Vol 82 – Strategies and Considerations for Effective CMC Submissions of Combination Products

August 23, 2023The Pathfinder 35 Min Read

One of the most enlightening experiences I recently had was engaging in a detailed conversation with an FDA reviewer. We delved into the complexities of developing combination products, a subject that often comes up in my interactions with clients and industry colleagues. The FDA reviewer’s perspective shed invaluable light on the critical CMC (Chemistry, Manufacturing, and Controls) strategies and considerations that play a pivotal role in the success of these innovative healthcare solutions. Here’s a synthesis of our discussion, encompassing essential elements such as design control, manufacturing validation, analytical testing, regulatory compliance, and post-marketing surveillance. 

Combination products, consisting of two or more regulated components, such as drug/device, biologic/device, drug/biologic, or drug/device/biologic, have revolutionized healthcare. They offer innovative and targeted treatment options but bring complex challenges, particularly in CMC. 


Understanding the Complexity 


Combination products are unique in integrating various components that must work synergistically. The design, production, and quality control of each element are essential to the product’s overall safety and efficacy.  

Strategies: Identify the primary mode of action to determine regulatory oversight. Perform a comprehensive risk assessment early in development. 


Example: Development of a Drug-Eluting Stent 

A company developing a drug-eluting stent faced challenges in defining the primary mode of action, requiring a meticulous approach to assessing both the device and the drug. 


IND Submission: 

  • Comprehensive description of the drug component, including its formulation, stability, and pharmacokinetics. 
  • Details of the stent material, design, and manufacturing process.  

NDA Submission: 

  • Integrated summary of the entire product, including clinical efficacy, safety data, and risk assessment. 
  • Full-scale manufacturing information, including validation and quality control protocols. 


Regulatory Landscape 

The regulatory pathway for combination products can be labyrinthine, and aligning with the appropriate guidelines is crucial.  

Strategies: Understand the regulations specific to each component. Engage with regulatory authorities early in the process, particularly the FDA if marketing in the United States. Consider guidance on Orphan Drugs Designation, Fast Track, Break-through Therapy, Accelerated Approval, ANDA, and 505(b)(2) submissions. 


Example: Insulin Pump with Integrated Glucose Monitor 

This case required alignment with regulations governing both medical devices and biologics. 


IND Submission: 

  • A clear definition of the regulatory classification of the product. 
  • Detailed information on insulin formulation and glucose monitoring technology.  

NDA Submission: 

  • Complete clinical data integration, manufacturing processes, and quality control measures. 
  • Documentation on post-marketing surveillance strategies. 


Manufacturing Considerations 

Manufacturing combination products requires an integrated approach that ensures consistency and reliability.  

Strategies: Implement robust process validation protocols. Ensure the manufacturing process complies with Good Manufacturing Practices (GMP). Focus on scale-up and technology transfer considerations. 


Example: Combination Inhaler for Asthma Treatment 

The development of a combination inhaler required consistent manufacturing of drug and device components. 


IND Submission: 

  • Detailed description of the manufacturing process for the drug and the inhaler device. 
  • Protocols for ensuring product uniformity and reproducibility.  

NDA Submission: 

  • Comprehensive manufacturing validation data. 
  • Scale-up considerations and technology transfer protocols. 


Analytical and Stability Testing 

Analytical methodologies and stability testing are vital for establishing the quality attributes of the combination product.  

Strategies: Develop analytical methods that are sensitive to the specific characteristics of both the device and the therapeutic component. Establish a stability program that encompasses real-time and accelerated stability studies. 


Example: Antibody-Drug Conjugate for Cancer Treatment 

The development of this product necessitated extensive analytical testing of both the antibody and the conjugated drug. 


IND Submission: 

  • Analytical methods specific to both components, including stability testing. 
  • Protocols for assessing the conjugation efficiency and integrity.  

NDA Submission: 

  • Detailed stability program outcomes, including real-time and accelerated studies. 
  • Summary of all analytical validation data. 


Clinical Development and Post-Marketing Surveillance 

Clinical trials and post-marketing surveillance are integral for demonstrating safety and effectiveness.  

Strategies: Design clinical trials that reflect the unique nature of combination products. Implement a rigorous post-marketing surveillance plan to monitor long-term safety and efficacy.  

Combination products are at the forefront of medical innovation but require intricate strategies and a robust understanding of CMC considerations. Emphasizing a holistic approach that integrates design, manufacturing, regulatory compliance, and post-marketing surveillance is crucial for success. Engaging with seasoned experts in the field, who are adept at navigating these complexities, can be the pivotal factor that turns potential pitfalls into pathways for innovation. 


