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For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

  • 1.  For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 05-31-2025 12:28
      |   view attached

    FDA released on Friday a draft guidance on "Replacing Color Additives in Approved or Marketed Drugs" for comment (attached). Comments are due to the FDA by 29Jul25. 

    AAPS will be providing comments on the guidance, and Ketaki Patwardhan and I will be compiling the feedback from the Excipients Community.  

    Please review the draft guidance and send your comments to [email protected] and [email protected] before the end of June so that they can be compiled with the feedback from the other AAPS Communities.

    Thank you,

    Bruno Hancock



    ------------------------------
    Bruno Hancock Ph.D., FAAPS
    Partner
    Aleurites LLC
    Westerly RI
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------


  • 2.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 06-02-2025 16:18

    Glad you will be coordinating the comments Bruno and Ketaki. Although this guidance provides some flexibility for companies who want to replace a color with another one (CBE-30 vs PAS), the timing of this guidance is a bit suspect with what RFK Jr. and Dr. Makary have been saying recently about the synthetic FD&C colors. 

    One can only hope that this guidance doesn't mean they will actually be trying to ban the synthetic colors since there is absolutely no scientifically credible justification for doing this.  Most natural colors don't have the stability, consistency and other properties to be adequately used in pharma applications and any attempt at reformulation of drug products will probably lead to reduced expiration dates , second class quality and major drug shortages.  I think these points need to be highlighted in the comments that will be submitted. I would be glad to help with your efforts on this. 



    ------------------------------
    David Schoneker
    President/Owner/Consultant
    Black Diamond Regulatory Consulting, LLC
    Lansdale PA
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------



  • 3.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 06-02-2025 16:34
    Hi Dave,

    Thanks for your perspective. Please email us your comments in the first instance.

    If there is enough interest we will set up a call with the Excipient Community to discuss these new guidelines.

    Cheers,

    Bruno

    (Please excuse typos - big fingers & tiny keyboard!).




  • 4.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 06-03-2025 07:48

    All, on this comment, "If there is enough interest we will set up a call with the Excipient Community to discuss these new guidelines." I am interested in having a call. 



    ------------------------------
    Shahrzad Missaghi
    Senior Manager, Product Development
    Colorcon
    Harleysville PA
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------



  • 5.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 06-05-2025 13:00
    Hi there,

    Is there an Excipient Community monthly meeting slot coming up where we could have a discussion of the new FDA guidelines on "Replacing Color Additives in Approved or Marketed Drugs"?  I think the members of the community would appreciate the chance to discuss the new guidelines.

    I don't have any community meetings in my calendar currently, but I recall we had monthly meetings (on Thursdays) in 2024.

    Thanks,
    BCH_signature short version.png


    Bruno Hancock

    https://www.linkedin.com/in/brunohancock/

    Begin forwarded message:






  • 6.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 06-06-2025 10:45
    I recommend that we set up a meeting specifically to discuss the color guidance this month. I don't think would be time for me to present on the color topic overall and still have time to discuss the guidance. Let's meet this month to talk about the guidance and then I can do a presentation next month as planned which will go significantly beyond this guidance. 

    Regards,

    Dave

    Sent from my mobile device. 

    On Jun 6, 2025, at 8:09 AM, Jin Zhao <[email protected]> wrote:

    

    Internal



    IMPORTANT NOTICE: This email is from a legacy IFF.com email address associated with a former IFF business that was recently divested. The sender is no longer an employee of IFF or its affiliates and the use of this email by the sender is for a limited time and transitional purposes. The content of this email is not authorized by, or known to, IFF. The sender is now an employee of Roquette. Please use the sender's new email address at Roquette for any future communications.



    Hi Ketaki,

    I agree.  Please use my new email address: [email protected] in the future communications.

