Contact us

Thank you for your interest in Garg Law PLLC.

Our commitment to understanding your regulatory questions and business goals, and helping you achieve results starts here.

If you are looking for representation on a new matter, please fill out the form below to request a free consultation. The form enables us to conduct a preliminary check for potential conflicts of interest and to determine if we can proceed with the free consultation.

FDA Proposes Rule to Modernize Drug Manufacturing Registration

Proposed rule would streamline registration for advanced distributed manufacturers and increase visibility into foreign drug supply sources

The U.S. Food and Drug Administration today issued a proposed rule that, if finalized, would create a streamlined registration pathway for distributed manufacturing establishments that operate as a single establishment using a “hub-and-spoke” model. The proposed rule would also clarify registration requirements for certain foreign establishments that manufacture drugs, including active pharmaceutical ingredients, that indirectly enter the U.S. drug supply.

This action is another step forward in the FDA’s coordinated effort to help ensure Americans have reliable access to safe, quality medicines by strengthening domestic pharmaceutical manufacturing, and ensuring that regulatory frameworks keep pace with innovation.

Distributed manufacturing establishments operate using a “hub-and-spoke” model, with a central quality oversight hub and multiple equivalent manufacturing units at different locations. Currently, regulations require each manufacturing unit in such a network to register separately, creating unnecessary administrative burdens. Under the proposed rule, distributed manufacturing establishments could register as a single establishment. Units could be added, relocated or removed through a streamlined update process, and companies would be required to notify the FDA in advance of any unit relocation, closing a gap in the agency’s real-time oversight.

“The FDA is proposing changes to our establishment registration regulations that would reflect how distributed manufacturing actually works — as one single establishment,” said Michael Davis, M.D., Ph.D., Acting Director of FDA’s Center for Drug Evaluation and Research. “The proposed changes would make it easier for innovative manufacturers to operate efficiently, and give the FDA a clearer, more accurate picture of how and where drugs are being made.”

The proposed rule would also clarify registration and drug listing requirements for certain foreign drug manufacturing establishments. Currently, some foreign establishments that manufacture drugs (including components of drugs, such as active pharmaceutical ingredients) only for distribution to other foreign establishments may not be registered with the FDA, limiting the agency’s visibility into upstream supply chains. By aligning our regulations to the statutory requirements, this proposed rule would make it clearer that these establishments must register with the FDA and report on the drugs they produce, giving the FDA greater ability to detect and respond to potential safety concerns.

“When an active ingredient in a medicine reaches an American patient, the FDA should be able to trace exactly where it came from,” said Dr. Davis. “Closing this registration gap for foreign establishments is a concrete step toward increasing the supply chain transparency that patients deserve.”

If finalized, the proposed rule is expected to reduce registration costs for distributed manufacturing companies and generate long-term efficiencies for both industry and the agency. It builds on a series of administration actions aimed at revitalizing American pharmaceutical manufacturing, improving supply chain transparency, and reducing vulnerabilities in the drug supply chain.

The proposed rule is available here.

Request a Consultation

★★★★★

Working with Shelly on various new product launches over the last couple of years has been seamless. Quick and clear guidance is always what we get.
R.G. Client
I've been working with Shelly and her team at Garg law for a little while now and they are fantastic! Very responsive, professional and they certainly get things done. Extremely satisfied with their service and highly recommend.
Mike H. Client
Ms Garg helped my company navigate an FDA import issue. She achieved an excellent result, was very responsive and professional, and managed to keep the project within budget. She is a stellar attorney.
Dr. Sastry Client
I have been using Shelly Garg as FDA Counsel for 10+ years, since she was at another international law firm. While we continued to use the previous firm she was at (mainly due to the process required to change firms), we realized the quality of counsel was not the same. We have since been using Garg Law and the ease of use and trust in the knowledge was back instantly. Shelly has the skills to help me understand the regulations (by translating into layman's terms) and risks in a manner that is specific to my business. She is also extremely timely in her responses which is critical when we have a deadline mandated by the FDA. Many other attorneys cite the regulations which l've already read, but need further counsel. In my opinion, this demonstrates Shelly's in-depth knowledge of the regulations, how they pertain to the law, and how they are applicable IRL. Shelly's personable approach and pleasant manner in communication makes it very easy to have been work with her and have productive discussions on the best next steps. She truly has a passion iternational for all things FDA and I've learned so much from her.
Claire P. Client

News & Insights

Get the latest news on FDA regulatory delivered straight to your inbox.