Variations TGA

Variations to prescription medicines
– excluding variations requiring

evaluation of clinical or
bioequivalence data
Appendix 1: Variation types – chemical entities
Version 3.1, January 2020

Therapeutic Goods Administration
Copyright
© Commonwealth of Australia 2020
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Variations to prescription medicines – excluding variations requiring evaluation of clinical or Page 2 of 128
bioequivalence data; Appendix 1: Variation types – chemical entities
V3.1 January 2020
Contents
Introduction ___________________________________ 6
Data supporting variation requests _________________________________________ 7
Index of variation types – chemical entities _________ 8
1. Corrections, notifications and quality information
changes _____________________________________ 23
1.1 Active Pharmaceutical Ingredient (API) changes ______________ 23
1.1.1 Changes that do not require reporting to the TGA -------------------- 23
1.1.2 Notifications --------------------------------------------------------------------- 24
1.1.3 Category 3 requests – Data evaluation required under s.9D(3) --- 33
1.2 Drug product manufacture changes - method, batch size or
equipment ____________________________________________________________________ 36
1.2.1 Correction to, or completion of, an ARTG entry ------------------------ 36
1.2.2 Notifications --------------------------------------------------------------------- 37
1.2.3 Self-assessable requests (SARs) -------------------------------------------- 42
1.2.4 Category 3 requests - Data evaluation required under s. 9D(3) --- 43
1.3 Drug product - site of manufacture changes ____________________ 45
1.3.1 Changes that do not require prior approval ---------------------------- 45
1.3.2 Notifications --------------------------------------------------------------------- 45
1.4 Drug product formulation changes ______________________________ 52
1.4.2 Self-assessable requests (SARs) that create a separate and distinct good
(s. 23) 53
1.4.3 Category 3 requests - Data evaluation required under s. 23 (separate and
distinct good) – Retaining AUST R number ----------------------------------------- 55
1.4.4 Category 3 requests — Data evaluation required under s. 23 (separate
and distinct good) – New AUST R number------------------------------------------- 58
1.5 Drug product specifications or test changes ____________________ 61
1.5.1 Notifications --------------------------------------------------------------------- 61
1.6 Excipients changes__________________________________________________ 66
1.6.2 Notifications --------------------------------------------------------------------- 66
1.7 Container/closure system changes ______________________________ 71
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1.7.3 Notifications --------------------------------------------------------------------- 72
distinct good) – New AUST R number ------------------------------------------------ 80
1.8 Pack size changes ___________________________________________________ 81
1.9 Product shelf life or storage conditions changes _______________ 83
1.10 Product information (PI) changes: Quality aspects, corrections and
self-assessable requests (SARs) ___________________________________________ 86
1.11 Product label changes ______________________________________________ 91
1.11.2 Notifications --------------------------------------------------------------------- 92
1.11.4 Category 3 requests - Data evaluation required under s. 9D(3) -- 105
distinct good) – Retaining AUST R number ---------------------------------------- 105
1.12 Other changes ______________________________________________________ 106
1.12.1 Correction to, or completion of, an ARTG entry ----------------------- 106
1.12.2 Self-assessable requests (SARs) ------------------------------------------- 109
1.12.3 Category 3 requests - Data evaluation required under s. 9D(3) -- 110
1.13 Associated changes ________________________________________________ 111
1.13.1 Changes associated with DFCI and DFFC -------------------------------- 111
1.13.2 Changes associated with DFCF and DTTR------------------------------- 112
1.13.3 Changes associated with DFNA and PCCT ------------------------------- 116
2. Product information (PI) changes __________ 120
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2.1 Product information (PI) changes: Minor editorial changes and

safety-related requests (SRRs)____________________________________________ 120
2.1.1 Minor editorial changes to the product information under s. 9D(3)120
2.1.2 Safety-related requests (SRRs) -------------------------------------------- 121
2.2 Extension of indications __________________________________________ 122
2.2.1 Extension of indications to align with a reference product -------- 122
2.3 Associated changes to product information (PI) ______________ 125
2.3.1 Changes associated with PIES ---------------------------------------------- 125
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Introduction
The Therapeutic Goods Administration (TGA) takes a risk-based approach to assessing
variations to prescription medicines. This means that the higher the risk associated with the
variation, the greater the level of assessment required by the TGA before a decision can be made.
This guidance outlines the following types of variations and changes that can be made to
chemically derived (non-biological) prescription medicines currently on the Australian Register
of Therapeutic Goods (ARTG) and is split into two parts:
Part 1: Corrections, notifications and quality information changes
• Changes that do not require prior approval. These are:
- changes that can be implemented without informing the TGA
- changes that can be implemented before you inform the TGA of the change.
• Corrections to an ARTG entry – a minor change to correct or complete information that was
inadvertently recorded incorrectly or omitted in the ARTG entry, including the product
information (PI).
• Notifications – very low risk variations with specific conditions. TGA approval for these
variations is made automatically upon lodgement and payment of the application fee. The
applicant must provide legal assurances that all conditions are met and submit supporting
data using the approved electronic form.
• Self-assessable requests (SARs) - lower risk variations for which the sponsor can provide an
assessment of their own data for the TGA to verify, including to the PI.
• Category 3 requests - variations that require evaluation of quality-related data only. These
variation types are intended as representative types, where a summary of the exact changes
being requested is included the cover letter. Includes changes to quality aspects of the PI.
Part 2: Product information (PI) changes
• Minor editorial changes to product information (MEC).
• Safety related requests (SRRs) – requests to either reduce the patient population that can
receive the medicine or add a warning or precaution.
• Extension of indications to align with a reference product.
Category 1 applications are not covered by this guidance. These require evaluation of a full
dataset, or any combination of quality, nonclinical, clinical and bioequivalence data. See the
Prescription medicines registration process for information on how to lodge a Category 1
application.
See also:
• Variations to prescription medicines – excluding variations requiring evaluation of clinical or
bioequivalence data; Process guidance.
• For changes to biological medicines see Variations to prescription medicines – excluding
variations requiring evaluation of clinical or bioequivalence data; Appendix 2: Variation
types – biological medicines.
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Data supporting variation requests

The conditions outlined within each variation type set out the minimum documentation
required for regulatory purposes, but depending on the particular circumstances surrounding
the change, additional data may be needed. Additional data may also be required to meet Good
Manufacturing Practice.
Refer to each type of variation for full data requirements.
V3.1 January 2020
Index of variation types – chemical entities

Variation Description Variation Requires update
type category to ARTG data 1
Part 1: Corrections, notifications and quality information changes
Active Pharmaceutical Ingredient (API) changes
API and intermediate manufacture - alternative Does not

site of quality control testing require
reporting to
the TGA
Ingredients - change to contact details of the Does not

local handling agent (including material of require
biological origin) reporting to
the TGA
ACCS API container - changes to container/closure Notification

system of a non-sterile API
ACEP API Certificate of Suitability (CEP) - a revision Notification

for a non-sterile API that is not a synthetic
polypeptide or prepared by fermentation
AMBS API and intermediate manufacture - change to Notification

batch size of a non-sterile API (existing site)
AMCS API site of manufacture - cessation Notification Manufacturers
AMIT API and intermediate manufacture - addition, Notification

revision or deletion of in-process control tests
and limits
AMMC API and intermediate manufacture - minor Notification

manufacturing changes not involving
sterilising steps (existing site)
AMMF API starting material/intermediate site of Notification

manufacture - change to/addition of (for APIs
manufactured by multi-step syntheses or
fermentation)
AMTA API site of manufacture - transfer of/addition Notification Manufacturers

to an existing manufacturer's site of a non-
sterile API that is not prepared by fermentation
1 Also referred to as data within the Provisional ARTG Record (PAR) field
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ASAM API/starting material/intermediate Notification

specifications - changes to non-biological test
methods for assay and/or residual solvents
(including water)
ASDR API re-test period and storage conditions - Notification

decrease to re-test period and/or more
restrictive storage conditions
ASID API/starting material/intermediate Notification

specifications - changes to identification tests
ASNL API/starting material/intermediate Notification

specifications - narrowing of limits
ASNT API/starting material/intermediate Notification

specifications - addition of new test and limit
ASPC API specifications - changes to physicochemical Notification

test methods and limits
ASPT API specifications - amendments resulting Notification

from pharmacopoeial or Therapeutic Goods
Order (TGO) changes
ADSL Shelf life - Changes to the retest period of the Category 3

active pharmaceutical ingredient
AMAS API manufacture - changes to the site(s) of Category 3 Manufacturers

manufacture
AMCM API manufacture - changes to the synthetic Category 3

route or the manufacturing process
ASCS API specifications - changes to the Category 3

specifications of the active pharmaceutical
ingredient, including changes to test methods
Drug product manufacture changes - method, batch size or equipment
CAMC Correct an ARTG entry - manufacture Correction Manufacturers
DMBS Drug product manufacture - changes to batch Notification

size for products that are not modified release
dosage forms
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DMEL Drug product manufacture - changes to Notification

manufacturing method and/or equipment of
semi-solid/liquid dosage forms that are not
modified release
DMEO Drug product manufacture - changes to Notification

oral/nasal inhalation dosage forms that are not
modified release
DMES Drug product manufacture - changes to Notification

manufacturing method and/or equipment for
solid dosage forms that are not modified
release
DMIT Drug product manufacture - changes to in- Notification

process control tests and limits
DMRO Drug product manufacture - reduction or Notification

removal of API and excipient overages for
ingredients that are not antioxidants or similar
DMSE Drug product manufacture - changes to Notification

sterile dosage forms that are not modified
release
DMDS Drug product manufacture - changes to SAR Visual

dimensions, shape, inked imprint, embossing Identification
or debossing of solid dosage forms
DMCM Drug product manufacture – changes to the Category 3

method of manufacture
Drug product - site of manufacture changes
Report Manufacturing - change to manufacturer’s Requires

separately name or the manufacturing address, provided reporting to
the actual site location does not change the TGA but
not prior
approval
DMDM Drug product site of manufacture - cessation of Notification Manufacturers

a site or deletion of a manufacturing step
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DMPL Drug product site of manufacture - change to Notification Manufacturers

site of labelling/primary packaging (non-
sterile products) or labelling/secondary
packaging
DMSL Drug product site of manufacture - change to Notification Manufacturers

site of manufacture of non-sterile semi-
solid/liquid dosage forms that are not modified
release
DMSO Drug product site of manufacture - change to Notification Manufacturers

site of manufacture of non-sterile oral/nasal
inhalation dosage forms that are not modified
release
DMSS Drug product site of manufacture - change to Notification Manufacturers

site of manufacture of non-sterile solid dosage
forms that are not modified release
DMTR Drug product site of manufacture - change to Notification Manufacturers

site performing testing and release for supply
DMCS Drug product site of manufacture - changes to Category 3 Manufacturers

the site(s) of manufacture
Drug product formulation changes
CAAO Correct an ARTG entry - animal origin Correction Formulation
CAFC Correct an ARTG entry - formulation Correction Formulation
DFCI Formulation - addition or deletion of, or SAR - Formulation

variation to, an inked imprint separate &
distinct
good
DFFC Formulation - change relating to colouring SAR - Formulation

agent, flavour or fragrance separate &
distinct
good
DFCF Formulation – changes (CE) – Retaining AUST Category 3 - Formulation

R number separate &
distinct
good –
Retaining
AUST R
number
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DFNA Formulation – changes (CE) – New AUST R Category 3 - Formulation

number separate &
distinct
good – New
AUST R
number
Drug product specifications or test changes
DSAM Drug product specification - changes to non- Notification

biological assay method for an active or
excipient that is not a radiopharmaceutical
DSID Drug product specification - changes to Notification

identification tests for the active or excipient
DSIP Drug product specification - changes from an Notification

in-house test method to a pharmacopoeial test
method
DSNL Drug product specification - narrowing of test Notification

limits
DSNT Drug product specification - addition of test Notification

and limit
DSPL Drug product specification - minor changes to Notification

physicochemical test methods and limits
DSPT Drug product specification - changes resulting Notification

from pharmacopoeial or TGO requirements
DSST Drug product specification - changes to sterility Notification

test method
DSCS Drug product specifications - changes to Category 3

specifications, including changes to test
methods
Excipients changes
Excipients (not of animal or human origin) - Does not

changes to the manufacturing process and/or require
site (same specifications) reporting to
the TGA
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EMRS Excipient manufacture (from Category IC Notification Formulation

ruminant tissues) - changes in source (from
animal to non-animal) and/or manufacturing
process or site
ESAM Excipient specification - change to assay Notification

method
ESIP Excipient specification - change from an in- Notification

house to a pharmacopoeial test method
ESNL Excipient specification - narrowing of limit Notification
ESNT Excipient specification - new test and limit Notification
ESPT Excipient specification - changes resulting from Notification

pharmacopoeial or TGO requirements
ESCS Excipient specification – changes to the Category 3

specifications of the excipients, raw materials
and starting materials
EMPC Excipients of animal origin – change to source Category 3 Formulation
EMPM Excipients of animal origin – change to method Category 3

of manufacture
Container/closure system changes
Non-sterile container - changes to the supplier Does not

or manufacturer if same material and require
specifications reporting to
the TGA
CACI Correct an ARTG entry - container information Correction Container & Shelf
Life
CCCA Container/closure - change to components Notification
CCSS Container/closure - change to size and shape Notification

for non-sterile dosage forms
CCST Container/closure - changes to specification Notification

and test methods
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CMDT Container/closure material - decrease in Notification

thickness for blister packs, strip packs and
sachets for non-sterile solid or semi-solid
dosage forms
CMIT Container/closure material - increase in Notification

thickness for non-sterile solid, semi-solid,
semi-liquid or liquid dosage forms
CMBP Container/closure material - changes to SAR Container & Shelf

material used for blister packs, strip packs and Life
sachets of non-sterile dosage forms
CMBT Container/closure material - changes to SAR Container & Shelf

material used for bottles, jars and tubes of non- Life
sterile dosage forms
CCSC Container/closure system - changes to Category 3 Container & Shelf

container components and/or dimensions Life
PCCT Packaging - changes to container type – New Category 3 - Container & Shelf
AUST R number separate & Life
distinct
good – New
AUST R
number
Pack size changes
CAPS Correct an ARTG entry - pack size & poison Correction Pack Size & Poison
schedule Schedule
PSAC Pack size - addition or change to pack size SAR Pack Size & Poison
excluding volume of fill of injections or other Schedule
sterile preparations
PSCA Pack size - change to, or addition of, pack size Category 3 Pack Size & Poison
Schedule
Product shelf life or storage conditions changes
CASL Correct an ARTG entry - shelf life / storage Correction Container & Shelf
condition Life
DSLD Shelf life - decrease and/or more restrictive SAR Container & Shelf
storage conditions Life
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DSLE Shelf life - extension according to an approved SAR Container & Shelf
stability-testing protocol Life
DSLC Shelf life - changes to the shelf life or storage Category 3 Container & Shelf
conditions of the drug product. Life
Product information (PI) changes: Quality aspects, corrections and self-assessable

requests (SARs)
CAPI Correct an ARTG entry – Product Information Correction

(PI)
PIAE PI - adding the names of excipients in the SAR

product
PICA PI - adding the Chemical Abstracts Service SAR

(CAS) number, molecular formula/weight
and/or chemical structure/nomenclature of
the API
PIPD PI - changing the PI of radiopharmaceuticals to SAR

give instructions that the patient dose should
be measured immediately before
administration
PIPS PI - changing the name, address or other SAR

details of the product’s sponsor or distributor
PIRI PI - changing the PI of radiopharmaceuticals to SAR

give instructions/information on radiation
protection and safety of user and patient
PISR PI - putting into effect the guidelines in section SAR

