Regulatory PathRegulatory requirements compared

SFDA item 44 · II. Quality changes · II.2 Finished product e) Container closure system

Change in any part of the (primary) packaging material not in contact with the finished product formulation (such as color of flip-off caps, color code rings on ampoules, change of needle shield (different plastic used)

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 44 — official PDF, p. 54 ↗

VariantChangeType
aChange that affects the product informationType IA(IN)
bChange that does not affect the product informationType IA

Conditions to be fulfilled and documentation to be supplied: see the official guideline, item 44.

EU European Union

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

Q.II.e.3 · Change in any part of the (primary) packaging material not in contact with the finished product formulation (such as colour of flip-off caps, colour code rings on ampoules)

VariantChangeType
aChange that affects the product informationType IA(IN)
bChange that does not affect the product informationType IA

Q.IV.2 · Changes to an integral medical device (part)

VariantChangeType
aAddition or replacement of an integral device (part) or major change to the materials and/or design and/or performance characteristics of an integral device which may have a significant impact on the delivery or the quality, safety, or efficacy of the medicinal productType II
bAddition or replacement of an integral device (part) which does not have a significant impact on the performance, delivery, quality, safety or efficacy of the medicinal productType IB
cDeletion of an integral medical device (part) that does not lead to the complete deletion of a strength or pharmaceutical formType IA(IN)
dChange of a material of a device (part) not in contact with the medicinal productType IA
eChange of a material of a device (part) in contact with the medicinal product that does not have a significant impact on the performance, safety, quality or efficacy of the medicinal product and does not contain materials of human or animal origin for which assessment is required of viral safety data or TSE riskType IB
fAddition or replacement of a supplier/manufacturer of an existing device (part)Type IA
gAddition or replacement of a site responsible for sterilisation of the device (part) and/or change to the sterilisation process of the device (part) when supplied as sterileType IB
hOther minor change to an integral device (part)Type IA

Note: A change of needle-shield material falls under Q.IV.2 (integral medical device part) rather than Q.II.e.3.

US FDA US Food and Drug Administration

21 CFR 314.70 and FDA guidance — 2004 Guidance §IX.C.1.a, §IX.D.8 · 2014 AR Guidance App. A 5.5–5.6 · 21 CFR 314.70(d)(2)(ix)

ChangeCategoryReference
Flip-off cap colour change consistent with an established colour-coding systemAnnual report2004 §IX.D.8; 2014 App. A 5.5
Crimp-cap (ferrule/overseal) change without colour change and with CCI shown; removing cap markings to comply with the compendiumAnnual report2014 App. A 5.5–5.6
Resulting update of the product description/How Supplied labelingAnnual report21 CFR 314.70(d)(2)(ix)
Other non-contact primary component change not listed (e.g., needle-shield plastic), no effect on qualityCBE-30 supplement2004 §IX.C.1.a

Note: A cap colour that departs from an established colour-coding system falls outside the AR example, and any change that could affect container-closure integrity or sterility assurance of a sterile product is PAS (§IX.B.4).

Other items in II.2 Finished product e) Container closure system

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.