PDA Regulatory Commenting
Keeping abreast of regulations and requirements is an ongoing concern for the pharmaceutical manufacturing community. When new and updated guidance is published, PDA Members work together to provide feedback regarding the content of the draft documents, which include proposed regulations, technical guidance documents, inspection procedures, policy statements, Pharmacopoeia proposals, standards setting activities, and other related items developed by the global regulatory bodies (e.g. US FDA, EMA, WHO, USP, ANVISA). The contributions of PDA’s members ensure a broad industry perspective is presented and considered for inclusion or revision of the draft document. Below are the comments submitted by PDA on behalf of its members to a variety of global regulatory and pharmacopeial bodies. The documents are available for review to all PDA Members as a valuable reference for staying up to date on compliance-related topics and concerns.
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For more information or to suggest a topic for PDA commenting, please contact Carrie Horton, Regulatory Affairs Program Manager.
Comments Archive
2025 PDA Regulatory Comments
- PDA Comments to FDA 2025-D-6159 Postapproval Methods to Capture Safety and Efficacy Data for Cell and Gene Therapy Products 9 December 2025 (863 KB)
- PDA Comments to EMA Volume 4 GMP Chapter 1 Quality Systems 1 December 2025 (1155 KB)
- PDA Comments to USP 1113 Microbial Characterization, Identification and Strain Typing 26 November 2025 (695 KB)
- PDA Comments to USP 1117 Microbiological Best Laboratory Practices 26 November 2025 (1043 KB)
- PDA Comments to EMA on ICH M4QR2 Guideline on the Common Technical Document for the Registration of Pharmaceuticals for Human Use 24 October 2025 (939 KB)
- PDA Comments to EMA on Stakeholder Annex 11 EMA PICs 7 October 2025 final (997 KB)
- PDA Comments to EMA on Stakeholder Annex 22 EMA PICs 3 October 2025 (1254 KB)
- PDA Comments to EMA Stakeholders' Consultation on EudraLex Volume 4 GMP Chapter 4 Documentation 03 October 2025 (863 KB)
- PDA Comments to USP on 1029 Good Documentation Guidance for Data Integrity 30 September 2025 (1389 KB)
- PDA Comments to USP Chapter 1072 Disinfectants and Antiseptics 30 September 2025 (911 KB)
- PDA Comments to USP Chapter 1231 Water for Pharmaceutical Purposes 30 September 2025 (911 KB)
- PDA Comments to EMA on Guideline on the Quality Aspects of mRNA Vaccines 26 September 2025 (703 KB)
- PDA Comments to FDA-2022-D-2301 Small Volume Parenteral Drug Products and Pharmacy Bulk Packages for Parenteral Nutrition Aluminum Content and Labeling Recommendations 28 August 2025 (1020 KB)
- PDA Comments to FDA 2025-D-1106 ICH Q1 Stability Testing Drug Substances Drug Products 20 August 2025 (1493 KB)
- PDA Comments to EMA on ICH Q1 Stability Testing Drug Substances Drug Products 30 July 2025 (1416 KB)
- PDA Comments to USP-1037-PAT 29 July 2025 (957 KB)
- PDA Comments to EMA-INS-GMP-48771 Part IV Guidelines on GMP 30 June 2025 (607 KB)
- PDA Comments to EDQM PhEU 5.1.6 Alternative Methods for Control of Microbiological Quality 27 June 2025 (886 KB)
- PDA Comments to PhEU 2.6.14 Bacterial Endotoxins27 June 2025 (1245 KB)
- PDA Comments to NMPA-FGWJ-2025-127 Appendix of Sterile Drugs of the GMP for Drugs 30 May 2025 (668 KB)
- PDA Comments to USP 1110 Microbial Contamination Control Strategy Considerations 30 May 2025 (1248 KB)
- PDA Comments to USP 1114 Microbial Contamination Control Strategies for Cell Therapy Products 30 May 2025 (1175 KB)
- PDA Comments to FDA-2024-D-4689 Considerations for the Use of Artificial Intelligence to Support Regulaotry Decision-Making for Drug and Biological Products 2 April 2025 (754 KB)
- PDA Comments to FDA-2024-D-5374 Considerations for Complying with 21 CFR 211.110 - 2 April 2025 (496 KB)
- PDA Comments to FDA-2024-D-4488 AI-Enabled Device Software Functions 1 April 2025 (1364 KB)
- PDA Comments to Health Canada Health Product Shortage Directorate Regulations Amending Certain Regulations Made Under the Food and Drugs Act 8 March 2025 (299 KB)
- PDA Comments FDA 2024-N-0002 Best Practices for FDA Communication Draft Report 3 February 2025 (212 KB)