20.2 of Guidance 20: Radiopharmaceuticals
PICC PI - changes to quality aspects of the product Category 3

information
Product label changes
Changes to labels that do not require reporting Does not

to the TGA. require
reporting to
the TGA
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LOCI Label - consequential change resulting from a Notification

change approved under subsection 9D(3) or
conditions imposed under subsection 28(3)
LPCL Label - addition or deletion of, or change to, the Notification

company logo or livery
LPCP Label - addition or deletion of, or change to, the Notification

pictogram of a product or its dosage form
LPCS Label - addition or deletion of, or change to, the Notification

name or address of the Australian sponsor or
supplier of the product
LPDG Label - deletion of existing graphics, pictures or Notification

diagrams, and any associated text
LPDR Label - deletion of repeated text (present Notification

elsewhere on a label) from selected side panels
provided that the information is not mandatory
LPIA Label - addition of simple Notification

instructional/informational/anti-tampering
statements, or information about a changed
appearance of the dosage form
LPOP Label - addition or deletion of, or change to, Notification

label text of outer protective pouches or
overwraps of the container or primary pack
LPPS Label - adding information either on label or as Notification

insert advising of patient support program
(PSP)
LPQR Label - inclusion of QR code Notification
LPRP Label - removal of phrases such as ‘New Notification

formulation’, ‘New appearance’ after a period
of time.
LQAE Label - addition of excipients Notification
LQAT Label - amendment of expression of API Notification

content in topical preparations as previously
approved
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LQHI Label - addition of 'hypotonic', 'hypertonic' and Notification

'isotonic' for large-volume injections
LQRT Label - addition of a previously approved Notification

release rate for transdermal patches
LWAH Label - addition of a warning or cautionary Notification

statement where an incorrect route for method
of administration is hazardous
LWSR Label - changes to/addition of a warning or Notification

precaution statement resulting from an
approved safety-related variation to the PI
LOAI Label - addition of a new TGA-approved route SAR

of administration for injectable medicines
LOCA Label - changes as a result of approved SAR

corrections made to an entry in the ARTG
LOCN Label - change to names of actives, excipients SAR

or dosage forms resulting from changes in the
AAN, ingredients database or code tables in
TGA eBS
LOEI Label - changes to the method of expressing the SAR

content of active ingredients or excipients, in
accordance with the current labelling TGO
LOPR Label - changes as a result of product SAR

rescheduling (following from changes to the
Poisons Standard)
LOPS Label - amendments due to implementation of SAR

changes that do not require prior approval
from the TGA
LOSA Label - amendments resulting from the SAR

implementation of a SAR that is either
submitted simultaneously or has been
previously approved by the TGA
LOTG Label - changes to comply with current TGOs SAR

for labels that have previously been evaluated
and approved by the TGA
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LPCO Label - addition/deletion of, or change to, the SAR

statement of country of origin or manufacture
for imported products
LPDL Label - changes to the colour, design or layout SAR

of labels with no change to content and
retaining differentiation of strengths
LPSP Label - change to the layout or design of a SAR

physician sample pack
LPWS Label - addition or deletion of, or change to, the SAR

website address of an Australian owned and
managed company
LCDE Label changes - any changes requiring Category 3

evaluation
DTTR Trade name replacement – Retaining AUST R Category 3 - Good Name

number separate &
distinct
good –
Retaining
AUST R
number
Other changes
CADF Correct an ARTG entry - dosage form Correction Dosage Form
CAGN Correct an ARTG entry - good name Correction Good Name
CAIC Correct an ARTG entry - indications Correction Indications
CANC Correct an ARTG entry - ATC Nordic codes Correction ATC Nordic Codes
CAQI Correct an ARTG entry - quality-related Correction

information, includes labels
CARA Correct an ARTG entry - route of Correction Route of

administration Administration
CASI Correct an ARTG entry - sterility information Correction Sterility

Information
CAVI Correct an ARTG entry - visual identification / Correction Visual

product description Identification
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OCPS Medicines and poisons - change in scheduling SAR Pack Size & Poison
Schedule
SARO Other self-assessable changes - an application SAR

using this type must include written advice
from the TGA
OCQD Other quality changes that do not create a Category 3

separate and distinct good
Associated changes (to be used when one variation requires multiple PAR fields to be
updated)
Changes associated with formulation changes - DFCI and DFFC
ZFSM ARTG data - Manufacturer changes associated SAR Manufacturers

with DFCI or DFFC
ZFSV ARTG data - Visual identification changes SAR Visual

associated with DFCI or DFFC Identification
Changes associated with formulation change - DFCF or new name - DTTR
ZFRC ARTG data - Container and shelf life changes Category 3 - Container & Shelf
associated with DFCF/PFCF or DTTR - separate & Life
Retaining AUST R number distinct
good –
Retaining
AUST R
number
ZFRM ARTG data - Manufacturer changes associated Category 3 - Manufacturers

with DFCF/PFCF or DTTR - Retaining AUST R separate &
number distinct
good –
Retaining
AUST R
number
ZFRN ARTG data - Good name changes associated Category 3 - Good Name
with DFCF/PFCF - Retaining AUST R number separate &
distinct
good –
Retaining
AUST R
number
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ZFRO Other consequential changes to the dossier Category 3 -

associated with DFCF/PFCF or DTTR – separate &
good –
Retaining
AUST R
number
ZFRP ARTG data - Pack size and poison schedule Category 3 - Pack Size & Poison
changes associated with DFCF/PFCF or DTTR - separate & Schedule
good –
Retaining
AUST R
number
ZFRS ARTG data - Sterility changes associated with Category 3 - Sterility

DFCF/PFCF or DTTR - Retaining AUST R separate & Information
number distinct
good –
Retaining
AUST R
number
ZFRV ARTG data - Visual identification changes Category 3 - Visual

associated with DFCF/PFCF or DTTR - separate & Identification
good –
Retaining
AUST R
number
Changes associated with formulation change - DFNA or packaging change - PCCT
ZFNC ARTG data - Container and shelf life changes Category 3 - Container & Shelf
associated with DFNA/PFNA - For the new separate & Life
AUST R number distinct
good – New
AUST R
number
ZFNM ARTG data - Manufacturer changes associated Category 3 - Manufacturers

with DFNA/PFNA or PCCT - For the new AUST separate &
R number distinct
good – New
AUST R
number
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ZFNN ARTG data - Good name changes associated Category 3 - Good Name
with DFNA/PFNA or PCCT - For the new AUST separate &
R number distinct
good – New
AUST R
number
ZFNO Other consequential changes to the dossier Category 3 -

associated with DFNA/PFNA or PCCT - For the separate &
new AUST R number distinct
good – New
AUST R
number
ZFNP ARTG data - Pack size and poison schedule Category 3 - Pack Size & Poison
changes associated with DFNA/PFNA or PCCT - separate & Schedule
For the new AUST R number distinct
good – New
AUST R
number
ZFNS ARTG data - Sterility changes associated with Category 3 - Sterility

DFNA/PFNA or PCCT - For the new AUST R separate & Information
number distinct
good – New
AUST R
number
ZFNV ARTG data - Visual identification changes Category 3 - Visual

associated with DFNA/PFNA or PCCT - For the separate & Identification
new AUST R number distinct
good – New
AUST R
number
Part 2: Product information (PI) changes
Product information (PI) changes: Minor editorial changes and safety related requests
(SRRs)
PIME PI - make minor editorial changes MEC
PIID PI - remove an indication with data SRR Indications
PIIN PI - remove an indication - no data SRR Indications
PIOD PI – make safety related changes with data SRR
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PION PI - make safety related changes no data SRR
Extension of indications to align with a reference product
PIES Extension of specific indications to align with a Extension of Indications

reference product indications
to align with
a reference
product
Associated changes to PI (to be used when one variation requires multiple PAR fields to
be updated)
Changes associated with extension of indications - PIES
PIEP Additional pack sizes resulting from extension Extension of Pack Size & Poison
of indications to align with a reference product indications Schedule
to align with
a reference
product
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1. Corrections, notifications and quality

information changes
The Variation e-form for prescription medicines has four category groups which are described in
Variations to prescription medicines – excluding variations requiring evaluation of clinical or
bioequivalence data; Process guidance:
• Correct an ARTG entry
• Notification
• Quality information
• Product information (PI).
Part 1 of this guidance describes the changes that can be made within the corrections,
notifications and quality information category groups. This includes changes to the quality
aspects of the PI, corrections to the PI and self-assessable requests (SARs) related to PI
information.
For changes that can be made within the product information (PI) category including minor
editorial changes, safety related requests and extension of indications to align with a reference
product see Part 2: Product information (PI) changes.
1.1 Active Pharmaceutical Ingredient (API) changes
1.1.1 Changes that do not require reporting to the TGA

These changes can be implemented without reporting to the TGA. This does not include any
proposed changes that require a consequential change to the approved product information of
the registered medicine.
API and intermediate manufacture - alternative site of quality control

testing
You do not need to inform the TGA if you are making a variation to the quality control testing
site of the API or intermediate in API manufacture.
Module 3 should be updated to reflect the new alternative site when the next variation is
submitted to the TGA. Refer to Evidence of GMP compliance for prescription medicines for
information about when you are required to provide evidence of GMP.
Conditions
• The new site must be GMP compliant.
• There must not be any changes to the existing test methods used for testing the API.
Data requirements
• You must generate appropriate technology transfer data of the approved test methods to the
proposed site.
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Ingredients - change to local handling agent contact details (including

material of biological origin)
You do not need to inform the TGA if you are making a variation that changes the contact details
of the local handling agent for the API and excipient. This includes material of biological origin.
Conditions
• Same site and method of manufacture, specifications and, where applicable, biological
source, including geographical origin and supplier.
1.1.2 Notifications
These variations fall under s. 9D(2C) of the Therapeutic Goods Act 1989.
Conditions that are outlined below the description of each variation type must be met for the
request to be processed as a notification.
ACCS: API container - changes to container/closure system of a non-sterile

API
Changes to the container or closure system used to store a non-sterile API.
Conditions
• The API must not be sterile.
• The material of the container/closure must be either unchanged or is changed to a more
protective material.
• The thickness of the material must be either unchanged or increased.
• There must either be no change in retest period/storage conditions, or a decrease in retest
period and/or more stringent storage conditions are applied in the new container/closure
system.
Data requirements
You must submit:
• Details of the new container/closure system.
• Details of the new retest period or storage conditions, if changed.
You must generate the following:
• Relevant comparative moisture permeability data for the current and proposed material
demonstrating either equivalent or better moisture protection.
• Initial stability testing data of the API in the new container/closure system conducted in
accordance with relevant stability testing guidelines.
ACEP: API Certificate of Suitability (CEP) - a revision for a non-sterile API

that is not a synthetic polypeptide or prepared by fermentation
This covers all changes to the data package of the API that have been reviewed by the European
Directorate for the Quality of Medicines and Healthcare (EDQM) where the EDQM subsequently
issued a revised Certificate of Suitability (CEP), or have declared that a revised CEP is not
required.
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Conditions
• The API must not be manufactured wholly or substantially by fermentation.
• The API must not be a synthetic polypeptide.
• The API must not be manufactured as a sterile drug substance.
• The current CEP must have been approved previously by the TGA.
• The revised CEP must be the next issued version from that approved by the TGA. Additional
consecutive updates can only be included:
- they follow the 5-year renewal (with no other changes) and/or
- the changes are for minor administrative updates and/or
- the drug substance has not been used to manufacture any drug products supplied in
Australia.
• Where changes to the API specification are involved (including test parameters, limits and
test methods), the same changes must be adopted by the product sponsor and/or drug
product manufacturer, and any new test methods must be validated as suitable for use.
• Where the change to the CEP is a change to the site of API manufacture, the site must have
either:
- a licence to manufacture the API (if the site is in Australia) or
- sponsor-specific GMP clearance (if the site is overseas) that is valid at the time of the
application.
Data requirements
You must submit:
• Documentary evidence that the current CEP has been previously approved by the TGA.
• The updated CEP, including any annexes, or a declaration from the EDQM that, due to the
nature of the changes, an updated CEP was not issued.
• A summary of the changes made to the API that resulted in the revision of the CEP.
• A declaration that any test requirements in addition to those in the CEP that were previously
approved by the TGA will continue to apply.
• A declaration that no significant changes to the API have been made since the revised CEP
was issued.
• The revised API specification, including test methods, adopted by the API manufacturer and
the drug product manufacturer/product sponsor (as relevant).
A GMP clearance or manufacturing licence is not required for the

manufacturing site of intermediates or the site of milling/micronisation of the
final drug substance. If, however, the milling of the final API occurs in Australia
the site will require a GMP licence.
If a manufacturing site for an intermediate is included in the CEP, please make
this clear to avoid confusion about the actual site of manufacture of the API.
Refer to Evidence of GMP compliance for prescription medicines for
information about when you are required to provide evidence of GMP.
V3.1 January 2020
You must generate the following data:

• Relevant comparative data for pre-change and post-change batches of the API (if the revision
to the CEP is due to changes to the method of synthesis that involve using different
crystallisation solvents, a different purification process, or micronisation of the final drug
substance).
• Comparative data using validated test methods to show that:
- there is no change in the crystalline (polymorphic) form of the final substance (if
relevant) and
- the particle size distribution profiles (tested by a laser diffraction or other equivalent
method) remain comparable and within the same ranges as the pre-change API.
Alternatively comparative dissolution profiles must be generated.
• Comparative batch data from at least one production-scale batch of the final drug substance
manufactured or tested according to the changed process, which demonstrate compliance
with any revised API specification.
AMBS: API and intermediate manufacture - change to batch size of a non-

sterile API (existing site)
Change to the size of a manufacturing batch of a non-sterile API or its intermediates.
Conditions
• Any increase in batch size must be less than 10 fold from that last evaluated by the TGA.
• There must be no change in route of synthesis (including solvents used in the final
purification of the API), other than any necessary adjustment to processing conditions or use
of different equipment.
• The change must not be due to unexpected events arising during manufacture or to stability
concerns.
• The API must not be a sterile substance.
Data requirements
You must submit:
• Details of the new manufacturing batch size.
• Comparative batch data demonstrating there is no significant difference in the tested
parameters, particularly particle size distribution, polymorphism and impurity profiles.
AMCS: API site of manufacture - cessation

