【EXPERT Q&A】What are the major steps in an FDA application?

March 18, 2026  Source: drugdu 41

Drugdu.com expert's response:

 

The steps for FDA application can be summarized into the following core stages, taking into account the commonalities and differences among product types (food, drugs, medical devices, etc.). The specific process is as follows:

I. Preliminary Preparation: Clarify Product Classification and Regulatory Requirements

1. Determine Product Classification

Food: Classified into general food, special food (e.g., infant food), dietary supplements, etc. Some require FCE/SID registration (e.g., low-acid canned food).

Drugs: Classified into new drugs (NDA), generic drugs (ANDA), biological products (BLA), etc., with different application paths for each category.

Medical Devices: Classified into Class I (low risk), Class II (medium risk), and Class III (high risk) based on risk level, determining the application type (e.g., 510(k), PMA).

2. Confirm Regulatory and Standard Requirements

Comply with regulations such as the Federal Food, Drug, and Cosmetic Act (FDCA) and the Medical Device Amendments.

Reference international standards (e.g., ISO 13485, IEC 60601) and FDA guidelines to ensure technical documents meet requirements.

II. Company Registration and Account Creation

1. Obtain a DUNS Number

Apply for a globally unique identification number from Dun & Bradstreet for FDA registration.

2. Create an FDA Electronic Account

Visit FDA electronic portals (e.g., FURLS, ESG) to register a company account and designate a U.S. Agent responsible for communication.

3. Company Registration

Fill in company information (name, address, contact details, etc.) and submit registration proof (e.g., business license).

Food: Register through the FFRS system, valid for two years, requiring regular updates.

Drugs/Medical Devices: List products in the FDA device registration system to indicate sales intent.

III. Prepare Application Materials

Prepare the following core documents based on product type:

1. Product Information

Detailed description (specifications, intended use, ingredients, production process, etc.).

Technical documents (design drawings, manufacturing process, quality control measures).

2. Safety and Effectiveness Evidence

Drugs: Provide chemical composition, pharmacological data, clinical trial results (NDA/BLA), or comparative data (ANDA).

Medical Devices:

Class II: Submit a 510(k) document demonstrating substantial equivalence to a legally marketed device.

Class III: Submit a PMA application including comprehensive clinical data.

Food: Provide ingredient safety assessments and a HARPC food safety plan (a preventive control plan based on risk analysis).

3. Labels and Instructions

Comply with FDA requirements, including product name, manufacturer information, usage instructions, warning information, allergen declaration (for food), etc.

Labels must be in English, with clear fonts, and must not contain false or misleading descriptions.

4. Quality Management System Documents

Such as ISO 9001 and ISO 13485 certification documents, demonstrating compliance with hygiene and quality standards in the production process.

5. Other Documents

Inspection reports (e.g., sterilization validation reports, material composition test reports).

Shelf life and storage condition descriptions (for food/drugs).

IV. Submit Application and Pay Fees

1. Choose Submission Method

Submit online through FDA electronic submission systems (e.g., eSubmitter, ESG) or mail paper documents (in some cases).

2. Pay Fees

Fees vary depending on product type and application complexity (e.g., drug NDA fees may reach millions of dollars, while food registration fees are relatively low).

Payment must be made at the time of submission; otherwise, the application is invalid.

V. FDA Review and Communication

1. Preliminary Review

FDA checks the completeness of the application. If materials are missing or do not meet requirements, a supplement notice will be issued (usually within a few weeks).

2. Technical Evaluation

Drugs/Medical Devices: Experts review clinical data, performance test results, risk assessments, etc.

Food: Review the HARPC plan, label compliance, and ingredient safety.

3. On-site Inspection (Optional)

FDA may conduct on-site inspections of production facilities to confirm compliance with GMP (for drugs/medical devices) or FSMA (for food) requirements.

4. Communication and Feedback

During the review process, FDA may request further explanations or supplementary materials via email or phone, requiring timely responses.

VI. Approval and Registration

1. Obtain Approval

If the application meets requirements, FDA issues an approval letter or registration number (e.g., drug NDA approval number, food facility registration number).

Medical Devices: After obtaining 510(k) clearance or PMA approval, the product can be legally sold.

2. Market Access

After completing registration, product information will be listed in FDA databases (e.g., NDC directory, medical device list).

Compliance with FDA's subsequent regulatory requirements (e.g., adverse event reporting, regular updates of registration information) is necessary.

VII. Post-market Surveillance

1. Compliance Maintenance

Regularly update company and product information (e.g., food registration every two years).

Follow label and advertising regulations to avoid misleading consumers.

2. Adverse Event Reporting

Report serious adverse reactions or device malfunctions for drugs/medical devices and safety issues for food.

3. Market Supervision

FDA may conduct product sampling inspections, and companies need to retain production records for review.

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By editor
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