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SFDA item 35 · II. Quality changes · II.2 Finished product c) Control of excipients

Change in synthesis or recovery of a non-pharmacopeial excipient (when described in the dossier) or a novel excipient

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 35 — official PDF, p. 45 ↗

VariantChangeType
aMinor change in synthesis or recovery of a non-pharmacopeial excipient or a novel excipientType IA
bThe specifications are affected or there is a change in physicochemical properties of the excipient which may affect the quality of the finished product.Type II
cThe excipient is a biological/immunological substanceType II

Conditions to be fulfilled and documentation to be supplied: see the official guideline, item 35.

EU European Union

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

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

US FDA US Food and Drug Administration

21 CFR 314.70 and FDA guidance — 21 CFR 314.70(b)(1), (b)(2)(iv), (d)(1) · 2004 Guidance §V, §VII.C.1.b, §VII.B.3 (by analogy)

ChangeCategoryReference
Established non-compendial excipient: minor synthesis/recovery change, specification, impurity profile and physicochemical properties unchangedAnnual report21 CFR 314.70(d)(1)
Novel excipient: process or process-parameter change with no effect on specification (drug-substance analogy)CBE-30 supplement2004 §VII.C.1.b
Change that may alter the excipient's impurity profile or physicochemical properties, or its specificationPrior approval supplement21 CFR 314.70(b)(2)(iv)
Biological/natural-source excipient: change in virus or adventitious-agent removal/inactivationPrior approval supplement2004 §VII.B.3

Note: The 2004 and 2014 guidances give no examples for excipient manufacturing changes (§V defers components to SUPAC). Under 314.70(a)(2) the applicant assesses the change and classifies it by its potential for adverse effect, using the drug-substance categories as a guide. Where the excipient is covered by a DMF, the holder amends the DMF and the applicant reports under these categories.

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.