Cessation of an approved site for the manufacture of the API.
Requires update to ARTG data: Manufacturers
Conditions
• There must be at least one other registered site of manufacture for the API.
V3.1 January 2020
A GMP clearance or manufacturing licence is required for the principal

manufacturing site of the final drug substance. Exceptions are some common
inorganic salts and simple organic compounds. For more information see
guidance on drug master files (active substance master files).
Data requirements
You must submit:
• The name and address of the manufacturer to be ceased.
• A current TGA Business Services printout for the product or a copy of the TGA approval
showing that at least one registered site of manufacture of the API remains to perform the
relevant steps of manufacture.
AMIT: API and intermediate manufacture - addition, revision or deletion of

in-process control tests and limits
Addition, revision or deletion of in-process control tests and associated limits applied during
manufacture of the API or its intermediates.
Conditions
• The change must be consistent with any applicable principles of the Guide to Good
Manufacturing Practice for Medicinal Products.
• The change must not be due to adverse events during manufacture.
• The change must result in equivalent or improved quality of the final isolated material.
• The specifications of the API and/or intermediates may only be changed in ways permitted
in other parts of this guidance document or remain unchanged.
• The new test method must not be a biological method.
Data requirements
You must submit:
• Details of the new in-process control tests and limits.
• Appropriate validation data for the in-process control test method.
• Batch analytical data from testing of three batches using the current and proposed methods
demonstrating the results are within the same ranges.
AMMC: API/starting material/intermediate manufacture - minor

manufacturing changes not involving sterilising steps (existing site)
Minor changes to the manufacture of the API, starting material or intermediates (i.e. equipment
or process changes to improve efficiency), excluding changes to sterilising steps.
V3.1 January 2020
Conditions
• The change must be consistent with any applicable principles of the Guide to Good
• The synthetic route must remain the same, and no new reagents, solvents or catalysts are to
be used in the amended process.
• The change must not involve any sterilising steps.
• The specifications of the API, starting materials and intermediates may only be changed in
ways permitted in other parts of this document or remain unchanged.
Data requirements
You must submit:
• Details of the amended manufacturing process, including the synthesis flowchart.
• Comparative batch data for the API/starting material/intermediate demonstrating there are
no significant differences in the purity profiles or physicochemical properties.
AMMF: API starting material/intermediate site of manufacture - change

to/addition of (for APIs manufactured by multi-step syntheses or
fermentation)
Transfer to, or addition of, an alternative site for the manufacture of intermediates for APIs that
are manufactured by multi-step synthesis, which may include intermediates prepared wholly or
partially by fermentation.
Conditions
• The intermediates must be isolated chemical species and be at least three steps back in the
synthetic scheme from the API (purification procedures do not count as steps of synthesis).
• The synthetic route must remain the same, and no new reagents, solvents or catalysts are to
be used at the new site.
• The specification limits of starting materials or intermediates must be the same or tighter.
• For intermediates prepared wholly or partially by fermentation:
- there must be either no change in the strain of the producer organism used or, where
there is a change, details of the new producer organism must be provided and the
component profiles of the final fermentation broth at harvest made from the new and
old strain must be the same.
- there must be no changes to the scale of operation of the fermentation tank and
fermentation processes.
- there must be no changes to the nature of the media ingredients, particularly

precursors, activators or components of biological or animal origin (although changes
to the quantities used are acceptable, provided that they are not a result of a change in
scale of operation).
V3.1 January 2020
Data requirements
You must submit:
• The name and site address of the new manufacturer(s) of the starting material(s) or
intermediate(s).
• The route of synthesis of the API.
• The name or code number of the intermediates for which the alternative site of manufacture
is sought.
• Comparative batch data (including impurity levels) for the starting material(s) or
intermediate(s) manufactured at the current and proposed sites using validated test
methods demonstrating that there are no significant differences in purity profiles.
• Comparative batch data for API synthesised using starting material(s) or intermediate(s)
from the current and proposed sites demonstrating that there are no significant differences
in purity profiles.
AMTA: API site of manufacture - transfer of/addition to an existing

manufacturer's site of a non-sterile API that is not prepared by
fermentation
Transfer to, or addition of, an alternative site of manufacture of non-sterile APIs that are not
prepared by fermentation, but by chemical synthesis or through isolation from a natural source
as pure chemical entities.
Conditions
• The API must be prepared by chemical synthesis or isolated from a natural source as pure
chemical entities.
• The API must not be prepared wholly or partially by fermentation, and must not be sterile.
• There must be no change to the existing method of synthesis, including to any intermediates
and any solvents or reagents used in the synthesis and purification of the drug substance
(the API), or any other aspect of manufacture and specifications.
This change only applies where the sponsor of the drug product or the new API
manufacturer knows the full route of synthesis and all other details of
manufacture of the API at both sites.
• The manufacturing batch size remains unchanged or smaller.

• The new site must either have:
- a current manufacturing licence issued by the TGA (Australian manufacturers) for this
type of manufacture or
- a sponsor-specific GMP clearance (if the site is overseas) that is valid at the time of the
application for this type of manufacture.
V3.1 January 2020
Data requirements
You must submit:
• The name and address of the new manufacturing site and GMP clearance number.
• The flowchart of the route of synthesis at the existing site and the new site of manufacture.
• The manufacturing batch size at the new site.
• Comparative batch data for three batches of the API from the proposed site. This data must
demonstrate that all results (including impurity profiles, particle size distribution and
polymorphic forms) are either:
- within the same range as three batches manufactured at the current site (that is, no
new impurities or polymorphic forms are present) or
- remain unchanged.
ASAM: API/starting material/intermediate specifications - changes to non-

biological test methods for assay and/or residual solvents (including water)
Changes to a non-biological method used for assaying or residual solvent testing (including
testing for water where this may be present) of the API, starting materials for API synthesis or
intermediates created in the synthetic process.
Conditions
• The proposed method must not be a biological method.
• Validation data from the proposed method must demonstrate either:
- an improvement in at least one of precision, accuracy or specificity, without a reduction

in the other parameters or
- an improvement in specificity or accuracy with reduced precision (provided precision

remains within the specified limits).
Data requirements
You must submit:
• A summary description of the change and details of the new method.
• Validation data for the proposed method.
• Data for three batches of the API tested using the current and proposed methods
demonstrating equivalency of both methods.
ASDR: API re-test period and storage conditions - decrease to re-test period
and/or more restrictive storage conditions
Decrease in the re-test period, or application of more restrictive storage conditions, for APIs.
Conditions
• The change should not be the result of unexpected events arising during manufacture or
because of stability concerns.
V3.1 January 2020
Data requirements
You must submit:
• Reasons for the change.
• Details of the new retest period and/or storage conditions.
• An assurance that you possess adequate stability data for at least three production-scale
batches of the API to support the new retest period and/or storage conditions.
ASID: API/starting material/intermediate specifications - changes to

identification tests
Changes to identification tests used for the API, starting materials for API synthesis or
intermediates created in the synthetic process.
Conditions
• The changes to identification tests must:
- be from a less specific to a more specific identification test (for example, from an
ultraviolet/visible spectrophotometric or chromatographic method, such as thin layer
chromatography, gas chromatography or high-performance liquid chromatography
(HPLC), to a conventional infrared spectroscopic method) and/or
- vary the existing identification test (for example, an HPLC test that has been shown to
improve or at least maintain the specificity of the method) and/or
- replace an existing identification test with a near infrared spectroscopic identification

test and/or
- include a new identification test in addition to an existing identification test.

• Any additional identification test must not serve as an alternative identification test.
• For near infrared spectroscopy tests, the method development and other data requirements
(including data collection, establishment of the spectral reference library, calibration and
validation of the method) must comply with the currently adopted European Medicines
Agency (EMA) guideline on the use of near-infrared spectroscopy.
Data requirements
You must submit:
• The revised set of specifications.
• Details of the identification test method.
ASNL: API/starting material/intermediate specifications - narrowing of

limits
Any revision of the specifications for testing of the API, starting materials for API synthesis or
intermediates created in the synthetic process must make the limits applied to the test results
more stringent.
Conditions
• The proposed limits must be consistent with any applicable official standard or adopted
guidelines.
V3.1 January 2020
• The grade of material must not change (for example, unmicronised to micronised material).
Data requirements
You must submit:
• The revised set of specifications for the starting materials, intermediates or API (as
applicable).
• Data for at least three production-scale batches demonstrating compliance with the
proposed test and limits.
ASNT: API/starting material/intermediate specifications - addition of new

test and limit
Addition of a new test and associated limits to the approved specifications for the API, starting
materials for API synthesis or intermediates created in the synthetic process.
Conditions
• The change must not result from an altered method of manufacture that changes the
material’s quality characteristics (such as micronisation).
• The proposed method must be validated.
• Applied limits must be based on batch analytical data, and comply with any applicable
official standard or adopted guidelines.
• The change must not involve a genotoxic impurity.
Data requirements
You must submit:
• Details of the new method.
• The revised set of specifications for the starting materials, intermediates or API (as
applicable).
• Comparative batch data for at least three commercial batches demonstrating compliance
with the proposed test and limit.
ASPC: API specifications - changes to physicochemical test methods and

limits
Physicochemical parameters include pH, hardness, friability, colour, particle

size distribution, particulate matter contamination, density, specific gravity,
optical rotation, extractable volume, osmolality, osmolarity and viscosity.
Conditions
• The test limit must either remain unchanged or be more stringent.
• The amended method must have been validated or deemed comparable.
• The test principle must remain unchanged.
V3.1 January 2020
Data requirements
You must submit:
• Details of the new method together with a summary description of the change.
• Appropriate validation data or comparison data for the new method.
ASPT: API specifications - amendments resulting from pharmacopoeial or

TGO changes
Changes to the specifications for the API as a result of amendments to requirements in a default
standard (i.e. a monograph in the British pharmacopoeia [BP], The United States Pharmacopeia
and The National Formulary [USP-NF] or the European Pharmacopoeia [EP]) or relevant
requirements in an applicable standard made by the Minister under section 10 of the Act.
Conditions
• The API must already be tested to the existing pharmacopoeial or Therapeutic Goods Order
(TGO) requirements.
• The requirements applied from one pharmacopoeia must not be changed to another (e.g.
changing from the BP to the USP requires the submission of data for evaluation).
• The new pharmacopoeial monograph or amended TGO must be applicable to the API.
• Any tests that were performed in addition to those of the pharmacopoeial monograph must
continue to be applied, except where the test was required by the old monograph and not by
the new one.
Data requirements
You must submit:
• The revised set of specifications for the API.
1.1.3 Category 3 requests – Data evaluation required under s.9D(3)

These variations fall under s. 9D(3) of the Therapeutic Goods Act 1989 and require the
submission of data for evaluation.
ADSL: Shelf life - Changes to the retest period of the active pharmaceutical
ingredient
Any proposed changes to the retest period of an API can be submitted as part of this Category 3
variation type.
Conditions
• Data is submitted as described below.
Data requirements
You must submit:
• Stability data generated according to International Conference on Harmonisation of
Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH) guidelines
on at least three production-scale batches of the API to support the change. Data from fewer
batches or pilot-scale batches may be acceptable, if justified.
V3.1 January 2020
AMAS: API manufacture - changes to the site(s) of manufacture

Any proposed changes to the site of manufacture of an API can be submitted as part of this
Category 3 variation type.
Conditions
Data requirements
You must submit:
• GMP evidence for the new site (that is, the Australian manufacturing licence for an
Australian site or a current GMP clearance letter for an overseas site). The Australian licence
or GMP clearance letter should cover the relevant manufacturing steps and should be valid
(before expiry) at the time of application.
• Process validation data, including full details of the method of synthesis and relevant flow
diagrams, and validation of sterile manufacture and sterile processes, if applicable.
• If the API exhibits polymorphism, relevant data to demonstrate that the approved
polymorphic form is produced.
• Comparative impurity profile data from representative batches from current and new sites
of manufacture, using a validated test method.
• Comparative particle size distribution data from at least three batches of pre-variation API
and at least one batch of post-variation API to demonstrate comparability in particle size
profile.
• Validation data that demonstrate the suitability of the API from the new site for use in the
dosage form for which it is intended (for example, comparative dissolution profiles for solid
dosage forms, drug mass aerodynamic particle size distribution for inhalation products) or
justification for not providing such data. Where multi-strength (more than two) products are
involved, comparative data for the highest and lowest strengths should suffice if the various
strengths are direct scale or their formulations are closely similar.
• A Drug Master File (DMF) with accompanying letter of access, a CEP with accompanying
letter of access, or a declaration that the manufacturing process and quality control are the
same as those used at the currently approved manufacturing sites, or a description of any
differences between the processes at the different sites (refer to Guidance 11: Drug Master
Files and Certificates of Suitability of a Monograph of the European Pharmacopoeia for drug
substances for further details).
• Certificates of analysis for at least three production-scale batches manufactured at the new
site that demonstrate the manufacturer’s ability to produce material that meets the
currently approved specifications, including particle size limits and polymorphic form.
V3.1 January 2020
AMCM: API manufacture - changes to the synthetic route or the

manufacturing process
Any proposed changes to the synthetic route or manufacturing process can be submitted as part
of this Category 3 variation type. For example, increases in batch size, changes to manufacture of
key intermediates or redefining a starting material.
Conditions
Data requirements
You must submit:
• A description (including flow diagram) of the changed manufacturing process, including any
changes to manufacturing batch size and in-process controls.
• If redefining a starting material, justification for the choice of the starting material. Provide
the pre-starting material synthetic process and details of controls of starting material
impurities, including metal catalysts and residual solvents.
• Validation of the process.
• If the API is made entirely by fermentation, details of any material of animal origin used
during the process that is classified as Category IC in the TGA’s Transmissible Spongiform
Encephalopathies (TSE): TGA approach to minimising the risk of exposure. If appropriate,
provide assurance regarding self-assessment of TSE risks of such materials (see variation
type EMRS)
• A description and discussion of any resulting changes in impurities.
• Comparative impurity profile data from three batches of pre-variation material and at least
one production batch of post-variation material using a validated test method.
• Comparative particle size distribution data from at least three batches of pre-variation and
at least one batch of post-variation API to demonstrate comparability in particle size profile.
• Certificates of analysis for at least one production batch of API manufactured using the new
process that demonstrates the manufacturer’s ability to meet the currently approved
specifications, including polymorphic form and particle size distribution (using laser
diffraction method), if appropriate. An assurance that certificates of analysis for another two
batches showing compliance with the currently approved API specifications will be
generated should also be provided.
• An updated Drug Master File (DMF) or Certificate of Suitability (CEP) (refer to Guidance 11:
Drug Master Files and Certificates of Suitability of a Monograph of the European
Pharmacopoeia for drug substances for further details), if relevant.
• Where a change is to late stages of synthesis, crystallisation, purification or milling, either
relevant comparative data of the dosage form (for example, dissolution, drug mass,
aerodynamic particle size distribution) manufactured from at least three batches of pre-
variation and at least one batch of post-variation API, or a cogent justification for not
providing such data.
• Stability data for post-variation API in accordance with the relevant adopted EMA/ICH
guidelines, or a statement of commitment to carry out such studies to verify any applied
retest period of the API. Refer to ARGPM Guidance on Stability testing for prescription
medicines for further details. Additional accelerated and long-term stability data for the drug
product using the post-variation API may be necessary, in accordance with EMA guidelines.
V3.1 January 2020
ASCS: API specifications - changes to the specifications of the active

pharmaceutical ingredient, including changes to test methods
Any proposed changes to the specifications of the API can be submitted as part of this Category 3
variation type.
Conditions
Data requirements
You must submit:
• A copy of the revised specification. This should be consolidated to apply to all sites of API
manufacture, where relevant.
• Justification for the proposed changes, including changes to test methods.
• Validation of any changed test methods. Method cross-validation data against alternative or
pharmacopoeial methods may also be required, if relevant.
• Certificates of analysis for at least three representative production-scale batches of the bulk
API that demonstrate the stability of the API.
1.2 Drug product manufacture changes - method, batch

size or equipment
These changes may be made to any products containing chemical entities (including sterile
products) covered by this document except those that are specifically excluded under each
change type.
1.2.1 Correction to, or completion of, an ARTG entry

Sponsors can request corrections to ARTG entries under s. 9D(1) of the Therapeutic Goods Act
1989. Alternatively, the Secretary can make corrections to ARTG entries under s. 9D(1), at his or
her initiative. Refer to the Variations to prescription medicines – excluding variations requiring
evaluation of clinical or bioequivalence data; Process guidance for further information.
CAMC: Correct an ARTG entry – Manufacturer