Example: Wearable Drug Infusion Pump 

This case required a unique approach to clinical development and post-marketing surveillance due to its nature as a wearable device. 


IND Submission: 

  • Clinical trial design that considered both the device functionality and drug delivery. 
  • Early-phase safety assessments, including device-related adverse events.  

NDA Submission: 

  • Integrated summary of clinical efficacy and safety specific to the combination product. 
  • A robust post-marketing surveillance plan, including pharmacovigilance strategies for device-related issues.

Combination products are an intricate blend of diverse components, and their development demands a comprehensive understanding of CMC considerations. These case studies exemplify the complexities in preparing IND and NDA submissions. Integrating precise regulatory strategy, manufacturing control, analytical acumen, and clinical oversight is paramount. Collaboration with experts who can navigate these multifaceted requirements can significantly streamline the development process, fostering innovation and ensuring patient safety. 


Strategies and Considerations for Combination Products  

Design Control and Integration 

  • Strategy: Implement robust design controls that ensure seamless integration of components (e.g., drug/device, biologic/device). 
  • Considerations: Compatibility, risk assessment, functionality, and user requirements. 

 “One of the most popular questions I get is” 

“What are the critical CMC strategies and considerations for developing combination products?” This question resonates strongly in today’s pharmaceutical landscape, where innovation drives the integration of drugs, biologics, and devices into groundbreaking therapies.  

The marriage of different components in combination products requires meticulous design control. Compatibility, risk assessment, and user requirements must be thoroughly addressed. For example, in developing drug-eluting stents, the customized design ensures controlled drug release while maintaining the stent’s mechanical properties. 


Manufacturing Process Development and Validation 

  • Strategy: Develop a manufacturing process considering drug and device components, ensuring quality and reproducibility. 
  • Considerations: Scalability, validation protocols, technology transfer, and Good Manufacturing Practices (GMP) compliance.  

“One of the most popular questions I get is” 

Manufacturing combination products is not a simple task. It involves a well-coordinated process that ensures quality, scalability, and reproducibility. In the case of an insulin pump with an integrated glucose monitor, rigorous manufacturing validation was essential to ensure seamless synchronization between insulin delivery and glucose sensing. 


Analytical Testing and Stability Studies 

  • Strategy: Implement analytical methods specific to combination products, encompassing both stability and functionality. 
  • Considerations: Sensitivity to all components, real-time and accelerated stability studies, and quality attributes.  

“One of the most popular questions I get is.” 

Quality control in combination products extends beyond conventional testing. It requires analytical methods sensitive to all components, including stability and functionality. Developing a combination inhaler for asthma treatment demanded comprehensive stability programs to assess both active pharmaceutical ingredients’ compatibility with the device. 


Regulatory Compliance and Alignment 

  • Strategy: Align with relevant regulations and guidances specific to combination products. 
  • Considerations: Regulatory classification, regional differences, and submissions strategy (IND, NDA).  

“One of the most popular questions I get is.” 

The regulatory landscape for combination products is complex. Understanding and aligning with the relevant regulations and guidances is paramount. Regulatory compliance isn’t just about following rules; it’s about demonstrating the safety and efficacy of the product to regulatory authorities. 


Post-Marketing Surveillance and Lifecycle Management 

  • Strategy: Establish a comprehensive post-marketing surveillance plan, including both drug and device components. 
  • Considerations: Pharmacovigilance, device vigilance, and lifecycle management strategy. 

 “One of the most popular questions I get is” 

Once a combination product reaches the market, the work doesn’t stop. Establishing a comprehensive post-marketing surveillance plan and lifecycle management strategy is vital. Continuously monitoring real-world feedback ensures that any potential issues are addressed promptly. 


Guidances that Cover the Requirements 


For Combination Products in General:  

  • FDA Guidance on Combination Products: The U.S. FDA’s Office of Combination Products (OCP) provides guidance documents specific to the regulatory pathways for combination products. 
  • 21 CFR Part 4: Regulation for Current Good Manufacturing Practice Requirements for Combination Products.  

For the IND Submission:  

  • 21 CFR Part 312: Regulations concerning the IND application process, outlining specific requirements for the submission. 
  • ICH Guidance M3(R2) on Nonclinical Safety Studies: Provides details on nonclinical safety study requirements. 
  • FDA Guidance on CMC Information for Human Gene Therapy INDs: Specific to gene therapy products. 
  • FDA Guidance on Content and Format of INDs for Phase 1 Studies: Specifics on CMC information for early-phase studies.  

