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Page 1: A note on Drug Master Filings - PHARMEXCILpharmexcil.org/uploadfile/ufiles/pxl-edigest/docs/2DMFs.pdf · company is claiming manufacturing drug and facility suitable for ... Facilities,

A note on Drug Master Filings

Page 2: A note on Drug Master Filings - PHARMEXCILpharmexcil.org/uploadfile/ufiles/pxl-edigest/docs/2DMFs.pdf · company is claiming manufacturing drug and facility suitable for ... Facilities,

Dynamics of Drug Master Filings at United States Food and Drug

Administration

Rau. B. S* and Dr. Appaji P. V

Patent Facilitation Center, Pharmaceuticals Export Promotion Council of India, 101,

Aditya Trade Centre, Hyderabad- 500 038, AP, India

Abstract

Drug master filing at USFDA in one of the parameters that helps in knowing the potentiality of a

country in the field of pharmaceuticals. Filing a drug master file at USFDA implies that the

company is claiming manufacturing drug and facility suitable for USFDA rules and regulations.

Several incidences are available where a company do have a USFDA approved facility but do

not have financial viability of the developed products. Patent Facilitation Center at Pharmexcil

of India believes that providing lead information to develop innovative products finally leads to

protection of intellectual property. The article mainly concentrates statistics relating to type II

drug master filing at USFDA since manufacturing drugs in USFDA approved facilities usually

comply global standards.

Introduction

As per the regulatory guidelines, it is mandatory to file a drug master file and after being

approved, releasing the drug into the market. A drug master file may be for a bulk drug or for a

formulation. A drug master file declared by the company provides in detail the manufacturing

place, physicochemical properties, pharmacodynamic/kinetic, toxicology studies of the bulk

drugs and formulations, therapeutic class, dosage form, strength, route of administration,

labeling, packaging etc. Filing a drug master file at USFDA by a company is an indication that

the company is claiming its capability in manufacturing and having a facility complying USFDA

rules and regulations.

Filing drug master files from countries other than United States, give a provision to the US

pharmaceutical organizations recommending foreign country facilities utilizing the manufactured

products upon approval by the USFDA authorities to market in United States.

It is necessary to understand DMF filings by pharmaceutical industries give an indication of

potential market both in terms of volume and value.

Drug master files are classified into five types by the USFDA and are as follows:

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Type I : Manufacturing Site, Facilities, Operating Procedures, and Personnel (no longer

applicable)

Type II : Drug Substance, Drug Substance Intermediate, and Material Used in Their

Preparation, or Drug Product

Type III : Packaging Material

Type IV : Excipient, Colorant, Flavor, Essence, or Material Used in Their Preparation

Type V : FDA Accepted Reference Information

At USFDA, DMF filings are classified as “I”-Inactive, “A”-Active, “N”-Not an assigned

number, “P”-DMF Pending Filing Review

Over view of DMF statistics

All DMFs-Status wise

As on 4th

quarter, 2011 a total of 25640 drug master files were filed at United States Food and

Drug Administration that includes all types. Figure 1 indicates that among all the types, 55

percent of the filings are inactive and 43 percent of the filings are active. The left over are in the

stage of review or not assigned with a number.

11027, 43%

14130, 55%

363, 1% 120, 1%

Figure 1: List of DMF filings at USFDA until 4th Quarter,

2011-Status wise

Active

Inactive

Not an assigned Number

Pending Filing Review

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All DMFs-Type wise

A study by type wise on the number of DMFs filed at USFDA indicates from table 1, figure 2

that a maximum of 59 percent of DMF filings is relating to type II that includes all types of

status. It has been observed that DMF filings of the type I are during the years 1941-2000

indicating that type I filings are withdrawn by the USFDA authorities.

Table 1: List of DMF filings at USFDA until 2011-Type wise

S.