Conditions
Data requirements
You must submit:
• Details of the correction or additional information.
• Relevant justification and documentary evidence.
• An assurance that the only changes being made to the ARTG entry are those identified in the
request.
• Valid GMP clearances and/or Australian manufacturing licences for the relevant steps of
manufacture.
V3.1 January 2020
1.2.2 Notifications
These variations fall under section 9D(2C) of the Therapeutic Goods Act 1989.
DMBS: Drug product manufacture - changes to batch size for products that
are not modified release dosage forms
Changes to the size of the manufacturing batch of drug products, where these are not modified
release dosage forms.
Conditions
• The change must not be an increase in batch size for sterile products or products
manufactured under sterile conditions.
• For sterile products, a decrease in manufacturing batch size must be either:
- not accompanied by any change in sterile manufacturing process or
- where there has been a change in sterile manufacturing process, the specific conditions
in DMSE: Drug product manufacture - changes to manufacturing method and/or
equipment of sterile dosage forms that are not modified release have been met.
• The product must not be a modified-release dosage form. This includes enteric-coated
tablets, enteric capsules and transdermal patches.
• The new manufacturing batch size must be validated in accordance with applicable
principles of the Guide to Good Manufacturing Practice for Medicinal Products and any
relevant guidelines adopted by the TGA.
Data requirements
You must submit:
• Details of the new manufacturing batch size, with the revised batch manufacturing formula.
• Additional validation data as required for the dosage form, as appropriate:
- For solid dosage forms, see DMES: Drug product manufacture - changes to
manufacturing method and/or equipment of solid dosage forms that are not modified
release.
- For semi-solid/liquid dosage forms, see DMEL: Drug product manufacture - changes to
manufacturing method and/or equipment of semi-solid/liquid dosage forms that are
not modified release.
- For oral/nasal inhalation dosage forms, see DMEO: Drug product manufacture -
changes to manufacturing method and/or equipment of oral/nasal inhalation dosage
forms that are not modified release.
- For sterile dosage forms, see DMSE: Drug product manufacture - changes to
manufacturing method and/or equipment of sterile dosage forms that are not modified
release.
V3.1 January 2020
DMEL: Drug product manufacture - changes to manufacturing method

and/or equipment of semi-solid/liquid dosage forms that are not modified
release
Changes to methods or equipment used in the manufacture of semi-solid or liquid products,
where these are not modified release dosage forms and are not sterile.
Conditions
• The product must not be a modified-release dosage form (including enteric-coated tablets,
enteric capsules and transdermal patches) or sterile.
• The new manufacturing method and equipment must be validated consistent with applicable
relevant guidelines adopted by the TGA on at least one production-scale batch of the
product.
Data requirements
You must submit:
• Details of the revised method of manufacture and/or equipment, and any relevant flow
diagram of the new process.
• Comparative batch data that demonstrates all results are comparable and within the same
range as those obtained previously, as well as meeting currently approved drug product
release specifications.
• For semi-solid and liquid products (for example, ointments, creams, lotions, oral liquids,
moulded suppositories and pessaries), comparative batch data using appropriate current
methodology demonstrating that there has been no change to the particle size distribution
and polymorphic form of the API in suspension.
• These data are not required if the API is in solution for the drug product, or if it is in solution
as liquid globules.
DMEO: Drug product manufacture - changes to manufacturing method

and/or equipment of oral/nasal inhalation dosage forms that are not
modified release
Changes to methods or equipment used in the manufacture of oral or nasal inhalation products,
where these are not modified release dosage forms and are not sterile.
Conditions
product.
V3.1 January 2020
Data requirements
You must submit:
You must generate comparative batch data:
• That demonstrates all results are comparable and within the same range as those obtained
previously, as well as meeting currently approved drug product release specifications.
• For the drug mass aerodynamic particle size distribution of the aerosol emitted by the drug
product (for metered-dose pressurised inhalations, metered-dose nasal spray solutions, and
dry powders for oral or nasal inhalation) that demonstrates that results are in the same
range as previously obtained, as measured by either a multi-stage liquid impinger or a multi-
stage cascade impactor (Andersen type).
DMES: Drug product manufacture - changes to manufacturing method

and/or equipment for solid dosage forms that are not modified release
Changes to the manufacturing method or equipment used in the manufacture of solid dosage
forms that are not modified release and are not sterile.
Conditions
product.
Data requirements
You must submit:
• All solid dosage forms (for example, tablets, capsules, compressed suppositories and
pessaries) must have similar comparative dissolution profiles - that is, the similarity factor,
f2, should be between 50 and 100. These data are not required if the API is in solution for the
drug product, or if it is in solution as liquid globules.
V3.1 January 2020
DMIT: Drug product manufacture - changes to in-process control tests and

limits
Addition, revision or deletion of in-process control tests and associated limits applied during
manufacture of the drug product.
Conditions
• The change must not relate to the parametric release of sterile products.
Parametric release
The European Pharmacopoeia refers to parametric release in the monograph
“methods of preparation of sterile products” as:
When a fully validated terminal sterilisation method by steam, dry heat or
ionising radiation is used, parametric release, that is the release of a batch of
sterilised items based on process data rather than on the basis of submitting a
sample of the items to sterility testing, may be carried out, subject to the
approval of the competent authority.
Parametric release can only be applied to products terminally sterilised in
their final containers.
• The change must be consistent with applicable principles of the Guide to Good
• Any changes to in-process control test methods must be validated appropriately.
• The change must result in either improved quality or no change in the quality of the drug
product.
Data requirements
You must submit:
• Details of the changes proposed, and the revised set of in-process control tests and limits.
Test method details are not required.
• Comparative batch data with the results within the same range as previously obtained.
DMRO: Drug product manufacture - reduction or removal of API and

excipient overages for ingredients that are not antioxidants or similar
Reduction or removal of previously approved manufacturing overages for APIs or excipients,
where the excipients may be preservatives but are not antioxidants and where the final drug
product is not a modified release dosage form.
Since overages do not change the nominal quantity recorded in the ARTG, this type of change is
not regarded as a change in the product formulation.
V3.1 January 2020
Conditions
• Any excipient involved must not be an antioxidant or another ingredient whose function (at
least in part) involves being ‘consumed’ over time.
• Manufacture of the product with reduced overage must be appropriately validated.
• The TGA must be notified as a priority if the results of supporting stability data fail to meet
the specifications. The TGA reserves the right to withdraw the product from the market if
this requirement is not met.
Data requirements
You must submit:
• The revised manufacturing formula.
• Comparative batch data to demonstrate that the results are comparable to those obtained
previously (allowing for the reduction in overage).
• Stability data on at least one production batch of the post-variation product (with at least
two more production batches to be similarly tested).
DMSE: Drug product manufacture - changes to manufacturing method

and/or equipment of sterile dosage forms that are not modified release
Changes to methods or equipment used in the manufacture of sterile dosage forms, where these
are not modified release dosage forms.
Conditions
• The product must not be a modified-release dosage form.
principles of the Guide to Good Manufacturing Practice for Medicinal Products on at least
one production-scale batch of the product.
• Other changes to ensure sterility are permitted, provided that:
- the technology to be used already exists at the manufacturing site and is in use for
other TGA-approved products.
- there are no changes to (or there are improvements in) microbiological environmental
standards, bioburden specifications, the sterilisation cycle or its parameters, and
sterility assurance levels.
Data requirements
You must submit:
• Validated process times.
V3.1 January 2020
• The new method of manufacture (including sterilisation of containers or container
components, and use of a second filter in a filling line) or new manufacturing equipment
(such as introduction of a similar filling line) must not affect the final sterility of the product.
• All of the dosage-specific data requirements described in the following variation types must
be certified as having been met, as appropriate:
- For solid dosage forms, see DMES: Drug product manufacture - changes to
manufacturing method and/or equipment of solid dosage forms that are not modified
release.
- For semi-solid/liquid dosage forms, see DMEL: Drug product manufacture - changes to
manufacturing method and/or equipment of semi-solid/liquid dosage forms that are
not modified release.
- For oral/nasal inhalation dosage forms, see DMEO: Drug product manufacture -
changes to manufacturing method and/or equipment of oral/nasal inhalation dosage
forms that are not modified release.
1.2.3 Self-assessable requests (SARs)

These variations fall under s. 9D(3) of the Therapeutic Goods Act 1989.
The conditions outlined below the description of each variation type must be met for the request
to be processed as self-assessable.
DMDS: Drug product manufacture - changes to dimensions, shape, inked

imprint, embossing or debossing of solid dosage forms
Changes to dimensions, shape, inked imprint, or embossing and debossing of solid dosage forms.
Requires update to ARTG data: Visual Identification
Definitions
An inked imprint is a marking or pattern on the product made by printing
with an ink during product manufacture.
Embossing/debossing is either the raised (embossed) or depressed
(debossed) marking, pattern or engraving on the product that is formed by
special tools used during product manufacture.
Conditions
• The product should be a solid dosage form (note that capsules are considered to be solid
dosage forms, but impregnated sponges are not).
• There should be no concurrent change to the formulation except as allowed in self-
assessable requests that create a separate and distinct good.
• There should be no change to, or addition or deletion of, scoring.
• Where an inked imprint is changed, there should be no change to the imprinting ink used.
V3.1 January 2020
• Where a change involves product shape, dimension or embossing/debossing, the

comparative dissolution profiles of pre-variation and post-variation products should be
similar (that is, the f2 value should be between 50 and 100).
‘Comparative dissolution profiles’ should be generated on three recent pre-variation batches
and at least one batch of post-variation product as follows:
- At least 12 dosage units (for example, tablets, capsules) of each batch should be tested
individually, and mean and individual results reported. The percentage of nominal
content released should be measured at a minimum of three suitably spaced time
points (excluding the zero time point) to provide a profile for each batch (for example,
at 5, 15, 30 and 45 minutes, or as appropriate to achieve virtually complete
dissolution). The batches should be tested using the same apparatus and, if possible, on
the same day. Test conditions should be those used in routine quality control or, if
dissolution is not part of routine quality control, any reasonable, validated method.
- To demonstrate the similarity of two dissolution profiles, the similarity factor, f2,
should be calculated using the equation and conditions stated in Appendix I of the
European Medicines Agency (EMA) Guideline on the Investigation of Bioequivalence
(CPMP/EWP/QWP/1401/98 Rev. 1/Corr). The f2 value should be between 50 and 100.
In cases where more than 85% of the active substance is dissolved within 15 minutes in
all tested batches, dissolution profiles are considered to be similar and the similarity
factor does not need to be calculated.
- Insufficient quantities of recently manufactured batches may be available to meet this

requirement. In these cases, it is acceptable to test retention batches, and to explain in
the test report why this was done, stating the age and storage history of the samples.
Data requirements
You must submit:
• The new product description.
• The revised set of drug product specifications at release and expiry.
• An updated CPD document.
• Where the proposed change requires an update to the PI, details of changes to the PI.
1.2.4 Category 3 requests - Data evaluation required under s. 9D(3)

DMCM: Drug product manufacture – changes to the method of manufacture

Any proposed changes to the method of manufacture of the drug product can be submitted as
part of this Category 3 variation type. This includes changes to batch size and equipment.
Conditions
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Data requirements
You must submit:
• A detailed description of the changed manufacturing process, including in-process controls.
• Process validation protocols and process validation data for the changed process (including
validation of sterile manufacture and sterilisation processes, if applicable) for at least three
production-scale batches. If fewer than three batches are process validated, explain why.
• Batch data for representative batches of the drug product manufactured using the current
and proposed process.
- At least one of these batches should be full production scale unless otherwise justified;
the other batches should be at least pilot scale but manufactured using full production–
scale equipment unless otherwise justified.
- These data should be compared with at least three batches of recently manufactured
pre-variation product. All data should be generated using approved routine quality
control methods, unless otherwise justified and details are provided of the non-routine
methods used.
• Relevant comparative data of the type listed below for the dosage form manufactured using
the new and old manufacturing method or process.
At least three recently manufactured batches of the pre-variation product and at least one
production batch of the post-variation product should be tested, preferably at the same time
and using the same method. The second and third batches manufactured under the new
conditions, if not available at the time of application, should be tested, and the results should
be reviewed by the sponsor as soon as they become available. The TGA should be notified of
any differences as a priority.
- For all solid dosage forms (for example, tablets, capsules, compressed
pessaries/suppositories, implants, modified-release dosage forms) and transdermal
patches, dissolution profiles using a discriminatory method. For modified-release
dosage forms and low-solubility drugs used in conventional dosage form, dissolution
testing over a pH range (for example, at pH 1.0, 4.5 and 6.8) should be conducted,
unless otherwise justified. Similarity factors (f2) should be calculated, where
appropriate.
- For semi-solid and liquid suspension products, particle size data (microscopic
imaging or other methods) and/or dissolution data, as relevant.
- For metered-dose pressurised inhalations (oral or nasal), dry powder for inhalation
products, and metered-dose nasal spray solutions or suspensions, drug mass
aerodynamic particle size distribution data using a multi-stage liquid impinger or a
multi-stage cascade impactor of the Andersen type.
• Stability data, or confirmation that stability data will be generated. Relevant stability data
should be generated for batches produced using the new process, as required by GMP.
The TGA may ask the sponsor to provide accelerated stability data for a particular medicine
if stability is known to be a problem or if changes in stability could have clinical
consequences. The relevant stability data do not necessarily need to be supplied before the
change of process is approved. However, if the data are not supplied, the sponsor should
provide written assurance that stability data will be generated, and the TGA should be
notified immediately if there are any significant problems, or if the data indicate that the
stability of product from the new process is different from that made by the original process
to the extent that the shelf life of the medicine would be affected.
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• If the changes proposed may affect bioavailability of the product, bioavailability data
establishing bioequivalence of product manufactured using the new and currently approved
processes, or a justification for a waiver for such data. For further information on this aspect,
see Guidance 15: Biopharmaceutic studies. If bioavailability data are required and are
submitted to support the change, the application becomes a Category 1 application.
1.3 Drug product - site of manufacture changes
1.3.1 Changes that do not require prior approval

These changes can be implemented before you inform the TGA of the change.
Reporting to the TGA should be in writing, together with any relevant documentary evidence
required in support and the date of implementation advised. No specific form is required. This
process cannot be used if the proposed changes require a consequential change to the approved
product information of the registered medicine.
See information on changes that do not require prior approval in Variations to prescription
medicines – excluding variations requiring evaluation of clinical or bioequivalence data; Process
guidance.
Manufacturing - change to manufacturer’s name or the manufacturing

address, provided the actual site location does not change
Change to manufacturer’s name only (including manufacturers who are also product sponsors)
or the manufacturing address, provided the actual site location does not change.
Conditions
• The change includes manufacturers who are also product sponsors.
• The physical location of the manufacturing facility remains the same.
Data requirements
You must submit:
• Notification of the change.
• Valid evidence of good manufacturing practice (GMP) for the company with the new name.
1.3.2 Notifications
DMDM: Drug product site of manufacture - cessation of a site or deletion of

a manufacturing step
Cessation of, or deletion of a step in, the manufacture of the drug product at an approved site.
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Conditions
• This change is applicable to all medicines, including sterile products and modified-release
dosage forms.
• There must be at least one other site that performs the same steps of manufacture as the
ceased site, or that performs the deleted step of manufacture.
Data requirements
You must submit:
• The name and address of the manufacturer to be ceased.
• Details of the manufacturing step(s) to be deleted, as relevant.
• Documentary evidence to show that there is at least one registered site of manufacture
performing the same step of manufacture as the ceased site.
DMPL: Drug product site of manufacture - change to site of

labelling/primary packaging (non-sterile products) or labelling/secondary
packaging
Change to the location of a manufacturer, or addition of a new manufacturer, approved for
labelling and primary packaging operations for non-sterile dosage forms or labelling and
secondary packaging operations for all dosage forms.
Conditions
• A change in, or addition of an alternative, site of primary packaging operations may relate
to any product except products that are sterile or are manufactured under sterile conditions.
• A change in, or addition of an alternative, site of secondary packaging operations may
relate to any product, including sterile products and products manufactured under sterile
conditions.
- a current GMP clearance issued by the TGA and valid at the time of this application
(overseas manufacturers) for this type of manufacture.
• Apart from the change in site of manufacture, there must be no change to any aspect of the
quality data other than changes to manufacturing equipment.
- Where a change in manufacturing equipment is made, this must be validated in

accordance with the principles of GMP.
Data requirements
You must submit:
• The name and address of the new manufacturer and licence/clearance number.
• Details of the manufacturing step(s) undertaken at the new site of manufacture.
V3.1 January 2020
DMSL: Drug product site of manufacture - change to site of manufacture of

