Generic Animal Drugs: Approved or Unapproved?
As used on this page, the term “unapproved animal drug” refers to a drug intended for use in animals that meets the definition of “new animal drug” in the Federal Food, Drug, and Cosmetic Act and does not have legal marketing status.
Generic animal drugs are not the same as unapproved animal drugs. Unlike unapproved animal drugs, generic animal drugs have gone through an FDA pre-market review and obtained legal marketing status. The pre-market review is integral to FDA’s ability to protect public health. During the review, the agency evaluates information submitted by the drug company to make sure the generic drug is safe and effective for its intended use and that the generic drug is properly manufactured and properly labeled.
Approval Process for Generic Animal Drugs
What is “marketing exclusivity”?
FDA gives “marketing exclusivity” to a drug company that gets a brand name animal drug approved. Starting on the date of approval, marketing exclusivity is the period of time during which FDA will not approve a generic copy of the approved brand name animal drug.
What are “exclusive marketing rights”?
“Exclusive marketing rights” apply to designated brand name animal drugs for minor species or minor uses in a major species (called “MUMS drugs”). FDA gives seven years of exclusive marketing rights to a drug company that gets a brand name MUMS drug designated and then approved, or conditionally approved. This means FDA cannot approve a generic copy or another brand name version for seven years from the date of approval, or conditional approval, of the designated brand name MUMS drug.
After a drug company’s patent, marketing exclusivity, or exclusive marketing rights for an approved brand name animal drug expire, another drug company can start the approval process for a generic copy. (The approved brand name animal drug is also called the “reference-listed new animal drug product” or the “pioneer” animal drug.) Rather than the full New Animal Drug Application process that a brand name animal drug goes through, a generic animal drug goes through the Abbreviated New Animal Drug Application (ANADA) process. The process is called “abbreviated” because the drug company doesn’t have to conduct new safety and effectiveness studies with the generic animal drug. The Generic Animal Drug and Patent Term Restoration Act (GADPTRA) established the approval process for generic animal drugs in 1988.
Quality and Performance
FDA requires a generic drug to have the same quality, performance, and intended uses as the brand name drug. Before marketing a generic animal drug, the drug company must prove to FDA that the generic copy is the same as the approved brand name animal drug in:
- Active ingredient;
- Dosage form; and
- Dosage regimen, including route of administration.
The drug company must also prove to FDA that the generic copy is bioequivalent to the approved brand name drug. This means that the generic drug is absorbed by and performs the same way in the animal’s body as the brand name drug.
Manufacturing and Labeling
What does “dosage form” mean?
The dosage form is the drug’s physical form when it comes out of the manufacturing facility. There are several categories of dosage forms, including oral and injectable. A drug given by mouth is an oral dosage form. Tablets and capsules are two types of an oral dosage form. A drug that is injected under the skin, into muscle, or into a vein is an injectable dosage form. A solution is a common type of an injectable dosage form.
What does “dosage regimen” mean?
The dosage regimen includes:
- How much of the drug to give (the dose);
- How often to give it (the frequency);
- How long to give it (the duration); and
- How to give it (the route of administration). Various routes of administration include injecting the drug under the skin, into muscle, or into a vein; giving the drug by mouth; or applying the drug topically to the skin.
FDA requires that the generic drug be manufactured under the same strict manufacturing standards as the brand name drug. The manufacturing processes for the generic copy must consistently produce a product that is equivalent to the brand name animal drug in identity, strength, purity, and quality.
The labeling for the generic copy must match the labeling for the approved brand name animal drug. The labeling may differ only in items that are specific to the generic drug, such as trade name, logo, and company name and address. For example, Heartgard® Tablets (Merial, Inc.) is the trade name of a brand name heartworm preventive. Iverhart™ Tablets (Virbac AH, Inc.) is the trade name of a generic copy.
Generic Name versus Generic Drug
A “generic name” is not the same as a “generic drug.” The term “generic name” refers to the drug’s established name, also called the active ingredient. In the heartworm preventive example above, the active ingredient in both Heartgard® Tablets and Iverhart™ Tablets is ivermectin. Ivermectin is the generic (established) name of the drug, but Iverhart™ Tablets is the generic drug.
Because unapproved animal drugs have not gone through an FDA pre-market review, there’s no way to know if these drugs are safe, effective, and quality manufactured. In contrast, FDA evaluates generic animal drugs before they are marketed to ensure they meet the agency's strict standards for safety and effectiveness and are properly manufactured and properly labeled.
Resources for You
The following FDA Web pages discuss generic drugs for people. Like a generic drug for animals, a generic drug for people is compared to a brand name drug, which is called the “innovator drug.” For animal drugs, the comparable brand name drug is called the “pioneer drug.” Despite this difference in terminology, the concepts generally apply to generic drugs for both people and animals:
- Understanding Generic Drugs
- Facts about Generic Drugs
- What are Generic Drugs?
- Generic Drugs: Questions and Answers