No

Type Type

code

No. of

DMFs

1 Manufacturing Site, Facilities, Operating

Procedures, and Personnel (no longer applicable)

I 1826

2 Drug Substance, Drug Substance Intermediate,

and Material Used in Their Preparation, or Drug

Product

II 15230

3 Packaging Material III 4511

4 Excipient, Colorant, Flavor, Essence, or Material

Used in Their Preparation

IV 1749

5 FDA Accepted Reference Information V 355

6 Blanks Blanks 1969

Grand Total 25640

I

7%

II

59%

III

18%

IV

7%

V

1%

Blanks

8%

Figure 2: List of DMF filings at USFDA

until 2011-Type wise

I

II

III

IV

V

Blanks

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It is necessary to understand that type II filings have potential market since industries select

molecules that have potential market both in terms of volume and value.

Type II DMFs in Detail

Drug Master Filings under type II includes drug substance, drug substance intermediate, and

material used in their preparation, or drug product. When a study is made among the type II drug

master files, figure 3 indicates that among the 15230 type II DMFs filed, 51 percent of the filings

are active.

Type II DMFs Active-Global Scenario

It has been observed that a total of 57 countries have filed 7886 DMFs that are currently active.

The number of DMFs type II active is higher than mentioned in figure 3 due to the reason of

several DMFs belonging same company being manufactured in different countries.

When a study is made in terms of number of DMFs type II active, table 2 and figure 4 clearly

indicates an uptrend in filings to market the products in United States market. During the period

1956 to 2011, the number of filings ranging a minimum of 1 to a maximum of 766 is observed.

7811, 51%

7419, 49%

Figure 3: List of Type II DMFs filed at USFDA

-Active/Inactive wise

Active

Inactive

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Table 2: List of DMFs Type II Active at

USFDA

(Globally-Year wise-until 2011)

Year No. of

DMFs

Year No. of

DMFs

1956 1 1985 57

1957 2 1986 66

1959 1 1987 68

1960 2 1988 62

1961 1 1989 55

1962 1 1990 55

1963 2 1991 74

1964 4 1992 71

1965 3 1993 86

1967 4 1994 86

1968 4 1995 96

1969 6 1996 126

1970 3 1997 106

1971 6 1998 291

1972 10 1999 196

1973 6 2000 188

1974 9 2001 218

1975 12 2002 240

1976 17 2003 328

1977 16 2004 396

1978 23 2005 548

1979 29 2006 581

1980 34 2007 649

1981 43 2008 638

1982 46 2009 714

1983 55 2010 736

1984 49 2011 766

Grand

Total

7886

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Type II DMFs Active-Contribution of Top 20 Countries

Even though DMF filings at USFDA starts from the year 1940, currently type II DMF filings

that are active is from the year 1956 which is filed by a local company of United States. When a

study is made from 1956 for the DMFs type II that are still active, the first foreign country is

Mexico filing type II DMF in the year 1961.

Considering the currently available type II DMFs that are active, top 20 countries that still have

active DMFs (cumulative-until 2011) were considered and when compared their percentage

contribution to total type II DMFs active figure 5 indicates 95 percent contribution is from these

top 20 countries (including USA).

0

100

200

300

400

500

600

700

800

19

56

19

59

19

61

19

63

19

65

19

68

19

70

19

72

19

74

19

76

19

78

19

80

19

82

19

84

19

86

19

88

19

90

19

92

19

94

19

96

19

98

20

00

20

02

20

04

20

06

20

08

20

10

No

. of

DM

Fs T

ype

II A

ctiv

e

Year

Figure 4: List of DMFs Type II Active filed at USFDA

(Globally-Year wise-until 2011)

7486, 95%

400, 5%

Figure 5: Percentage Contribution of Top 20 Countries

in filing DMFs (Type II Active) at USFDA-Globally-

until 2011

Top 20 Countries

Rest

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When a study is made among the top 20 countries that have filed type II DMFs and active, table

3 and figure 6, India stands first with 2759 DMFs of the type II that are currently active with a

contribution of about 35 percent when compared to the total number of type II DMFs active .

