552.
- Note: In the EU, many mouthwashes are regulated as medical devices under the Medical Device Regulation (MDR) or as medicinal products, depending on their ingredients and claims. However, no EMA-specific approval data is present in the provided sources.
Summary Table
Type of Mouthwash | Example Products | FDA Regulatory Pathway | Class/Status |
---|---|---|---|
Dry Mouth/Artificial Saliva | Biotene, Oral-B, SmartMouth, Oral7 | 510(k) | Unclassified/Class II |
Desensitizing | Colgate Sensitive, Listerine Defense | 510(k) | Class II |
Oral Wound/Mucositis | Aftamed, MuGard, OraMagic | 510(k) | Unclassified/Class II |
Plaque/Gingivitis (Non-drug) | Decapinol | 510(k) | Class II |
Antimicrobial (Chlorhexidine) | Peridex, ******** | NDA/ANDA | Rx Drug |
Anticaries/Antiplaque (Fluoride) | Colgate Total | NDA | OTC/Rx Drug |
Key Points
- Most dry mouth, desensitizing, and wound care mouthwashes are regulated as medical devices and cleared via the FDA 510(k) pathway.
- Antimicrobial and anticaries mouthwashes with active drug ingredients (e.g., chlorhexidine, fluoride) are regulated as drugs and require NDA or ANDA approval.
- Bioequivalence waivers are commonly granted for generic chlorhexidine gluconate rinses due to their topical use and identical formulation to reference products 224455606365667075.
- No direct EMA approval data is present in the provided sources.
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