Regulatory PathRegulatory requirements compared

SFDA item 52 · II. Quality changes · II.5 Drug containing medical device

Change of a measuring or administration device

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 52 — official PDF, p. 64 ↗

VariantChangeType
a.1Addition or replacement of a device which is not an integrated part of the primary packaging — Spacer device for metered dose inhalers or other device which may have a significant impact on the delivery of the active substance in the product (e.g. nebuliser)Type II
a.2Addition or replacement of a device which is not an integrated part of the primary packaging — Certified Device (for example with MDMA)Type IA(IN)
a.3Addition or replacement of a device which is not an integrated part of the primary packaging — Non certified Device for veterinary products onlyType IB
bDeletion of a deviceType IA(IN)
cAddition or replacement of a device which is an integrated part of the primary packagingType II

Conditions to be fulfilled and documentation to be supplied: see the official guideline, item 52.

EU European Union

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

Q.IV.1 · Changes to a device co-packaged with the medicinal product or referenced in the product information

VariantChangeType
aAddition or replacement of a co-packaged device or referenced deviceType IA(IN)
bAddition, replacement or other changes of a co-packaged or referenced device that may have a significant impact to the delivery, quality, safety and/or efficacy of the medicinal productType II
cDeletion of a co-packaged or referenced deviceType IA(IN)
dMinor change for a co-packaged device or referenced device that does not impact the delivery, quality, safety and/or efficacy of the medicinal product or the usability of the deviceType 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: Q.IV.1 covers devices co-packaged with or referenced by the product; a device integral to the primary packaging falls under Q.IV.2.

US FDA US Food and Drug Administration

21 CFR 314.70 and FDA guidance — 2004 Guidance §IX.B.3 (fn 20), §IX.C.1.a, Glossary 'Package' (by analogy) · 21 CFR 314.70(b)(2)(vi), (d)(2)(ix)

ChangeCategoryReference
Deletion of a co-packaged device where dosing instructions do not depend on it (How Supplied update only)Annual report21 CFR 314.70(d)(2)(ix)
Add/replace a measuring device where the user measures the dose (dosing cup, oral syringe, spoon, dropper)CBE-30 supplement2004 §IX.B.3 fn 20; §IX.C.1.a
Dose-controlling device or one integrated with the primary package (MDI valve/actuator, co-packaged spacer, pen or prefilled-syringe mechanism)Prior approval supplement21 CFR 314.70(b)(2)(vi); 2004 §IX.B.3
Non-certified device for veterinary productsNo US equivalent

Note: Co-packaged devices are classified like container closure components (Glossary 'Package'); a component is dose-controlling only when the system, not a person, meters the dose (§IX fn 20). Device certification does not lower the category. Combination products also fall under 21 CFR part 4; dosing-instruction changes follow the labeling categories. Veterinary products fall under FDA CVM rules (21 CFR 514.8).

Other items in II.5 Drug containing medical device

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.