Table 3: List of Countries Filed DMFs Type

II Active at USFDA - until 2011-Top 20

S.

No

Name of

Country

No. of

DMFs

Type II

Active

Filed

%

Contribution

Global

1 India 2759 34.99

2 USA 1323 16.78

3 China 870 11.03

4 Italy 644 8.17

5 Japan 270 3.42

6 Spain 268 3.40

7 Germany 266 3.37

8 France 170 2.16

9 Israel 170 2.16

10 Switzerland 136 1.72

11 Mexico 102 1.29

12 Canada 80 1.01

13 UK 65 0.82

14 The

Netherlands

64 0.81

15 Belgium 62 0.79

16 Hungary 61 0.77

17 Czech

Republic

50 0.63

18 Austria 47 0.60

19 Finland 40 0.51

20 Ireland 39 0.49

Sub Total

Top 20

7486 94.93

Grand Total 7886 100.00

Page 9: A note on Drug Master Filings - PHARMEXCILpharmexcil.org/uploadfile/ufiles/pxl-edigest/docs/2DMFs.pdf · company is claiming manufacturing drug and facility suitable for ... Facilities,

Type II DMFs Active - % yoy growth during 2007-2011

Considering the top 10 countries (based on cumulative type II DMFs active until 2011), when a

study is made in terms of number of type II DMFs active and filed by different countries yearly,

table 4, figure 7 indicates India standing first with 51.2 percent filings with 392 filings over a

total of 766 filings when compared to other countries for the year 2011.

Table 4: List indicative No. of DMF filings & % yoy growth at USFDA (2007-2011)-Top 10 Countries based on cumulative DMFs until 2011

Rank

(as a

whole-

cumulative

-2011)

Year/

Country

(Rank 2011)

2007 %yoy

2007

2008 %yoy

2008

2009 %yoy

2009

2010 %yoy

2010

2011 %yoy

2011

Grand

Total (as

a whole

cumulati

ve)

%yoy

Grand

Total

1 India (I) 302 46.5 342 53.6 345 48.3 353 48.0 392 51.2 2759 35.0

2 USA (II) 52 8.0 45 7.1 66 9.2 67 9.1 50 6.5 1323 16.8

3 China (III) 104 16.0 75 11.8 113 15.8 142 19.3 137 17.9 870 11.0

4 Italy (IV) 44 6.8 42 6.6 54 7.6 33 4.5 43 5.6 644 8.2

5 Japan (V) 18 2.8 16 2.5 21 2.9 9 1.2 17 2.2 270 3.4

6 Spain (VI) 15 2.3 15 2.4 13 1.8 17 2.3 20 2.6 268 3.4

7

Germany

(VII)

20 3.1 20 3.1 14 2.0 13 1.8 9 1.2 266 3.4

8

France

(VIII)

14 2.2 6 0.9 7 1.0 11 1.5 12 1.6 170 2.2

9 Israel (IX) 12 1.8 8 1.3 9 1.3 9 1.2 3 0.4 170 2.2

10

Switzerland

(X)

7 1.1 8 1.3 8 1.1 2 0.3 11 1.4 136 1.7

Grand Total 649 638 714 736 766 7886

0

500

1000

1500

2000

2500

3000

No

. o

f D

MF

s T

yp

e I

I

Acti

ve

Country Name

Figure 6: List of Countries Filed DMFs Type II Active-until 2011-Top 20

No. of DMFs

% Contribution Global

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Type II DMFs Active-India’s contribution year wise

Studies reveal that a total of 2759 type II DMFs are active until 4th

quarter 2011. Figure 8

reveals that type II DMFs are filed and active from India since 1984. The figure clearly

indicates an uptrend in filing type II DMFs which clearly indicates strength of Indian

pharmaceutical industry pioneering in manufacture of pharmaceuticals that comply to global

standards.

