January 10, 2025
FDA releases final interim guidance on bulk drug substances for both 503As and 503Bs
STOP THE PRESSES! Earlier this week, the FDA released its final interim guidance for compounding using bulk drug substances — and it’s applicable to both 503A compounding pharmacies and 503B outsourcing facilities. This new guidance supersedes the 2017 versions of the same titles. If you haven’t reviewed the documents yet, you can access them here for some relaxing bedtime reading:
- Interim Policy on Compounding Using Bulk Drug Substances Under Section 503A of the Federal Food, Drug, and Cosmetic Act
- Interim Policy on Compounding Using Bulk Drug Substances Under Section 503B of the Federal Food, Drug, and Cosmetic Act
Key Takeaways
Too long? Not ready to read the whole thing? Here’s what’s changed and what you need to know:
- Category 1 substances remain usable
Bulk drug substances in Category 1 can continue to be used in compounding by both traditional pharmacies and outsourcing facilities. - Categories 2 and 3 have been eliminated
Importantly, the FDA has removed categories 2 and 3. While this does not affect compounding practices (substances in these categories were already prohibited from use in compounding), it underscores the FDA’s intent to streamline and clarify regulatory oversight. Compounders must recognize that substances formerly listed in categories 2 and 3 remain prohibited from use in any compounded preparations. - New nominations must go through the PCAC process
Newly nominated API will have to go through the PCAC process to be added to the official bulks lists going forward.