Regulatory Guidance on Grouped Submissions: FDA, EMA, PMDA
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Regulatory submissions play a critical role in bringing new drugs and medical devices to market, and any strategy that streamlines this process is highly sought-after. Grouped submissions offer a potential solution by allowing manufacturers to combine related regulatory information or applications for multiple products or variations within a single package submitted to health authorities. However, the specific rules and regulations governing grouped submissions vary significantly across different regions. This blog delves into the regulatory guidance on grouped submissions provided by the FDA (U.S. Food and Drug Administration), EMA (European Medicines Agency), and PMDA (Pharmaceuticals and Medical Devices Agency, Japan).

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Understanding Grouped Submissions: Benefits and Considerations

Grouped submissions offer several potential benefits for manufacturers, including:

  • Reduced administrative burden: Combining information for multiple applications into a single submission can significantly reduce the time and resources needed for preparation and filing.
  • Improved efficiency: By streamlining the submission process, manufacturers can potentially expedite the review process by regulatory agencies, leading to faster product approvals.
  • Consistency: When identical changes are proposed for multiple products, grouped submissions can ensure consistency in the information presented to regulators.

However, there are also important considerations to keep in mind:

  • Regulatory agency variations: As mentioned earlier, the rules for grouped submissions differ between regulatory bodies, requiring a tailored approach for each region.
  • Submission complexity: While grouped submissions can simplify applications for identical changes, the process can become more complex for variations that differ across products.
  • Expertise is key: Navigating the intricacies of grouped submissions requires a thorough understanding of relevant regulations and experience in dealing with specific regulatory agencies.

Understanding Grouped Submissions Across Regulatory Landscapes

Here's a closer look at the approaches taken by the FDA, EMA, and PMDA:

1. FDA (U.S. Food and Drug Administration):

The FDA allows grouped submissions under specific circumstances. Notably, their "Grouped Submissions" policy permits manufacturers to submit a single supplement for changes affecting multiple applications if the changes are identical and relate to Chemistry, Manufacturing, and Controls (CMC).

Key Considerations:

Applicable for identical CMC changes across multiple products with existing applications.

Specific guidance documents outlining procedures for such grouped supplements are available from the FDA's Center for Drug Evaluation and Research (CDER) and Center for Biologics Evaluation and Research (CBER).

2. EMA (European Medicines Agency):

The EMA employs a concept called "work-sharing" that shares similarities with grouped submissions. This procedure is relevant when identical or similar changes or extensions are proposed for multiple products already authorized within the European Union (EU).

Key Considerations:

Work-sharing applies to variations (modifications) proposed for multiple EU-authorized products.

The EMA's "Procedural advice for users of the centralized procedure for human medicines" provides specific guidance on submitting grouped variations for multiple products.

3. PMDA (Pharmaceuticals and Medical Devices Agency):

While the PMDA in Japan doesn't have a direct equivalent term for "grouped submissions," the agency allows for simultaneous submissions of related applications.

Key Considerations:

The PMDA offers procedures for handling combined applications, even if the terminology differs.

Consult the PMDA's guidance on application submissions for drugs, medical devices, and regenerative medicine products to understand how to handle related submissions.


Grouped submissions can be a powerful tool for streamlining regulatory submissions in the pharmaceutical and medical device industries. However, navigating the intricacies of regional regulations and ensuring successful applications require a deep understanding of relevant policies and potentially, the expertise of regulatory professionals. Leveraging grouped submissions further amplifies these benefits, facilitating a more efficient and effective approval process. To optimize Regulatory processes and gain a competitive edge, reach out to Freyr and Get tailored Regulatory solutions with expert guidance in your journey toward compliance.


Sonal Gadekar