0.0

10.0

20.0

30.0

40.0

50.0

60.0

% y

oy

Gro

wth

Country Name (Rank)

Figure 7: List indicating No. of DMF filings-Type II active-

Top 10 Countries-based on % yoy growth

%yoy 2007

%yoy 2008

%yoy 2009

%yoy 2010

%yoy 2011

0

50

100

150

200

250

300

350

400

19

84

19

87

19

89

19

91

19

93

19

95

19

97

19

99

20

01

20

03

20

05

20

07

20

09

20

11

1 3

3

4

5

1 4

2 7

1 3 6 17

2

0

22

3

2

43

59

1

04

1

67

2

47

27

4 30

2 3

42

3

45

3

53

39

2

No

. o

f ty

pe I

I D

MF

s A

cti

ve

Year

Figure 8: List of Type II Active DMFs filed by Indian companies

at USFDA (until 2011-Year wise)

No. of DMFs

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Type II DMFs Active-India’s contribution Molecule wise-Top 10

It is observed that about 721 molecules either as base, salt, isomer, or intermediates are filed for

Drug master files from India as type II DMFs and are active. Figure 9, reveals that Cefuroxime

being filed maximum with 36 DMFs and Metoprolol, Pioglitazone, Telmisartan with 19 filings

each standing top 10th

among India filings. Among the 721 molecules that were filed, the

contribution of top 10 molecules is 10.3 percent.

Type II DMFs Active-India’s contribution Company wise-Top 10

When a study is made with relating to number of type II DMFs active with respect to company

wise, it has been observed that a total 225 companies have filed DMFs and are active. Figure 10,

reveals that Dr. Reddy’s Laboratories Limited with a maximum of 175 active DMFs while Ipca

Laboratories Limited with 10th

position of 67 active DMFs. It has been observed that 41 percent

contribution in type II DMFs active is by the top 10 companies.

0

5

10

15

20

25

30

35

40 36

28 28 26

24 23 22 21 20 19 19 19

1.3

0

1.0

1

1.0

1

0.9

4

0.8

7

0.8

3

0.8

0

0.7

6

0.7

2

0.6

9

0.6

9

0.6

9 No

. o

f D

MF

s

Molecule Name

Figure 9: List of Molecules filed by Indian Companies as type II

active DMFs until 2011

(includes base/salt/isomer/intermediate)-Top 10

DMFs

% Contribution amongst

Indian

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Type II DMFs Active-China’s contribution Molecule wise-Top 10

It is believed that China is the immediate competitor to Indian pharmaceutical industry and it is

observed that about 471 molecules either as base, salt, isomer, or intermediates are filed by

China as type II DMFs and are active. Figure 11, reveals that Clindamycin being filed maximum

with 17 DMFs and Chondroitin, Duloxetine, Granisetron with 6 filings each standing top 10th

among Chinese filings. Among the 471 molecules that were filed, the contribution of top 10

molecules is 12 percent.

020406080

100120140160180

17

5

15

4

14

8

11

7

10

3

97

95

94

85

67

6.3

4

5.5

8

5.3

6

4.2

4

3.7

3

3.5

2

3.4

4

3.4

1

3.0

8

2.4

3

No

. o

f D

MF

s

Company Name

Figure 10: List of Companies with Number of Type II DMFs

Active until 2011

(Excluding Sister Concern)

DMFs

% Contribution amongst

Indian

0

2

4

6

8

10

12

14

16

1817

11 11 10

9 8

7 7 7 6 6 6

1.9

5

1.2

6

1.2

6

1.1

5

1.0

3

0.9

2

0.8

0

0.8

0

0.8

0

0.6

9

0.6

9

0.6

9

No

. o

f D

MF

s T

yp

e I

I A

cti

ve

Drug

Figure 11: List of Molecules filed by Chinese Companies as type

II active DMFs until 2011

(includes base/salt/isomer/intermediate)-Top 10

DMFs

% Contribution amongst

Chinese

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Type II DMFs Active-China’s contribution Company wise-Top 10

When a study is made with relating to number of type II DMFs active with respect to company

wise, it has been observed that a total 277 companies have filed DMFs and are active. Figure 12,

reveals that Zhejiang Hisun Pharmaceutical Co Ltd., with a maximum of 43 active DMFs while

Chungwa Chemical Synthesis & Biotech Co Ltd., with 14 active DMFs. It has been observed

that 29 percent contribution in type II DMFs active is by the top 10 companies among Chinese

filings.

