Regulatory PathRegulatory requirements compared

SFDA item 55 · III. Safety, efficacy, pharmacovigilance changes

Change in the summary of product characteristics, labeling and patient information leaflet of a generic/hybrid/biosimilar medicinal product following assessment of the same change for the reference product *.

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 55 — official PDF, p. 67 ↗

VariantChangeType
-Implementation of change(s) for which no new additional data are submitted by the MAHType IB

Conditions to be fulfilled and documentation to be supplied: see the official guideline, item 55.

EU European Union

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

C.2 · Change(s) in the summary of product characteristics, labelling or package leaflet of a generic/hybrid/biosimilar medicinal products following assessment of the same change for the reference product

VariantChangeType
aImplementation of change(s) for which no new additional data is required to be submitted by the holderType IB
bImplementation of change(s) which require to be further substantiated by new additional data to be submitted by the marketing authorisation holder (e.g. comparability)Type II

US FDA US Food and Drug Administration

21 CFR 314.70 and FDA guidance — 21 CFR 314.70(c)(6)(iii)(A),(E) · 2004 Guidance §X.A, §X.C

ChangeCategoryReference
Copy an approved RLD safety change (new or strengthened contraindication, warning, precaution or adverse reaction)CBE-0 supplement21 CFR 314.70(c)(6)(iii)(A); 2004 §X.C
Copy other approved RLD labeling revisions where FDA directs submission under the CBE provisionCBE-0 supplement21 CFR 314.70(c)(6)(iii)(E)

Note: ANDA labeling must stay the same as the RLD's (2004 §X.A: consistent with section 505(j)). In FDA's generic-drug practice, RLD-conforming updates are submitted as CBE-0 supplements, and an ANDA holder cannot use CBE-0 to depart from the RLD. Biosimilars (351(k) BLAs) follow 21 CFR 601.12(f).

Other items in III. Safety, efficacy, pharmacovigilance 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.