Comparison of post approval changes & requirements of US, Brazil & Mexico

  • Dharavi Patel Department of Pharma Regulatory Affairs, K.B. Institute of Pharmaceutical Education and Research, a constituent college of Kadi Sarva Vishwavidyalaya, Gandhinagar
  • Abhishek Patel DGM-RA, Intas Pharmaceuticals ltd, Ahmedabad
  • Zuki Patel Department of Pharma Regulatory Affairs, K.B. Institute of Pharmaceutical Education and Research, a constituent college of Kadi Sarva Vishwavidyalaya, Gandhinagar
  • Maitreyi Zaveri Department of Pharma Regulatory Affairs, K.B. Institute of Pharmaceutical Education and Research, a constituent college of Kadi Sarva Vishwavidyalaya, Gandhinagar

Abstract

Once the medicine’s regulatory authority (RA) in a given country has approved its commercialization, the manufacturer or market authorization holder (MAH) may recognize the need for adaption to a registered dossier and make similar suggestions. If the expected modifications are thought to affect the medicine’s quality, safety and efficacity, the responsible RA must provide their previous authorization. These modifications may take the form of administrative or chemical manufacturing and controls (CMC) tweaks. Through the submission of an operation known as a "post approval change submission," these variations are communicated to the relevant authority for review of the suggested changes. A change is described as "A modification in every aspect of a medicinal product. In that 3 countries classification of PAC based upon risk.  In USA, the Food and Drug Administration (FDA) provide four reporting categories for post-approval adjustments are provided under Section 506 A of the Federal Food, Drugs, and Cosmetic Act and 21 CFR 314.70. In Brazil, National Health Surveillance Agency ‐ ANVISA provide Resolution (RDC73/2016) for filing guidance of post approval change. In Mexico, Mexican health authority or COFEPRIS provide criteria to define the classification of modifications to the conditions of sanitary registry of medicines. In conclusion, USA well define and specific guideline for various type of change compare to Brazil and Mexico. While there are similarities in the post-approval filing categories between the USA, Brazil and Mexico, there are also differences in terminology, processes, timeline for approval and specific requirements. Understanding these similarities and differences is essential for companies seeking to market regulated products in 3 countries to ensure compliance with regulatory requirements and facilitate timely approvals. These timelines can vary based on the complexity of the submission and the type of product.

Keywords: CMC, SUPAC, FDA, Post Approval changes, ANVISA, COFEPRIS, MAH

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References

1. Gupta N.V, Lokesh M.S, Belagoankar B.D, Comparative Study of Process of Post Approval Change Application Submission and Approval for Marketing Authorization Variations in EU, US, India, Saudi Arabia and Singapore. Int. J. Drug Dev. & Res. 2015 Aug;7(1):10-22.
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https://www.fda.gov/regulatory-information/search-fda-guidance-documents/changes-approved-nda-or-anda
3. Ministry of Health, National Supplementary Health Agency
RESOLUTION RDC No. 73, OF APRIL 7, 2016-ANVISA [Internet]. Brazil : ANVISA; 2016 Apr 07 [cited 2025 Feb 05]. Available from:
https://bvsms.saude.gov.br/bvs/saudelegis/ans/2016/prt0073_07_04_2016.html
4. Guide on the Application of Criteria to be Observed for the Evaluation of the Certification of Good Manufacturing Practices for Drugs, Medications, Medical Devices and Primary Packaging Warehouses that Accompany Requests for Modifications, Extensions and Sanitary Registrations [Internet]. COFEPRIS;2020 Mar 06 [cited 2025 Feb 05]. Available from:
https://www.gob.mx/cms/uploads/attachment/file/539408/Guia_sobre_la_aplicacion_de_criterios_Certificacion_de_Buenas_Practicas_de_Fabricacion_ver._06_de_marzo_de_2020.pdf
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1.
Patel D, Patel A, Patel Z, Zaveri M. Comparison of post approval changes & requirements of US, Brazil & Mexico. Int J Drug Reg Affairs [Internet]. 2025Jun.15 [cited 2026Jan.31];13(2):1-. Available from: https://www.ijdra.com/index.php/journal/article/view/741