non-sterile semi-solid/liquid dosage forms that are not modified release
Change to the location of an approved manufacturer, or addition of a new manufacturer, to make
the final drug product, where the products are non-sterile, semi-solid or liquid dosage forms that
are not modified release.
Conditions
• Applies to sites of manufacture of the final drug product only, not sites performing in-
process steps.
• The product must not be sterile or manufactured under sterile conditions.
• There must be no changes to any aspect of the quality data other than changes to
manufacturing equipment or method at the new site of manufacture and
- The changes to the manufacturing methods are only those necessitated by scale-up or
downscaling, e.g. use of different-sized equipment or
- The change does not adversely affect the reproducibility of the process and it is not the
result of unexpected events arising during manufacture or because of stability
concerns.
- Where a change in manufacturing equipment or method is made, this must have been
validated at the new manufacturing site in accordance with the principles of GMP
and/or any relevant guidelines adopted by the TGA.
Data requirements
You must submit:
• A summary of the change in manufacturing equipment or manufacturing method at the new
site, if relevant.
• Comparative batch data demonstrating all results are comparable and within the same range
as those obtained previously, as well as meeting currently approved drug product release
specifications.
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• For semi-solid and liquid products (for example, ointments, creams, lotions, oral liquids,
moulded suppositories and pessaries), comparative batch data using appropriate current
methodology demonstrating that there has been no change to the particle size distribution
and polymorphic form of the API in suspension. These data are not required if the API is in
solution at any stage during manufacture of the drug product, or if it is in solution in the drug
product or present as liquid globules.
• Appropriate validation of the manufacturing process at the new site carried out on at least
one production-scale batch. The second and third production-scale batches should be
subsequently validated.
DMSO: Drug product site of manufacture - change to site of manufacture of

non-sterile oral/nasal inhalation dosage forms that are not modified
release
Change to the location of an approved manufacturer, or addition of a new manufacturer, to make
the final drug product, where the products are non-sterile oral or nasal inhalation dosage forms
that are not modified release.
Conditions
process steps. For changes to the site of manufacture not involving the final product see:
- Excipients (not of animal or human origin) - changes to the manufacturing process

and/or site (same specifications) or
- Non-sterile container - changes to the supplier or manufacturer if same material and

specification.
• The product must not be a modified-release dosage form.
manufacturing equipment or method at the new site of manufacture.
Data requirements
You must submit:
V3.1 January 2020

site, if relevant.
• A declaration that the changes to the manufacturing methods are only those necessitated by
scaling-up or down, e.g. use of different-sized equipment, that the change does not adversely
affect the reproducibility of the process, that it is not the result of unexpected events arising
during manufacture or because of stability concerns.
specifications.
• For metered-dose pressurised inhalations, metered-dose nasal spray solutions, and dry
powders for oral or nasal inhalation, the comparative batch data for the drug mass
aerodynamic particle size distribution of the aerosol emitted by the drug product
demonstrating that results are in the same range as previously obtained, as measured by
either a multi-stage liquid impinger or a multi-stage cascade impactor (Andersen type).
DMSS: Drug product site of manufacture - change to site of manufacture of

non-sterile solid dosage forms that are not modified release
Change to the site of an approved manufacturer, or addition of a new manufacturer, to make the
final drug product, where the products are non-sterile solid dosage forms that are not modified
release.
Conditions
process steps.
manufacturing equipment or method at the new site of manufacture as outlined under Site
of manufacture changes.
V3.1 January 2020
Data requirements
You must submit:
site, if relevant.
• A declaration that the changes to the manufacturing methods are only those necessitated by
scaling-up or down, e.g. use of different-sized equipment, that the change does not adversely
affect the reproducibility of the process, that it is not the result of unexpected events arising
during manufacture or because of stability concerns.
specifications.
• All solid dosage forms (for example, tablets, capsules, compressed suppositories and
pessaries) must have similar comparative dissolution profiles - that is, the similarity factor,
f2, should be between 50 and 100. These data are not required if the API is in solution at any
stage during manufacture of the drug product, or if it is in solution in the drug product or
present as liquid globules.
• Appropriate validation of the manufacturing process at the new site carried out on at least
one production-scale batch. The second and third production-scale batches should be
subsequently validated.
DMTR: Drug product site of manufacture - change to site performing testing

and release for supply
Change to the location of a manufacturer, or addition of a new manufacturer, approved for
quality control testing (including sterility, microbiological, chemical, physical and bacterial
endotoxin or pyrogen testing) or release for supply of the final drug product.
Conditions
• The change applies to sites of manufacture of the final drug product only, not sites
performing in-process steps.
• This change is applicable to all medicines, including sterile products and modified-release
dosage forms.
• There may not be any changes to the existing test methods used for testing the product,
whether or not the test methods have been provided to the TGA previously, except where
allowed by DMSL: Drug product site of manufacture - change to site of manufacture of non-
sterile semi-solid/liquid dosage forms that are not modified release.
V3.1 January 2020
Data requirements
You must submit:
• Appropriate technology transfer of the approved test methods to the proposed site must
have been carried out.

DMCS: Drug product site of manufacture - changes to the site(s) of

manufacture
Any proposed changes to the site of manufacture of the drug product can be submitted as part of
this Category 3 variation type.
Conditions
Data requirements
You must submit:
• GMP evidence for the new site (that is, the Australian manufacturing licence for an
Australian site, or a current GMP clearance for an overseas site). The Australian licence or
GMP clearance should cover the relevant manufacturing steps and must be valid (before
expiry) at the time of application.
• A declaration that the manufacturing process, including batch size, is the same as that used
at the currently approved manufacturing sites, or a description of any differences between
the processes at the new and currently approved sites.
• Appropriate validation of the process at the new site for at least one production-scale batch
(including validation of sterile manufacture and sterilisation processes, if applicable) to
demonstrate that product manufactured at the new site meets the currently registered
requirements for in-process controls and the drug product specifications.
• Description and validation of quality control test methods where there is a change in test
procedures or where the laboratory testing the product (site of quality control testing) has
changed.
• Certificates of analysis for representative batches of drug product that were manufactured at
both the currently approved site and the new site. At least one batch from the new site
should be full production scale unless otherwise justified; other batches should be at least
pilot scale and manufactured using full production–scale equipment.
• Relevant comparative data on the product (see DMCM: Drug product manufacture – changes
to the method of manufacture). For modified-release dosage form and for low-solubility
drugs used in conventional dosage form, dissolution testing over a pH range (for example, at
pH 1.0, 4.5 and 6.8) should be considered, unless justification can be provided for not
conducting such testing. Similarity factor, f2, should be calculated, where appropriate.
V3.1 January 2020
• Relevant stability data should be generated for batches produced at the new site, as required
by GMP. The TGA may ask the sponsor to provide accelerated stability data for a particular
medicine if stability is known to be a problem or if changes in stability could have clinical
consequences. The relevant stability data do not necessarily need to be supplied before the
change of site is approved. However, if stability data are not supplied, the sponsor should
provide written assurance that stability data will be generated, and the TGA should be
notified as a priority if there are any significant problems, or if the data indicate that the
stability of product from the new site is different from that made at the original site to the
extent that the shelf life of the medicine would be affected.
1.4 Drug product formulation changes

CAAO: Correct an ARTG entry - Animal origin

Requires update to ARTG data: Formulation.
Conditions
Data requirements
You must submit:
request.
CAFC: Correct an ARTG entry - Formulation

Conditions
Data requirements
You must submit:
request.
V3.1 January 2020
1.4.2 Self-assessable requests (SARs) that create a separate and

distinct good (s. 23)
These variations fall under s. 23 of the Therapeutic Goods Act 1989 because they create a
separate and distinct good. However, the existing AUST R number can be retained under the
provisions of the Therapeutic Goods (Groups) Order No. 1 of 2001.
to be processed as self-assessable. All other formulation changes require the submission of data
for TGA evaluation. See DFCF: Formulation – changes (CE) – Retaining AUST R number or DFNA:
Formulation changes (CE) – New AUST R number.
DFCI: Formulation - addition or deletion of, or variation to, an inked imprint

Inked imprints on a solid oral dosage form may be added, deleted or varied through self-
assessment.
Note: If the proposed change is to the inking pattern, but the same ink is used, this represents a
change to an existing ARTG entry – see DMDS: Drug product manufacture - changes to
dimensions, shape, inked imprint, embossing or debossing of solid dosage forms.
Conditions
• Any new colour or ink should be in the current TGA list of colours permitted for use in
medicines for ingestion (see Colourings used in medicines for topical and oral use), and
should comply with the specifications in that list.
• Any new proprietary excipient to be used must already be present in another prescription
medicine registered on the ARTG.
• If relevant, the drug product specification should be revised to incorporate any change in
product description.
• The new markings do not reduce product differentiation or cause confusion.
Data requirements
You must submit:
• A comparative list of the current and new product formulations.
• Information on use or non-use of human embryos or human embryonic stem cells, or other
material sourced from human embryos or human embryonic stem cells, in the manufacture
of the product (this is a requirement under Regulation 9B of the Therapeutic Goods
Regulations 1990).
• The revised product description (if this has changed), incorporated into the revised set of
drug product specifications (release and expiry).
• The ingredient number for the new proprietary excipient, together with the ARTG number of
the existing good that contains that ingredient, if relevant.
• An updated CPD document that incorporates the changes, if applicable.
• Revised labels, stating ‘New Appearance’ if applicable.
• A clean copy of the PI. Where the proposed change would involve amendment of a PI, a
marked-up copy should also be provided.
V3.1 January 2020
Associated changes
You may need to update other information about your medicine as a result of the changes to the
inked imprint. Associated variation types that you can include with DFCI are:
• ZFSM: ARTG data - Manufacturer changes associated with DFCI or DFFC
• ZFSV: ARTG data - Visual identification changes associated with DFCI or DFFC.
DFFC: Formulation - change relating to colouring agent, flavour or fragrance

Certain changes to, or addition or deletion of, colouring agents, flavour or fragrance of a product
may be made through self-assessment.
Note: If the colouring agent, flavour or fragrance is present at more than 2% w/w or w/v, this
requires evaluation of data. See variation type DFCF: Formulation – changes (CE) – Retaining
AUST R number.
Conditions
• The colouring agent, fragrance or flavour is present in the formulation at not more than 2%
w/w or w/v.
• Any new colour is listed in the current TGA list of colours permitted in medicines for oral
use, and complies with the specifications in the same list (see Colourings used in medicines
for topical and oral use).
• Any new proprietary excipient to be used must already be present in another prescription
medicine registered on the ARTG.
• There are only changes to, or addition or deletion of excipients that are colours, flavours or
fragrances. You should consider if the formulation of a proprietary excipient contains
excipients that are not colours, flavours or fragrances.
• The changes do not reduce differentiation or cause confusion.
• If relevant, the drug product specifications (release and expiry) should be revised to
incorporate any new product description or other organoleptic properties of the product.
Data requirements
You must submit:
• The ingredient number for the new proprietary excipient, together with the ARTG number of
the existing good that contains that ingredient, if relevant.
• A comparative list of the current and new product formulations.
of the product (this is a requirement under regulation 9B of the Therapeutic Goods
Regulations 1990).
• Updated specifications, if applicable.
• An updated CPD document that incorporates the changes, if applicable.
• Revised labels, stating ‘New Appearance’ or ‘New Formulation’ if applicable.
V3.1 January 2020
• A clean copy of the PI. Where the proposed change would involve amendment of a PI, a
marked-up copy should also be provided.
• Relevant comparative data of the type listed below should have been generated for the
dosage form manufactured using the new and old formulations:
• At least three recently manufactured batches of the pre-variation product and one
production batch of the post-variation product should be tested, preferably at the same time
and using the same method. The second and third batches manufactured under the new
conditions, if not available at the time of application, should be tested, and the results should
be reviewed by the sponsor as soon as they become available. The TGA should be notified of
any differences as a priority. The following data (where applicable) is to be provided for
each batch of the product to be tested:
- All solid dosage forms (for example, tablets, capsules, compressed suppositories and
pessaries) must have similar comparative dissolution profiles - that is, the similarity
factor, f2, should be between 50 and 100. These data are not required if the API is in
solution at any stage during manufacture of the drug product, or if it is in solution in the
drug product or present as liquid globules.
- For semi-solid and liquid products (for example, ointments, creams, lotions, oral
liquids, moulded suppositories and pessaries), comparative batch data using
appropriate methodology should demonstrate that there has been no change to the
particle size distribution and polymorphic form of the drug substance in suspension.
These data are not required if the drug substance is in solution at any stage during
manufacture of the drug product, or if it is in solution in the drug product or present as
liquid globules.
• A stability test on the reformulated product should have begun on at least one production-
scale batch, and should begin on the second and third batches as they become available. If
the results of the stability test do not meet the specifications, the TGA should be notified
immediately, and the reformulated product may be withdrawn from the market at the TGA's
discretion.
Associated changes
colour, flavour or fragrance. Associated variation types that you can include with DFFC are:
• ZFSM: ARTG data - Manufacturer changes associated with DFCI or DFFC
• ZFSV: ARTG data - Visual identification changes associated with DFCI or DFFC.
1.4.3 Category 3 requests - Data evaluation required under s. 23

(separate and distinct good) – Retaining AUST R number
These variations fall under s. 23 of the Therapeutic Goods Act 1989 and require the submission
of data for evaluation.
DFCF: Formulation – changes (CE) – Retaining AUST R number

Proposed changes to the excipients in the drug product where the Therapeutic Goods (Groups)
Order No. 1 of 2001allows the AUST R number to be retained.
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The AUST R number can be retained