    Best Regards,

    Jin

    Internal






  • 7.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Community Leadership
    Posted 06-06-2025 12:59


    Agree.
    Jin Zhao, Ph. D
    Pharmaceutical Excipients R&D 
     Roquette
    ______ 
    Office Number: +1 517-273-3376
    Cell Phone Number: +1-989-859-9279 
    1801 Larkin Center Dr. 
    Larkin Laboratory 
    Midland, MI 48642 
    USA 






  • 8.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Community Leadership
    Posted 06-06-2025 16:01
    We should invite Richard Creekmore and Kevin Hughes from IPEC Europe. We spoke about the guidance at the USP Convention meeting. The USP Excipients team would like to be a part of the conversation as well. We can schedule a meeting and see who responds and attends from the invite.  Excipients in the supply chain was also highlighted from this topic.

    On Fri, Jun 6, 2025 at 10:44 AM David Schoneker <[email protected]> wrote:
    I recommend that we set up a meeting specifically to discuss the color guidance this month. I don't think would be time for me to present on the color topic overall and still have time to discuss the guidance. Let's meet this month to talk about the guidance and then I can do a presentation next month as planned which will go significantly beyond this guidance. 

    Regards,

    Dave

    Sent from my mobile device. 

    On Jun 6, 2025, at 8:09 AM, Jin Zhao <[email protected]> wrote:

    

    Internal



    IMPORTANT NOTICE: This email is from a legacy IFF.com email address associated with a former IFF business that was recently divested. The sender is no longer an employee of IFF or its affiliates and the use of this email by the sender is for a limited time and transitional purposes. The content of this email is not authorized by, or known to, IFF. The sender is now an employee of Roquette. Please use the sender's new email address at Roquette for any future communications.



    Hi Ketaki,

    I agree.  Please use my new email address: [email protected] in the future communications.

    Best Regards,

    Jin

    Internal






  • 9.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 06-09-2025 10:01
    Hi Allison,
    We can certainly invite Richard and Kevin if you would like.  I'm not sure what you meant about "Excipients in the supply chain was also highlighted from this topic" as it relates to this new FDA guidance document about replacing color additives.  Are you referring to the fact that there is not enough natural colors available in the world to replace the synthetic colors that are used or what are you referring to here?
    Regards,
    Dave


    ------------------------------
    David Schoneker
    President/Owner/Consultant
    Black Diamond Regulatory Consulting, LLC
    Lansdale PA
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------



  • 10.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Community Leadership
    Posted 06-24-2025 15:38

    Hi Dave,

    Apologies for the late response.  For clarification, I had separate conversations with @Richard Creekmore, Kevin and @Catherine Sheehan where there may not be enough natural colors to replace the synthetic colors.

    This month we will not have a monthly presentation. On June 26 from noon to 1pm EDT, we will use this time for members to share their thoughts on the recent guidance on color additives. @Ketaki Patwardhan and @Bruno Hancock will represent Excipient Community in the AAPS Regulatory Response Committee created for this guidance. We will channel collective community thoughts back to the Regulatory Response Team which then will be added to the formal response from AAPS.

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    AAPS Excipient Community Leadership Team

     

    ________________________________________________________________________________

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    Join the meeting now

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    Allison Radwick Ph.D.
    Sr Regulatory & Policy Comms Mgr
    USP
    East Fallowfield PA
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
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  • 11.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Posted 06-26-2025 11:11

    Thank you for setting up this meeting. It's such an important topic. Could it be recorded for those who cannot attend?

    @Ketaki Patwardhan or @Bruno Hancock 

    Many thanks,

    Shahrzad



    ------------------------------
    Shahrzad Missaghi
    Senior Manager, Product Development
    Colorcon
    Harleysville PA
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------



  • 12.  RE: For your feedback: Draft FDA Guidelines on "Replacing Color Additives in Approved or Marketed Drugs"

    Community Leadership
    Posted 06-27-2025 08:59

    Hello Shahrzad,

    From my previous experiences I have learnt that its tricky to share recording due to IT policies of various companies. Good news is that we have captured detailed notes that we will share with everyone on the teams invite. 

    -Ketaki  



    ------------------------------
    Ketaki Patwardhan Ph.D.
    Principal Scientist
    Kenvue
    Bridgewater NJ
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------