Regulatory Open Forum

 View Only
  • 1.  Annual report for OTC drugs

    Posted 09-Nov-2011 10:59
    Dear colleagues,

    Could someone advise me on post-marketing requirements for OTC drugs, namely, annual report.
    I realize that if OTC drug was approved under NDA or ANDA then those post-marketing requirements would apply, but what if OTC drug was approved under a monograph or under a citizen petition? Is there any requirement to submit AR?

    Thanks in advance!

    Sincerely,
    -------------------------------------------
    Elena Martsen
    Chapel Hill NC
    United States
    -------------------------------------------


  • 2.  RE:Annual report for OTC drugs

    Posted 10-Nov-2011 09:40

    An OTC product that complies with a monograph does not require an annual report.  You need to initially comply with the applicable monograph and then ensure that if there are changes that you still comply with the monograph. 

    Since there was no IND, NDA or ANDA submitted there is nothing to update from an Annual Report perspective.

    The OTC product must also comply with 21 CFR 201.66 which covers all OTC drug and drug-cosmetic products, whether marketed under a new drug marketing application (NDA), abbreviated new drug application (ANDA), or OTC drug monograph (or product not yet the subject of a final OTC drug monograph).

    Darlene
     
    -------------------------------------------
    Darlene O'Banion
    Regulatory QS
    San Jose CA
    USA
    -------------------------------------------