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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:
- 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:
- 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:
- 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:
- 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:
- 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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