Regulatory Pathways for Nanomedicine: Navigating FDA Combination Product Approvals

Understanding whether a magnetically guided drug-delivery nanorobot is classified as a drug, device, or combination product under 21 CFR Part 3.

Determining the Primary Mode of Action (PMOA)

Under FDA regulations, a product comprising a medical device (magnetic guidance system) and a pharmacological drug (chemotherapy payload) is classified based on its Primary Mode of Action (PMOA).

Cross-Center Review (CDER vs. CDRH)

If the primary therapeutic effect is achieved chemically, FDA CDER takes the lead with CDRH consulting on device safety, requiring both Investigational New Drug (IND) and device design controls.

Establishing Physicochemical Characterization Cascades

Sponsors must rigorously characterize particle size distribution, zeta potential, endotoxin contamination, and batch-to-batch reproducibility using standardized assays defined by the Nanotechnology Characterization Laboratory (NCL).

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