Under s. 16(1) of the Therapeutic Goods Act 1989, a change in formulation
means that the reformulated product is a separate and distinct good from the
existing product, and this requires a new ARTG entry.
However, the provisions of the Therapeutic Goods (Groups) Order No. 1 of
2001 allow the AUST R number of the existing product to be retained for the
new product if the new product replaces the existing product, for certain types
of formulation changes.
The following formulation changes allow the current AUST R number to be
retained:
• removal or addition of fragrance, flavour, ink or colour
• change in existing quantity of excipients (but not total removal).
Any other formulation changes will result in a new AUST R number, see
variation type DFNA: Formulation - changes (CE) – New AUST R number.
Conditions
• An excipient can only be removed from the formulation if it is a flavour, ink or colour.
Data requirements
This list of what to submit is not exhaustive and represents the minimum data necessary for
assessment. The TGA can request additional data or information from you in support of your
application.
You must submit:
• A copy of the current and revised formulation, and details of any new manufacturing process
and associated validation data.
Regulations 1990).
• Details of the specifications applicable to all the excipients used in the new formulation. If an
excipient was not used in the previous formulation, certificates of analysis issued by the drug
product manufacturer for two or three representative batches of the excipient should be
submitted.
• For excipients that are of ruminant origin:
- For all products that are implanted, injected or given by parenteral, ophthalmic or
intra-tracheal routes of administration, details of excipients derived from Category IC
tissues from transmissible spongiform encephalopathy (TSE)-relevant ruminant
species (including excipients whose manufacture may have exposed them to Category
IC materials) and measures taken by the manufacturers to minimise TSE risk.
- For products that are given by the oral, topical, vaginal, rectal or inhalation routes that
contain excipients derived from Category A or B materials (including excipients whose
manufacture may have exposed them to Category A or B materials) from TSE-relevant
ruminant species, details of all such excipients and measures taken by the
manufacturers to minimise TSE risk.
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- Products given by the oral, topical, vaginal, rectal or inhalation routes that contain only
excipients derived from Category IC TSE-relevant ruminant materials, details of the
excipients and a declaration that the Category IC material has been self-assessed and
complies with the TGA’s Supplementary information on Transmissible Spongiform
Encephalopathies regulation, together with an assurance that the sponsor will maintain
a record of compliance for future TGA compliance checks.
- Current Certificate of Suitability (CEP) issued by the European Directorate for the
Quality of Medicines and HealthCare (EDQM) to the manufacturer of the excipient. Not
all CEPs from the EDQM will be acceptable; this depends on the source country of the
animal and the parts of the animal used to manufacture the excipient, where relevant.
- Refer to Guidance 10: Adventitious agent safety of medicines for additional detail on
requirements for ingredients of human or animal origin.
• Relevant comparative data for the proposed new and currently approved drug products to
demonstrate that the change in formulation does not lead to changes in the physical
characteristics of the product that may affect the absorption and in vivo effect of the
medicine. For further guidance, see DMCM: Drug product manufacture – changes to the
method of manufacture.
• Where the change in formulation involves introduction of, or variation to, a range of values
for particular excipients, relevant validation of the manufacture and testing of the product
with excipient content at the extremes of the range may be required. Relevant guidance can
be found in the current Committee for Proprietary Medicinal Products (CPMP) guidance
document CPMP/QWP/486/95: Note for guidance on manufacture of the finished dosage
form adopted by the TGA.
• Certificates of analysis for at least one production-scale batch of the drug product
manufactured using the proposed new formulation. Pilot-scale batches are acceptable, if
justified.
• Stability data in accordance with relevant EMA/ICH guidelines. For minor formulation
changes, the sponsor may justify why relevant stability data need not be provided for
review. However, a commitment to carry out stability testing on at least three production-
scale batches of the reformulated product is required.
• Comparative bioavailability data may be required to establish bioequivalence of the new and
currently approved formulation (for example, if significant changes to the formulation are
made and this is likely to affect the bioavailability of the product). However, a justification
may be provided to demonstrate why such a study is not required. If bioequivalence data are
submitted, the application will be re-categorised as a Category 1 application. (For further
information on changes that are unlikely to affect bioavailability and provision of a
justification in lieu of bioavailability/bioequivalence data, see Guidance 15: Biopharmaceutic
studies).
• If the new formulation involves a change to the preservative system, additional data may be
required. These may include stability data (including microbial quality and proof of
antimicrobial efficacy of the drug product at expiry) and test methods (with accompanying
validation data) for determination of preservative content in the drug product. For
additional information, please refer to TGO 100 - Microbiological standards for medicines. If
relevant, revised labels may be required to provide information on the new formulation.
• A clean copy of the PI must be provided. Where the proposed change would involve
amendment of a PI, a marked-up copy should also be provided, as outlined in the Variations
to prescription medicines – excluding variations requiring evaluation of clinical or
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Associated changes
excipients in the formulation. Associated variation types that you can include with DFCF are:
• ZFRC: ARTG data – Container and shelf life changes associated with DFCF/PFCF or DTTR –
Retaining AUST R number
• ZFRM: ARTG data – Manufacturer changes associated with DFCF/PFCF or DTTR – Retaining
AUST R number
• ZFRN: ARTG data – Good name changes associated with DFCF/PFCF – Retaining AUST R
number
• ZFRO: Other consequential changes to the dossier associated with DFCF/PFCF or DTTR –
• ZFRP: ARTG data – Pack size and poison schedule changes associated with DFCF/PFCF or
DTTR – Retaining AUST R number
• ZFRS: ARTG data – Sterility changes associated with DFCF/PFCF or DTTR – Retaining AUST
R number
• ZFRV: ARTG data - Visual identification changes associated with a result of DFCF/PFCF or
DTTR – Retaining AUST R number.
1.4.4 Category 3 requests — Data evaluation required under s. 23

(separate and distinct good) – New AUST R number
These variations fall under s. 23 of the Therapeutic Goods Act 1989 and require the submission of
data for evaluation.
DFNA: Formulation changes (CE) – New AUST R number

Proposed changes to the formulation of the drug product which results in goods that require a
new AUST R number.
The AUST R number cannot be retained

Under s. 16(1) of the Therapeutic Goods Act 1989, a change in formulation
means that the reformulated product is a separate and distinct good from the
existing product, and this requires a new ARTG entry. The Therapeutic Goods
(Groups) Order No. 1 of 2001 only applies for certain types of formulation
changes.
For formulation changes that allow the AUST R number to be retained, see
variation type DFCF: Formulation changes (CE) – Retaining AUST R number.
Conditions
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Data requirements
This list of what to submit is not exhaustive and represents the minimum data necessary for
assessment. The TGA can request additional data or information from you in support of your
application.
You must submit:
• A copy of the current and revised formulation, and details of any new manufacturing process
and associated validation data.
Regulations 1990).
• Details of the specifications applicable to all the excipients used in the new formulation. If an
excipient was not used in the previous formulation, certificates of analysis issued by the drug
product manufacturer for two or three representative batches of the excipient should be
submitted.
• For excipients that are of ruminant origin:
- For all products that are implanted, injected or given by parenteral, ophthalmic or
intra-tracheal routes of administration, details of excipients derived from Category IC
tissues from transmissible spongiform encephalopathy (TSE)-relevant ruminant
species (including excipients whose manufacture may have exposed them to Category
IC materials) and measures taken by the manufacturers to minimise TSE risk.
- For products that are given by the oral, topical, vaginal, rectal or inhalation routes that
contain excipients derived from Category A or B materials (including excipients whose
manufacture may have exposed them to Category A or B materials) from TSE-relevant
ruminant species, details of all such excipients and measures taken by the
manufacturers to minimise TSE risk.
- Products given by the oral, topical, vaginal, rectal or inhalation routes that contain only
excipients derived from Category IC TSE-relevant ruminant materials, details of the
excipients and a declaration that the Category IC material has been self-assessed and
complies with the TGA’s Supplementary information on Transmissible Spongiform
Encephalopathies regulation, together with an assurance that the sponsor will maintain
a record of compliance for future TGA compliance checks.
- Current Certificate of Suitability (CEP) issued by the European Directorate for the
Quality of Medicines and HealthCare (EDQM) to the manufacturer of the excipient. Not
all CEPs from the EDQM will be acceptable; this depends on the source country of the
animal and the parts of the animal used to manufacture the excipient, where relevant.
- Refer to Guidance 10: Adventitious agent safety of medicines for additional detail on
requirements for ingredients of human or animal origin.
• Relevant comparative data for the proposed new and currently approved drug products to
demonstrate that the change in formulation does not lead to changes in the physical
characteristics of the product that may affect the absorption and in vivo effect of the
medicine. For further guidance, see DMCM: Drug product manufacture – changes to the
method of manufacture.
• Where the change in formulation involves introduction of, or variation to, a range of values
for particular excipients, relevant validation of the manufacture and testing of the product
with excipient content at the extremes of the range may be required. Relevant guidance can
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be found in the current Committee for Proprietary Medicinal Products (CPMP) guidance
document CPMP/QWP/486/95: Note for guidance on manufacture of the finished dosage
form adopted by the TGA.
• Certificates of analysis for at least one production-scale batch of the drug product
manufactured using the proposed new formulation. Pilot-scale batches are acceptable, if
justified.
• Stability data in accordance with relevant EMA/ICH guidelines. For minor formulation
changes, the sponsor may justify why relevant stability data need not be provided for
review. However, a commitment to carry out stability testing on at least three production-
scale batches of the reformulated product is required.
• Comparative bioavailability data may be required to establish bioequivalence of the new and
currently approved formulation (for example, if significant changes to the formulation are
made and this is likely to affect the bioavailability of the product). However, a justification
may be provided to demonstrate why such a study is not required. If bioequivalence data are
submitted, the application will be re-categorised as a Category 1 application. (For further
information on changes that are unlikely to affect bioavailability and provision of a
justification in lieu of bioavailability/bioequivalence data, see Guidance 15: Biopharmaceutic
studies).
• If the new formulation involves a change to the preservative system, additional data may be
required. These may include stability data (including microbial quality and proof of
antimicrobial efficacy of the drug product at expiry) and test methods (with accompanying
validation data) for determination of preservative content in the drug product. For
additional information, please refer to TGO 100 - Microbiological standards for medicines. If
relevant, revised labels may be required to provide information on the new formulation.
Associated changes
formulation. Associated variation types that you can include with DFNA are:
• ZFNC: ARTG data – Container and shelf life changes associated with DFNA/PFNA – For the
new AUST R number
• ZFNM: ARTG data – Manufacturer changes associated with DFNA/PFNA or PCCT – For the
new AUST R number
• ZFNN: ARTG data – Good name changes associated with DFNA/PFNA or PCCT – For the new
AUST R number
• ZFNO: Other consequential changes to the dossier associated with DFNA/PFNA or PCCT –
For the new AUST R number
• ZFNP: ARTG data – Pack size and poison schedule changes associated with DFNA/PFNA or
PCCT – For the new AUST R number
• ZFNS: ARTG data – Sterility changes associated with DFNA/PFNA or PCCT – For the new
AUST R number
• ZFNV: ARTG data – Visual identification changes associated with DFNA/PFNA or PCCT – For
the new AUST R number
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1.5 Drug product specifications or test changes
Certified product details (CPD) documents

An updated CPD document is usually provided when a change is made to
aspects of the drug product specifications, such as test requirements, limits of
acceptance or non-pharmacopoeial test methods.
If a self-assessable request results in changes to the product specifications or
the non-pharmacopoeial test methods, an updated and complete CPD
document must be provided in PDF format at the time of the request.
1.5.1 Notifications
DSAM: Drug product specification - changes to non-biological assay method

for an active or excipient that is not a radiopharmaceutical
Changes to a non-biological method used for assaying the API or excipients in a final drug
product that is not a radiopharmaceutical.
Conditions
• The product must not be a radiopharmaceutical.
• If the results obtained using the proposed method do not agree with the results obtained
during TGA testing, using an official method, the results from the official method will be
deemed to be correct.
• The proposed method must not be a biological method.
• The proposed method must not be a test method for impurities, related substances or
degradation products.
• Validation data from the proposed method must demonstrate either:
- an improvement in at least one of precision, accuracy or specificity, without a reduction

in the other parameters or
- an improvement in specificity or accuracy with reduced precision (providing precision

remains within the specified limits).
Data requirements
You must submit:
• Details of the proposed test method.
• Appropriate validation data for the proposed method.
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DSID: Drug product specification - changes to identification tests for the

active or excipient
Changes to the tests used to identify the API or excipients in the final drug product.
Conditions
• The changes to identification tests must:
- be from a less specific to a more specific identification test (for example, from an
ultraviolet/visible spectrophotometric or chromatographic method—such as thin layer
chromatography, gas chromatography or high-performance liquid chromatography
(HPLC) —to a conventional infrared spectroscopic method) and/or
- vary the existing identification test (for example, an HPLC test that demonstrably
improves or at least maintains the specificity of the method) and/or
- replace an existing identification test with a near infrared spectroscopic identification
test and/or
- include a new identification test in addition to an existing identification test.
• The method must be appropriately validated.
• Any additional identification test included cannot serve as an alternative identification test
(this should be submitted as a Category 3 application).
• If near-infrared spectroscopy is used, the method development and other data requirements
(including data collection, establishment of the spectral reference library, calibration and
validation of the method) must comply with the current EMA guideline on use of near-
infrared spectroscopy that has been adopted by the TGA.
Data requirements
You must submit:
• Details of the changes to the existing test or the new identification test.
• Appropriate validation data for the identification test.
DSIP: Drug product specification - changes from an in-house test method to

a pharmacopoeial test method
Changes to the specifications to ensure that the drug product complies with the requirements of
a default standard (i.e. a monograph in the BP, USP-NF or EP), where previously no default
standard applied.
Conditions
• Any changes can be made to assay and/or related substances test methods, but not to a
dissolution method which requires TGA evaluation of supporting data.
• The method must be appropriately validated.
Data requirements
You must submit:
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• Equivalency of the current and pharmacopoeial test method must be established by testing
of three batches of the drug product using the current and proposed methods.
DSNL: Drug product specification - narrowing of test limits

Revision of the approved specifications for testing of the final drug product, to make the limits
applied to test results more stringent.
Conditions
• The proposed limits must be consistent with applicable official standards or adopted
guidelines.
• There must be no change in test methods other than those allowed under change types:
- DSAM: Drug product specification - changes to non-biological assay method for an

active or excipient that is not a radiopharmaceutical
- DSIP: Drug product specification - changes from an in-house test method to a

pharmacopoeial test method
- DSPT: Drug product specification - changes resulting from pharmacopoeial or TGO

requirements
- DSPL: Drug product specification - minor changes to physicochemical test methods and
limits
Data requirements
You must submit:
• A statement of the current and proposed limits.
DSNT: Drug product specification - addition of test and limit

Addition of a new test and associated limits to the approved specifications for the final drug
product.
Conditions
• The proposed method must be validated.
• The proposed limit (release and expiry) of the new test must be based on batch data
obtained at product release and on storage for the duration of the shelf life of the product.
The limit must comply with any applicable official standard, TGO or adopted guidelines.
Data requirements
You must submit:
• A statement of the new test and limit.
• The revised set of product specifications at release and expiry.
• Details of the test method.
• Appropriate validation data for the test method.
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DSPL: Drug product specification - minor changes to physicochemical test

methods and limits
Minor changes to methods used to test physicochemical parameters of the final drug product.
Physicochemical parameters include pH, hardness, friability, colour, particle

size distribution, particulate matter contamination, density, specific gravity,
optical rotation, extractable volume, osmolality, osmolarity and viscosity.
Conditions
• The test limit should either remain unchanged or be more stringent.
• The amended method should have been validated.
Data requirements
You must submit:
• Appropriate validation data for the new method.
DSPT: Drug product specification - changes resulting from pharmacopoeial

or TGO requirements
Changes to the specifications for the final drug product as a result of amendments to
requirements in a default standard (i.e. a monograph in the BP, USP-NF or EP), or relevant
requirements in an applicable standard made by the Minister under section 10 of the Act.
Conditions
• The products must currently be tested to the existing pharmacopoeial or Therapeutic Goods
Order (TGO) requirements.
• Any tests that are performed in addition to those of the pharmacopoeial monograph or TGO
must continue to be performed.
• The requirements applied from one pharmacopoeia must not be changed to another, except
where the changes are allowed by other sections of this document (e.g. changing from USP to
BP is not permitted as a notification).
• The new pharmacopoeial monograph or amended TGO must be applicable to the product
and, if necessary, appropriate validation data must be generated.
• If the change involves updating microbiological test requirements for non-sterile products to
meet the TGO 100 - Microbiological standards for medicines, the product must have
undergone a risk assessment for objectionable microorganisms in addition to those specified
in the pharmacopoeias that form the basis of the TGO.
Data requirements
You must submit:
• The revised set of drug product specifications (release and expiry), if applicable.
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• If the change relates to an update to meet the requirements of the TGO 100 - Microbiological
standards for medicines, a written assurance that the TGA can review the risk assessment
report for objectionable microorganisms other than those specified in the order, if required.
• Appropriate validation data, as required.
DSST: Drug product specification - changes to sterility test method

Changes to the sterility test methods used for the final drug product.
Conditions
• All aspects of the test must comply with the requirements of the internationally harmonised
test published in a default pharmacopoeia and as specified in TGO 100 - Microbiological
standards for medicines.
• The change must comply with the guidelines on particular aspects of the sterility test that
are outlined in Guidance 17 - Microbial quality of prescription and over-the-counter
medicines.
Data requirements
You must submit:

DSCS: Drug product specifications - changes to specifications, including

changes to test methods
Any proposed changes to the specifications of the drug product can be submitted as part of this
Category 3 variation type.
Conditions
Data requirements
You must submit:
• A copy of the revised specifications at release and expiry.
• Justification for the proposed changes, including changes to test methods.
• Validation of any changed test methods. Method cross-validation data against alternative or
pharmacopoeial methods may also be required, if relevant.
• Certificates of analysis for at least two representative production-scale batches of the drug
product that demonstrate the product manufacturer’s ability to meet the revised
specifications. If pilot-scale batches were used for testing, this should be explained and
justified. Where appropriate, batch analytical data from aged samples may be necessary—
for example, to demonstrate compliance throughout shelf life.
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1.6 Excipients changes
Definition and conditions

An excipient is any component of a drug product other than the active
pharmaceutical ingredient.
Except as specified in EMRS below, changes to excipients of biological origin
(animal or human source) may not be made as a notification.

