Regulatory PathRegulatory requirements compared

SFDA item 1 · I. Administrative changes

Change in the marketing authorization holder

Variation category under SFDA, EU and US FDA rules for this change, with the variant wording as published.

Open in the Variation Compass

SFDA Saudi Food and Drug Authority

Guidelines for Variation Requirements v6.3 (DS-G-006), item 1 — official PDF, p. 12 ↗

VariantChangeType
aChange in the name and/or address of the marketing authorization holderType IA(IN)
bTransfer the product to new marketing authorization holder (different legal entity)Type IB

Conditions to be fulfilled and documentation to be supplied: see the official guideline, item 1.

EU European Union

Commission Guidelines C/2025/5045 — EUR-Lex ↗

E.4 · Change in the name and/or address of the marketing authorisation holder, ASMF holder, storage site of the master and/or working cell bank, manufacturing site for an active substance, intermediate or finished product, primary and/or secondary packaging site, manufacturer responsible for batch release, site where quality control takes place, and/or supplier of a packaging component, medical device (part), starting material, reagent and/or excipient (when mentioned in the dossier)

VariantChangeType
aThe change in the name and/or address concerns the marketing authorisation holderType IA(IN)
bThe change in the name and/or address concerns a manufacturer(s)whose activities include batch release of the finished productType IA(IN)
cThe change in the name and/or address does not concern a manufacturer(s) whose activities include batch release of the finished product nor the marketing authorisation holderType IA

Note: E.4(a) covers a change of the holder's name or address within the same legal entity. A transfer to a different legal entity is not an EU variation; it follows a separate transfer procedure (Regulation (EC) No 2141/96 for centrally authorised products).

US FDA US Food and Drug Administration

21 CFR 314.70 and FDA guidance — MAPP 5242.1 (name/address) · 21 CFR 314.72 (transfer) · 2004 Guidance §X.D.2 (labeling)

ChangeCategoryReference
Applicant name and/or address changes, same legal entity: administrative correspondence to the application, no supplementAdministrative correspondenceMAPP 5242.1
Transfer of the NDA/ANDA to a different legal entity: letters from former and new owner under 314.72, no supplementAdministrative correspondence21 CFR 314.72
Update the company name printed on carton/container labeling to the new name (editorial)Annual report2004 §X.D.2

Note: MAPP 5242.1 (name or address) and 21 CFR 314.72 (transfer of ownership) govern these changes. Under 314.72(b), a new owner may report a labeling change to the brand name or to the manufacturer, packer or distributor name in the next annual report; any other change in approval conditions still follows 314.70.

Other items in I. Administrative changes

Not regulatory advice. The binding text is each regulator's current official document; confirm the category with the authority before filing. FDA publishes no classification table: the US category follows FDA guidance or, where the guidance does not name the change, the closest example under 21 CFR 314.70.