Type III DMFs Active-India’s contribution year wise

Out of a total of 2154 type III DMFs active, figure 13 reveals India’s contribution of 8 percent

which is very low. Figure 14, is a plot of number of type III DMFs that are active year wise and

it reveals that a maximum number of filings were made in the year 2008.

05

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3.5

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2.4

1

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8

1.8

4

1.8

4

1.8

4

1.6

1

No

. o

f D

MF

s

Ty

pe I

I A

cti

ve

Company Name

Figure 12: List of Top 10 Chinese companies

with Type II DMFs Active-Excluding Sister Concerns

(until 2011-Top 10)

DMFs

% Contribution amongst

Chinese

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Type IV DMFs Active-India’s contribution year wise

Out of a total of 868 type IV DMFs that are active, figure 15 reveals that India has filed 60

DMFs contributing to 7% which is very low. Figure 16 indicates year wise the number of type

IV DMFs that are active and it reveals that a maximum of 11 DMFs were filed in the year 2009.

Our studies reveal that USFDA has approved 3017 inactive ingredients for 11100

permutation/combination products specifying clearly for a particular dosage form with a

specified route of administration (419). Even though certain inactive ingredients come under the

category of fine chemicals, filings DMFs is very poor and Indian industry should emphasize on

such filings under the category.

India

8%

Rest

92%

Figure 13: Contribution of India in filing type III DMFs

active at USFDA-until 2011

India

Rest

0

10

20

30

40

50

19

95

19

99

20

00

20

02

20

03

20

04

20

05

20

06

20

07

20

08

20

09

20

10

20

11

1 1 1 2 1 6

19 18 21

41

22 17

22

No

. o

f D

MF

s ty

pe I

II A

cti

ve

Year

Figure 14: India's Contribution of type III DMFs

active-Year wise

No. of DMFs

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Among the type IV DMF filings, Associated Capsules Group has a major contribution of 24

DMFs.

Type V DMFs Active-India’s contribution year wise

Out of a total of 193 active DMFs, figure 17 reveals that India’s contribution is 5 percent.

Among the Indian filings, figure 18 indicates a maximum filing of 5 DMFs in the year 2009.

India, 60, 7%

Rest , 808, 93%

Figure 15: India's contribution of type IV DMFs active at

USFDA, until 2011

India

Rest

0

2

4

6

8

10

12

19

97

20

00

20

01

20

02

20

04

20

05

20

06

20

07

20

08

20

09

20

10

20

11

2

1 1 1

5

10

4

5

2

11

10

8

No

. o

f ty

pe I

V D

MF

s a

cti

ve

Year

Figure 16: India's contribution of type IV active DMFs at

USFDA, until 2011-year wise

No. of DMFs

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Conclusion

Pharmexcil believes that drug master filing at USFDA by companies is one selected key strategy

in identifying molecules interested by companies. Such molecules developed by companies can

be assumed are of demand both in terms of volume and economic viability of the product in

marketing in United States. It is necessary to understand by the industries to regularly monitor

drug master files at USFDA so as to develop forecast strategies. It is also necessary to

understand several of the drug master files are under administrative review. Accepting a drug

master file by USFDA under administrative grounds leads to inspections by the authorities both

at the facility and the production levels when required.

References

1. United States Food and Drug Administration

India, 9, 5%

Rest, 184,

95%

Figure 17: India's contribution of type V DMFs active

at USFDA-until 2011

India

Rest

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

5

2008 2009 2010 2011

2

5

1 1

No

. o

f ty

pe V

DM

Fs

acti

ve

Year

Figure 18: India's contribution of type V DMFs active at

USFDA, until 2011

No. of DMFs