Excipients (not of animal or human origin) - changes to the manufacturing

process and/or site (same specifications)
You do not need to notify the TGA if you are making a variation that changes the manufacturing
process and site of manufacture of excipients of the same specifications (but excluding
excipients of animal or human origin).
1.6.2 Notifications
EMRS: Excipient manufacture (from Category IC ruminant tissues) - changes

in source (from animal to non-animal) and/or manufacturing process or
site
Changes to the source, manufacturing process or site of manufacture of excipients derived from
Category IC ruminant tissues (including from animal to plant or non-animal source).
Category IC ruminant tissues are defined in the TGA’s Transmissible

Spongiform Encephalopathies (TSE): TGA approach to minimising the risk of
exposure.
Conditions
• The product must only be intended for oral, topical, vaginal, rectal or inhalation routes, with
no potential for cross-contamination with higher risk (Category A or B) tissues.
• The product must not be administered by the parenteral, ophthalmic or intra-tracheal
routes.
• The change must be from a ruminant-derived source to a plant or other non-animal source.
• No changes to the specifications of the excipients are permitted, except for the changes
allowed within the changes to excipients section.
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Data requirements
You must submit:
• Details of the excipients and the proposed changes.
• Where relevant, CEP issued by the EDQM to the manufacturer of the excipient.
• A declaration that the Category IC material has been self-assessed and complies with the
TGA’s requirements regarding Transmissible Spongiform Encephalopathies (TSE) risks.
• An assurance that records of compliance will be maintained for future inspection by the TGA.
• The revised specifications, if changes have been made.
ESAM: Excipient specification - change to assay method

Changes to a method used for assaying an excipient.
Conditions
• The proposed method must either:
- improve at least one of precision, accuracy or specificity without a reduction in the

other parameters or
- the proposed method must improve accuracy or specificity with reduced precision
provided precision remains within the specified limits.
Data requirements
You must submit:
• Details of the new assay method.
ESIP: Excipient specification - change from an in-house to a pharmacopoeial

test method
Changes to the specifications to ensure that the excipient complies with the requirements of a
default standard (i.e. a monograph in the BP, USP-NF or EP), where previously no default
standard applied.
Conditions
• Change or addition must only be to test methods for physicochemical parameters (e.g. pH,
colour, particle size, particulate matter, density, specific gravity, optical rotation, osmolality,
osmolarity and viscosity).
official standard (TGO or default standard) or adopted guidelines.
for critical parameters (e.g. particle size, pH, viscosity) must continue to be performed.
V3.1 January 2020
Data requirements
You must submit:
• The revised set of specifications for the excipient.
• Validation data for the method(s), as required.
• Equivalency of the current and pharmacopoeial test method(s) must be established by
testing of three batches using the current and proposed methods.
ESNL: Excipient specification - narrowing of limits

Revision of the approved specifications for testing of excipients, to make the limits applied to
test results more stringent.
Conditions
• The proposed limits must be consistent with any applicable official standard (TGO or default
standard) or adopted guidelines.
Data requirements
You must submit:
• A statement of the current and proposed limits.
ESNT: Excipient specification - new test and limit

Addition of a new test and associated limits to the approved specifications for an excipient.
Conditions
official standard (TGO or default standard) or adopted guidelines.
Data requirements
You must submit:
• Details of the new test and limit, including the test method.
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ESPT: Excipient specification - changes resulting from pharmacopoeial or

TGO requirements
Changes to the specifications for an excipient as a result of amendments to requirements in a
default standard (i.e. monograph in BP, USP-NF or EP), or relevant requirements in an applicable
standard made by the Minister under section 10 of the Act.
Conditions
• The excipient must be tested to the existing pharmacopoeial or TGO requirements.
must continue to be performed.
• The new pharmacopoeial monograph or TGO must be applicable to the excipient.
Data requirements
You must submit:
• Details of the proposed change.

ESCS: Excipient specification – changes to the specifications of the

excipients, raw materials and starting materials
Any proposed changes to the specifications of the excipients, raw materials and starting
materials can be submitted as part of this Category 3 variation type.
This type of change includes replacement of one type of starch (for example,
wheat starch) with another type in a formulation, or changing the grade of an
excipient, with no change in quantity in the formulation.
Conditions
Data requirements
You must submit:
• A copy of the revised specifications.
• Justification for any new or changed limits or test methods.
• Validation of any changed test procedures for critical tests.
• Certificates of analysis for at least one representative batch of the excipient that
demonstrates the manufacturer’s ability to meet the revised specifications.
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• Where necessary (for example, when changing the grade of excipient or changing the type of
starch used in a product), relevant validation data, such as comparative dissolution profiles
and comparative batch data, that support the changed excipient.
EMPC: Excipients of animal origin – change to source

Any proposed changes to the source of excipients or animal origin can be submitted as part of
this Category 3 variation type.
Refer to Guidance 10: Adventitious agent safety of medicines, for additional

details on requirements for ingredients of human or animal origin.
Conditions
Data requirements
You must submit:
• For excipients derived from Category IC tissues from TSE-relevant ruminant species that are
used in products that are implants or injectable products given by the parenteral,
ophthalmic or intra-tracheal routes, or for excipients derived from Category A or B tissues
from TSE-relevant ruminant species (see the TGA’s Transmissible Spongiform
Encephalopathies (TSE): TGA approach to minimising the risk of exposure) used in products
given by the oral, topical, vaginal, rectal or inhalation routes:
- details of the excipients and the proposed changes.
- measures taken by the manufacturer to minimise TSE risks.
EMPM: Excipients of animal origin – change to method of manufacture

Any proposed changes to the method of manufacture of excipients of animal origin can be
submitted as part of this Category 3 variation type.
Refer to Guidance 10: Adventitious agent safety of medicines, for additional

details on requirements for ingredients of human or animal origin.
Conditions
Data requirements
You must submit:
• For excipients derived from Category IC tissues from TSE-relevant ruminant species that are
used in products that are implants or injectable products given by the parenteral,
ophthalmic or intra-tracheal routes, or for excipients derived from Category A or B tissues
from TSE-relevant ruminant species (see the TGA’s Transmissible Spongiform
V3.1 January 2020
Encephalopathies (TSE): TGA approach to minimising the risk of exposure) used in products
given by the oral, topical, vaginal, rectal or inhalation routes:
- details of the excipients and the proposed changes
- measures taken by the manufacturer to minimise TSE risks.
1.7 Container/closure system changes

Non-sterile container - changes to the supplier or manufacturer if same

material and specifications
You do not need to notify the TGA if you are making a variation that changes the supplier or
manufacturer of non-sterile containers or container components.
Conditions
• The same material type and specifications must be retained.

CACI: Correct an ARTG entry - container information

Requires update to ARTG data: Container & Shelf Life.
Conditions
Data requirements
You must submit:
request.
V3.1 January 2020
1.7.3 Notifications
These variations fall under s. 9D(2C) of the Therapeutic Goods Act 1989.
CCCA: Container/closure - change to components

Changes to outer packaging or components of the container that are not in direct contact with
the drug product.
For sterile products, the container components that are being changed are not
required to be sterile.
Conditions
• The change is restricted to one or more of the following:
- a change to, or addition or removal of, the outer carton or other outer primary pack
(including changes to size, shape, colour or material thickness); and/or
- a change to, or addition or removal of, components of the container that are not in
direct contact with the product (for example, tamper-evident seal, aluminium flip-off
crimps on injection vials, plastic dust-cover disc/top/cap); and/or
- the inclusion or removal of inert wadding from bottles and other containers containing
solid dosage forms; and/or
- the inclusion of a desiccant in containers of solid dosage forms; and/or
- the inclusion of, or change to, an outer overwrap designed to prevent ingress or egress
of moisture, solvent or gases from a container (including changes to size, shape or
colour, or increased material thickness).
• Other than inert wadding and desiccant, the components must not be in direct contact with
the product.
• The label of any outer carton or other primary pack that is added or changed must either be
identical to the container label or be changed as permitted under:
- Changes to product labels that are notifications and/or
- Changes that do not require TGA prior approval.
• Where an existing carton or primary pack is removed, the container label must either remain
unchanged or be changed as permitted under:
- Changes to product labels that are notifications and/or
- Changes that do not require TGA prior approval and must continue to meet all
requirements of the TGO that relates to labels.
• No change can be made to the product’s shelf life or storage conditions as a notification. For
self-assessable (SAR) changes to the shelf life or storage conditions see:
- DSLE: Shelf life - Extension according to an approved stability-testing protocol and
- DSLD: Shelf life - Decrease and/or more restrictive storage conditions.
V3.1 January 2020
the specifications. The product in the new container system may be withdrawn from the
market at the TGA’s discretion.
Data requirements
You must submit:
• Details of the change(s).
• Where a desiccant is included in a container, an assurance that the desiccant is used to
improve the existing acceptable stability profile of the product and is not used to overcome
stability problems in the existing container.
• Where a desiccant is included in a container, information on the nature of the desiccant, as
well as information showing that the desiccant is readily distinguishable from the product,
and is appropriately labelled and identified as a desiccant.
• If an overwrap is introduced, the rationale for its inclusion, and details of the material of the
overwrap and specification.
• Where applicable, comparative data to demonstrate the removal of inert wadding has not
adversely affected the product’s friability and other physical attributes during normal
transport.
• Where an overwrap is introduced or changed, a stability study to verify the product shelf life
of the product with the overwrap must have commenced at the time of the notification on at
least one production-scale batch of the product, and should continue on the second and third
batches as they are manufactured.
CCSS: Container/closure - change to size and shape for non-sterile dosage

forms
Changes to the size and shape of the container or closure system used for drug products that are
non-sterile dosage forms.
Conditions
• The change must not result in a change to the container type.
• If the container is a blister pack or strip pack, the change in size or shape must not result in
an increase in the headspace volume of the blister-pack or strip-pack pocket.
• If the container is a reclosable package, there must not be an increase in the headspace of the
container.
• The material and thickness of the container/closure system must be either unchanged or
changed in a manner permitted under variation types:
- CMIT: Container/closure material - increase in thickness for non-sterile solid, semi-

solid, semi-liquid or liquid dosage forms and/or
- CMDT: Container/closure material - decrease in thickness for blister packs, strip packs
and sachets for non-sterile solid or semi-solid dosage forms.
V3.1 January 2020

• No change can be made to the quantity of products in the new container/closure system.
Data requirements
You must submit:
• Details of the new container/closure system, with specifications, if relevant.
• If the closure is a child-resistant cap, or implied by its presentation and construction to be
one, a declaration that the reclosable package meets all of the requirements of the current
TGO on child-resistant packaging. The declaration must state, in particular, which of the
recognised international standards on child-resistant packaging the closure complies with,
and include evidence of adequate directions for opening and reclosing the package.
• If the container is a reclosable package and is child-resistant (or is implied by its
presentation to be a child-resistant package), data must have been generated to demonstrate
that the child-resistant properties of the package and operation of the closure have not been
adversely affected by the change in size and shape.
• For solid oral dosage forms, comparative moisture permeability (water-vapour
transmission) data must have been generated on the new and current container systems
using the current edition of the USP test for containers—permeation (multi-unit or single-
unit containers, as appropriate), and the results must show either equivalent or better
moisture protection.
• A stability study using the new container/closure system to verify the product shelf life must
have been initiated on at least one production-scale batch of the product (with at least two
more production batches to be similarly tested).
CCST: Container/closure - changes to specification and test methods

Changes to the specifications for the container or closure system of the final drug product, to
include new tests, make specified limits more stringent, delete a test procedure or make minor
changes to test methods.
Conditions
• There must be no change to container dimensions or components, other than those specified
in:
- CCSS: Container/closure - change to size and shape for non-sterile dosage forms and/or
- CCCA: Container/closure - change to components.
• The limits applied must be based on batch analytical data, and comply with any applicable
official standard or relevant guidelines adopted by the TGA.
• The packaging components must remain compliant with pharmacopoeial requirements and
food standards.
• The change does not result from unexpected events arising during manufacture.
V3.1 January 2020
Data requirements
You must submit:
• Updated specifications and test methods.
• Validation data for the proposed method demonstrating that the updated test procedure is
at least equivalent to the former test procedure.
CMDT: Container/closure material - decrease in thickness for blister packs,

strip packs and sachets for non-sterile solid or semi-solid dosage forms
Decrease in the thickness of aluminium foil, or laminate material used in laminated aluminium
foil, for blister packs, strip packs and sachets containing non-sterile solid or semi-solid drug
products.
Conditions
• The product must be a non-sterile dosage form.
• The material that is decreased in thickness must be either the aluminium foil or, in the case
of a laminated aluminium foil, the aluminium foil itself or any non-aluminium polymeric
material laminated to it.
• The new aluminium foil thickness or the aluminium component of the laminated foil must be
at least 20 μm.
• The container/closure material must be unchanged.
• No change should be made to the product’s shelf life or storage conditions. See self-
assessable changes to the shelf life or storage conditions.
Data requirements
You must submit:
• Details of the change in thickness of the container material, with specifications, if relevant.
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CMIT: Container/closure material - increase in thickness for non-sterile

solid, semi-solid, semi-liquid or liquid dosage forms
Increase in the thickness of the material used for the container or closure system of non-sterile
solid, semi-solid, semi-liquid or liquid drug products.
Conditions
• The container/closure material must be unchanged.

Data requirements
You must submit:
• Details of the change in thickness of the container/closure material, with specifications, if
relevant.

CMBP: Container/closure material - changes to material used for blister

packs, strip packs and sachets of non-sterile dosage forms
Changes to the material of a container/closure system - blister packs, strip packs and sachets.
Conditions
• The product should be a non-sterile solid (such as tablets or capsules) or semi-solid dosage
form (such as moulded suppositories and pessaries) in blister packs, strip packs or sachets.
• The plastic component of the container may be changed from:
- PVC to PVC/polyvinylidine chloride (PVDC) or PVC/polychlorotrifluoroethylene

(PCTFE) or PVC/PVDC/PE; or
- PVC/PVDC to PVC/PCTFE or PVC/PVDC/PE; or
- polypropylene to PVC/PVDC or PVC/PVDC/PE; or