For the NDA Submission: 

  • 21 CFR Part 314: Regulations concerning the NDA process, including details on the required content and format. 
  • ICH Guidance Q8, Q9, Q10: Quality guidelines providing principles on pharmaceutical development (Q8), quality risk management (Q9), and pharmaceutical quality systems (Q10). 
  • FDA Guidance on CMC Postapproval Manufacturing Changes: Guidance for postapproval changes in manufacturing procedures. 
  • FDA Guidance on Providing Regulatory Submissions in Electronic Format: Specifics on the format and structure of electronic submissions.  

Region-Specific and International Guidance: 

  • European Medicines Agency (EMA) Guidelines: For products marketed in the European Union, EMA guidelines will apply. 
  • International Conference on Harmonisation (ICH) Guidelines: ICH guidelines are often harmonized across different regulatory bodies and can be applicable globally. 


The guidance and regulations governing the submission of content for combination products are vast and multifaceted, reflecting the complex nature of these innovative healthcare solutions. Understanding and aligning with these guidances is paramount for successful submissions. Engaging with regulatory experts specializing in the field can provide invaluable support in navigating these requirements, ensuring compliance, and facilitating the development process. 


Case Studies 


Case Study 1: Development of a Drug-Eluting Stent 

Challenge: Integration of a cardiovascular stent with a specific drug to prevent restenosis.  

CMC Strategy: 

  • Design Control: Customized design to ensure controlled drug release. 
  • Manufacturing Validation: Rigorous validation to ensure uniform coating. 
  • Regulatory Alignment: Compliance with guidance specific to drug-eluting stents.  

Outcome: Successful NDA submission and commercialization. 


Case Study 2: Insulin Pump with Integrated Glucose Monitor 

Challenge: Developing an insulin pump that synchronizes with a glucose monitoring system.  

CMC Strategy: 

  • Design Integration: Ensuring compatibility between insulin delivery and glucose sensing components. 
  • Analytical Testing: Development of robust testing methods for both insulin stability and device functionality. 
  • Lifecycle Management: Continuous monitoring and updates based on real-world feedback.  

Outcome: Effective management of patient diabetes through precise insulin delivery. 


Case Study 3: Combination Inhaler for Asthma Treatment 

Challenge: Integration of two different active pharmaceutical ingredients (APIs) in a single inhaler device.  

CMC Strategy: 

  • Manufacturing Process Development: Ensuring consistent dosing of both APIs. 
  • Stability Studies: Comprehensive stability program to assess both APIs’ compatibility with the device. 
  • Regulatory Compliance: Alignment with specific regulations for combination inhalers.  

Outcome: Innovative product offering targeted therapy for asthma patients. 

Combination products present exciting opportunities for innovation but come with unique CMC challenges. By adopting strategies that consider design, manufacturing, analytical testing, regulatory alignment, and lifecycle management, developers can navigate these complexities. The case studies illustrate the practical application of these strategies, emphasizing the importance of a holistic and integrated approach. 

Collaborating with experts well-versed in the CMC considerations for combination products can provide critical support throughout the development lifecycle, ensuring compliance and fostering innovation. 




Reflecting on my conversation with the FDA reviewer, it becomes clear that developing combination products is not merely a technical endeavor. It’s a multifaceted journey that requires an intricate balance of innovation, compliance, quality, and continuous improvement. The insights shared by the reviewer underscore the importance of a well-orchestrated strategy guided by scientific rigor and regulatory wisdom.  

As the landscape of combination products continues to evolve, these CMC considerations will remain at the core of success, driving the potential to transform patient care and advance medical science. Engaging with regulatory experts, such as those within the FDA, can offer a rich understanding that supports innovation while ensuring patient safety. The journey of combination product development is both challenging and rewarding, and this conversation was a profound reminder that collaboration, understanding, and diligence are crucial to unlocking its immense potential.  

The development of combination products is a fascinating yet intricate process. From design integration to lifecycle management, each stage requires specialized knowledge and a holistic approach. The case studies above illustrate how these strategies are applied in real-world scenarios.  

As more combination products emerge, understanding and implementing effective CMC strategies cannot be overstated. For those looking to innovate in this space, embracing these considerations could be the key to unlocking the next wave of medical breakthroughs. 

Upcoming Event

Oct 22


October 22-25, 2023 

Orlando, FL, USA

Orange County Convention Center

The Pathfinder

The latest in biotech for your ears

The VirtualPharm Podcast is an audio series that covers topics related to compliance and regulatory affairs in the Lifesciences industry. Each episode, hosted by an expert in the topic with decades of experience, offers listeners detailed insight into the changing regulatory environment.

Subscribe to the Pathfinder

    Lets discuss your product