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SFDA item 34 · II. Quality changes · II.2 Finished product c) Control of excipients

Change in supplier of an excipient or reagent without TSE risk

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 34 — official PDF, p. 45 ↗

VariantChangeType
-Change in supplier of an excipient or reagent without TSE riskType IA

Conditions to be fulfilled and documentation to be supplied: see the official guideline, item 34.

EU European Union

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

Q.II.c.3 · Change in source of an excipient or reagent with TSE risk, which is used in the manufacture of an active substance or in a finished product

VariantChangeType
aChange in the source of an excipient or reagent from a TSE risk material to a material of vegetable or synthetic originType IA
bChange in the source of an excipient or reagent which is unlikely to present any risk of TSE contaminationType IA
cChange in the source of a TSE risk material, or introduction of a TSE risk material, not covered by a European Pharmacopoeial TSE certificate of suitabilityType II

Q.II.c.4 · Change in synthesis, manufacturing or recovery of an excipient (when described in the dossier)

VariantChangeType
aMinor change in synthesis, manufacturing or recovery of an excipientType IA
bChange in the manufacturing site, synthesis, manufacturing or recovery of the excipient which may affect the quality, safety or efficacy of the finished productType II
cDeletion of one manufacturing process of an excipientType IA
dAddition or replacement of a site responsible for the manufacture or testing of an excipient, when required to be described in the dossierType IB

Note: There is no exact EU item. Q.II.c.3(b) covers a change in source of an excipient or reagent unlikely to present a TSE risk; a new excipient manufacturing site described in the dossier is Q.II.c.4(d).

US FDA US Food and Drug Administration

21 CFR 314.70 and FDA guidance — 2014 AR Guidance App. A 1.3, App. B 1.4 · 21 CFR 314.70(a)(1)(i), (d)

ChangeCategoryReference
Supplier not named in the approved application; grade and specification unchanged (supplier qualification handled under CGMP)Not reportable21 CFR 314.70(a)(1)(i)
Supplier (or DMF holder) named in the application replaced or added; excipient specification and technical grade unchangedAnnual report2014 App. A 1.3; App. B 1.4

Note: If the new supplier's material has a different grade or specification, classify by the specification or composition change instead (e.g., relaxation PAS, §VIII.B.1; release-controlling excipients of modified-release products per SUPAC-MR). A supplier not named in the approved application is not a condition of approval, so changing it needs no 314.70 notice (314.70(a)(1)).

Other items in II.2 Finished product c) Control of excipients

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.