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- PVC to polypropylene; or
- any type of plastic material to double aluminium foil blister packs (cold-formed
laminated aluminium/aluminium blister packs) or double aluminium foil strip packs.
• Any new plastic material used should meet current pharmacopoeial (BP/Ph. Eur./USP)
requirements for plastic materials used for the manufacture of containers.
• Comparative moisture permeability (water-vapour transmission) data should have been
generated on the new and current blister-pack or strip-pack system using the current
edition of the USP test for containers—permeation (single-unit containers and unit-dose
containers), and the results should show either equivalent or better moisture protection.
• A stability study using the new container system to verify the product shelf life should have
begun on at least one production-scale batch of the product, and should begin on the second
and third batches as they are manufactured.
• If the results of the stability study fail to meet the specifications, the TGA should be notified
as a priority, and the product in the new container system may be withdrawn from the
• No change should be made to the product’s shelf life or storage conditions. See subsection
Product shelf life or storage conditions changes for self-assessable changes to the shelf life or
storage conditions.
Data requirements
You must submit:
• Details of the new container material, including specifications, if relevant.
• Where the proposed change requires an update to the PI, details of the amended PI, as
outlined in the Variations to prescription medicines – excluding variations requiring
evaluation of clinical or bioequivalence data; Process guidance.
CMBT: Container/closure material - changes to material used for bottles,

jars and tubes of non-sterile dosage forms
Changes to the material of a container/closure system - bottles, jars and tubes.
Conditions
• The product should be a non-sterile solid dosage form (for example, tablets, capsules,
compressed pessaries and suppositories) or a non-sterile semi-solid, semi-liquid or liquid
(for example, ointment, gel, cream, lotion, oral solution or suspension).
• The material of which the container/closure system (including a reclosable package) is made
may be changed from:
- polystyrene to polyvinyl chloride (PVC), polyethylene (PE), polypropylene or glass; or
- PVC to PE, polypropylene or glass; or
- PE to glass or polypropylene with a density of at least 0.89; or
- PE of one density to PE of a higher density; or
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- glass, metal or PE with a density of at least 0.95 to polypropylene with a density of at

least 0.89.
• Any new plastic material used should meet current default standard (BP/Ph. Eur./USP)
requirements for materials used for the manufacture of containers, as well as any other
guidelines adopted by the TGA.
• If the product is a semi-solid, a semi-liquid or a liquid, it should be water-based and should
not contain organic solvent.
• If the container and/or closure system is a child-resistant package or is implied by its
presentation to be a child-resistant package, data should have been generated to
demonstrate that the child-resistant properties of the package and operation of the closure
have not been adversely affected by the change in material, in accordance with the current
TGO on child-resistant packaging of medicines.
• If the product is a solid dosage form, comparative moisture permeability (water-vapour
transmission) data should have been generated on the new and current container/closure
systems using the current edition of the USP test for containers—permeation (multi-unit
containers), and the results should show either equivalent or better moisture protection.
• A stability study using the new container/closure system to verify the product’s shelf life
should have started on at least one production-scale batch of the product, and should begin
on the second and third batches as they are produced.
• If the results of the stability study fail to meet the specifications, the TGA should be notified
as a priority after the failure is detected, and the product in the new container/closure
system may be withdrawn from the market at the TGA’s discretion.
• No change should be made to the product’s shelf life or storage conditions. See subsection
‘Product shelf life or storage conditions changes’ for self-assessable changes to the shelf life
or storage conditions.
Data requirements
You must submit:
• Details of the new container/closure system, including any new material used and the
material or container specifications (where relevant).
• If the closure is a child-resistant cap (or is implied by its presentation and construction to be
a child-resistant cap), a declaration that the reclosable package meets all of the requirements
of the current TGO on child-resistant packaging. The declaration should state, in particular,
which of the recognised international standards on child-resistant packaging the closure
complies with, and include evidence of adequate directions for opening and reclosing the
package.
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CCSC: Container/closure system - changes to container components and/or

dimensions
Any proposed changes to the components or dimensions of the container or closure system (or
specifications for the container or closure system) can be submitted as part of this Category 3
variation type. This includes container shape, size and material, as well as any measuring or
delivery system included in the pack, but excludes container type. For changes to container type
see PCCT: Packaging - changes to container type – New AUST R number.
Note: If your entry allows the medicine container to be made of alternative materials (for
example glass and plastic ampoules; PVCD/ aluminium and PVC/ aluminium blisters) you will
need to include separate Container & Shelf Life details for each container material. Include these
details in both the cover letter and the comments field of the application.
Conditions
Data requirements
You must submit:
• Description and specifications of container/closure system and materials.
• If relevant, biomaterial safety evidence that any new polymeric or rubber container/closure
materials that are in contact with the product are free from leachable toxic impurities and
comply with BP/Ph. Eur./USP and Australian requirements for polymeric materials used in
packaging of medicines.
• Relevant stability data if the packaging may be expected to be less protective than the
currently approved packaging, or if the change may affect the stability of the product;
otherwise, a commitment to generate such data according to relevant stability guidelines
and in accordance with GMP requirements. Comparative moisture permeability data of the
current and proposed container/closure system may be required.
• Validation data on the changed measuring/delivery system in the pack, if relevant.
• If the container/closure system is a child-resistant package or is implied by its presentation
to be a child-resistant package, a declaration that the reclosable package meets all of the
requirements of the current TGO on child-resistant packaging. State in the declaration which
of the recognised international standards on child-resistant packaging the closure complies
with, and include evidence of adequate directions for opening and reclosing the package.
• For sterile products, sterile manufacture information and sterility testing data, as
appropriate, including information such as validation of aseptic processes and preservative
efficacy test data.
• Revised labelling, instructions for use and any other appropriate information or data that
relate to the change, if applicable.
• For non-sterile multi-dose oral liquid or suspension products, preservative efficacy test data.
V3.1 January 2020

(separate and distinct good) – New AUST R number
PCCT: Packaging - changes to container type – New AUST R number

Any proposed changes to the container type can be submitted as part of this Category 3 variation
type.
The AUST R number cannot be retained

Under s. 16(1) of the Therapeutic Goods Act 1989, a change in container type
means that the repackaged product is a separate and distinct good from the
existing product, and this requires a new ARTG entry. The provisions of the
Therapeutic Goods (Groups) Order No. 1 of 2001 do not apply so it is not
possible for the current AUST R number to be used for the new product.
Conditions
Data requirements
You must submit:
• Description and relevant specifications of container/closure system and materials.
• The proposed shelf life and storage conditions in the new container type.
• Stability data (including physical, chemical and microbiological aspects, as applicable) from
at least three production-scale batches, to confirm the stability of the product in the
proposed new container. Stability data obtained only from pilot scale batches should be
justified.
Regulations 1990).
• For sterile products, information on sterile manufacture, validation of sterilisation
processes, preservative efficacy data and sterility testing data, as appropriate.
• If relevant, biomaterial safety evidence may be required. This is assessed on a case-by-case
basis.
• For non-sterile products, details of the revised manufacturing process in the new container,
together with process validation data, if appropriate.
• Proposed labels for the product in the new container type.
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Associated changes
container. Associated variation types that you can include with PCCT are:
• ZFNM: ARTG data – Manufacturer changes associated with DFNA/PFNA or PCCT – For the
new AUST R number
• ZFNN: ARTG data – Good name changes associated with DFNA/PFNA or PCCT – For the new
AUST R number
• ZFNO: Other consequential changes to the dossier associated with DFNA/PFNA or PCCT –
• ZFNP: ARTG data – Pack size and poison schedule changes associated with DFNA/PFNA or
• ZFNS: ARTG data – Sterility changes associated with DFNA/PFNA or PCCT – For the new
AUST R number
• ZFNV: ARTG data – Visual identification changes associated with DFNA/PFNA or PCCT – For
the new AUST R number
1.8 Pack size changes
Pack size definitions

For products presented as:
• discrete dosage units (for example, tablets, capsules, compressed or
moulded suppositories, pessaries, or other single-dose medicine inside a
container), the pack size is the number of units in the container.
• non-sterile solid, powder, semi-solid and liquid products, the pack size
is the weight or volume of the container contents.
• injections and other sterile preparations, the pack size is the number of
ampoules, vials, prefilled syringes, bags, bottles and so on per primary pack
(carton).
• transdermal patches, the pack size is the number of patches per primary
pack (carton).
• pressurised metered-dose preparations or dry powder inhalers, the
pack size is the nominal number of doses in the container.
• non-pressurised metered-dose preparations, the pack size is the
minimum number of doses in the container, or the volume or weight of the
container contents.
Volume of fill of a sterile product is defined as the nominal volume of solution
in the container, the total content of which represents the strength of the
product as listed on the label. It may include an overfill.
Inclusion of a new volume of fill, or a change in the existing nominal volume of
fill of an injection or a peritoneal dialysis solution is considered under the
legislation as a change in product strength and requires a Category 1
application.
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CAPS: Correct an ARTG entry – pack size & poison schedule

Requires update to ARTG data: Pack Size & Poison Schedule.
Conditions
Data requirements
You must submit:
request.

PSAC: Pack size - addition or change to pack size excluding volume of fill of
injections or other sterile preparations
Conditions
• The change should not be a change in the volume of fill of an injection or other sterile
preparation.
• The change should be:
- the result of a Pharmaceutical Benefits Advisory Committee recommendation
(including a larger pack size); or
- to introduce a smaller pack size; or
- to delete an existing pack size that is no longer to be supplied.
• The change in pack size should not be accompanied by changes to dosage regimen or
indications.
• The label for the new pack size should be the same as for the current pack size, except for
quantity of products or other changes allowed under section K, below, and/or Part 6 of this
document.
• The additional or changed pack size should be consistent with the treatment
recommendations in the PI.
• The container material, size and shape should be either unchanged or changed in a manner
permitted in other sections of this document.
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Data requirements
You must submit:
• Relevant details regarding the change in pack size.
• A copy of the label for the new pack size.
• Where the proposed change requires an update to the PI, details of changes to the PI, as

PSCA: Pack size - change to, or addition of, pack size

Any proposed changes to the pack size can be submitted as part of this Category 3 variation type.
Conditions
Data requirements
You must submit:
• Details of the new or additional pack size, and the rationale for its introduction.
• Revised labelling, if applicable.
1.9 Product shelf life or storage conditions changes
Pre-approved stability-testing protocols

Stability-testing protocols can be approved in advance, so that the shelf life of a
product can be extended through self-assessment. Such protocols may be
submitted with the application for registration of a product or with an
application to vary the registration. When a stability-testing protocol is
submitted, at least 12 months of stability data should be available for the
product (or a closely related formulation) in the marketed container or a less
protective container.
• Any stability-testing protocol proposed for this purpose should include:
• Information on the number of batches to be tested (minimum of three
production-scale batches) and container/closure to be used
• A statement of the proposed tests and methods
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• A matrix indicating the time points at which each of the tests will be
conducted, including storage conditions and duration
• Acceptance limits for the results for each test. Some test limits (particularly
those with quantitative results, such as assay, dissolution/disintegration,
and impurities/degradation products) should be more stringent than the
approved expiry limits, but not necessarily as stringent as the release
limits.

CASL: Correct an ARTG entry - shelf life / storage condition

Conditions
Data requirements
You must submit:
request.

DSLD: Shelf life - decrease and/or more restrictive storage conditions

If changes to shelf life or storage conditions are requested because of a problem with stability,
data are required for evaluation, and the variation is not self-assessable.
Conditions
• Adequate stability data for at least three production-scale batches of the product should
have been generated to support the new shelf life and/or storage conditions.
• Where relevant, product labels and the PI should be changed to reflect the new storage
conditions and/or shelf life.
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Data requirements
You must submit:
• Reasons for the change.
• Details of the new shelf life and/or storage conditions.
• A copy of the revised product labels.
DSLE: Shelf life - extension according to an approved stability-testing

protocol
Conditions
• This does not apply to the in-use shelf life for multi-dose products.
• A stability-testing protocol should have been previously approved by the TGA through self-
assessment, explicitly for the purpose of extending the shelf life. See the definition of a pre-
approved stability-testing protocol above.
• At least three production-scale batches of the product should have been tested in accordance
with the approved stability-testing protocol.
• The extended shelf life should not be longer than the time for which stability data meeting
the approved protocol requirements are available, and should not be longer than five years.
• The extended shelf life should not be based on extrapolation of the stability data generated
according to the approved protocol.
Data requirements
You must submit:
• Evidence that the TGA has approved the protocol for the purpose of shelf life extension
through self-assessment. See the definition of a pre-approved stability-testing protocol
above.
• The new shelf life and storage conditions.

DSLC: Shelf life - changes to the shelf life or storage conditions of the drug
product.
Any proposed changes to the shelf life or storage conditions of the drug product can be
submitted as part of this Category 3 variation type.
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Conditions
Data requirements
You must submit:
• Stability data generated according to ICH guidelines on at least three production-scale
batches to support the change. Data from fewer batches or pilot-scale batches may be
acceptable, if justified.
• Revised labelling, if the storage conditions are to be changed.
• For increases in shelf life of multi-dose liquid products, preservative efficacy data, as
specified in TGO 100 (see Guidance 17: Microbial quality of prescription and over-the-
counter medicines).
1.10 Product information (PI) changes: Quality aspects,

corrections and self-assessable requests (SARs)
The changes listed here are to the quality aspects of the product information, corrections to the
PI and SARs. For safety related requests, minor editorial changes and extension of indications
see Part 2: Product information (PI) changes.
Consequential changes to the product information

Changes to the PI that are a consequence of a quality change do not require a
separate variation type to be selected. These PI changes should be submitted
with the quality change request. See Consequential changes to the product
information that result from variations to an ARTG entry in Variations to
prescription medicines – excluding variations requiring evaluation of clinical
or bioequivalence data; Process guidance.
A single PI often refers to multiple ARTG entries (products). If the affected PI
refers to additional ARTG entries that are not selected in Variation e-form then
these additional ARTG entries should be listed in the application cover letter
and comments field of the Variation e-form. A statement should be included
requesting that the PI for these additional products is also varied.

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CAPI: Product Information (PI)

Conditions
• The correction does not involve subsection 9D(2) and subsection 9D(3) changes to the PI.
Data requirements
You must submit:
request.
• A clean and marked-up copy of the draft revised PI.

PIAE: PI - adding the names of excipients in the product

Adding the names of excipients in the product, whether or not those excipients are referred to in
the TGO pertaining to labels.
Conditions
• Any included technical information should be accurate and should be obtained from
recognised reference sources.
• All names and terminology used in the PI should be Australian approved names or entered
in the TGA eBusiness Services code tables.
• Products should not be supplied with a new PI until the change has come into effect.
• The approved amended PI should be updated on the TGA website when the proposed
changes come into effect.
Data requirements
You must submit:
• Details of changes to the PI, as outlined in the Variations to prescription medicines –
excluding variations requiring evaluation of clinical or bioequivalence data; Process
guidance. If the amendments are necessary because of other regulatory actions that have
already been approved or notified, evidence of such approval or notification.
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PICA: PI - adding the Chemical Abstracts Service (CAS) number, molecular

formula/weight and/or chemical structure/nomenclature of the API
Adding the Chemical Abstracts Service (CAS) number, chemical structure, molecular formula,
molecular weight and/or chemical name/nomenclature of the API.
Conditions
Data requirements
You must submit:
PIPD: PI - changing the PI of radiopharmaceuticals to give instructions that

the patient dose should be measured immediately before administration
Conditions
Data requirements
You must submit:
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PIPS: PI - changing the name, address or other details of the product’s

sponsor or distributor
Conditions
Data requirements
You must submit:
PIRI: PI - changing the PI of radiopharmaceuticals to give instructions/

information on radiation protection and safety of user and patient
These may include radiation shielding data, decay charts, procedures to minimise radiation
doses to staff and unintended doses to patients, and references to guidelines and codes of
practice relating to radiation protection.
Conditions
Data requirements
You must submit:
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PISR: PI - putting into effect the guidelines in section 20.2 of Guidance 20:
Radiopharmaceuticals
Conditions
Data requirements
You must submit:

The changes listed here are representative, rather than exhaustive.
PICC: PI - changes to quality aspects of the product information

Proposed quality-related changes to the ARTG entry resulting in changes to the PI that are not
described above may be submitted as this variation type. However, changes to the PI that are a
consequence of a quality change do not require a separate variation type to be selected. These PI
changes should be submitted with the quality change request. See Consequential changes to the
product information that result from variations to an ARTG entry and Multiple related changes
in Variations to prescription medicines – excluding variations requiring evaluation of clinical or
Note that safety-related changes to the PI must be separately submitted as a SRR.
Conditions
Data requirements
You must submit:
• A description of the proposed changes to the PI.
guidance.
• Relevant technical data to support the proposed change(s).
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1.11 Product label changes
Requirements for labels

Mandatory labelling requirements for prescription medicines are set out in the
Therapeutic Goods Order (TGO) that pertains to labels, as amended from time
to time. It is the sponsor’s responsibility to ensure that their product labels
meet any state and territory government requirements.
Multiple related and unrelated changes to the label

Multiple changes to the label may not require the selection of multiple
variation types. For information and an example on submitting multiple
unrelated changes to medicine labels see Variations to prescription medicines
– excluding variations requiring evaluation of clinical or bioequivalence data;
Process guidance.
Consequential changes to the label (changes to the label that are a
consequence of a quality change) do not require a separate variation type to
be selected. These label changes should be submitted with the quality change
request. See Multiple related changes with an example in the process guidance.

You do not need to notify the TGA if you are making the following variations to a label:
• change to AUST R number following an approved change that requires a new AUST R
number (e.g. new formulation)
• inclusion or removal of, or changes to, sponsor or supplier telephone/facsimile number,
email address, barcodes, ABN or Australian Company Number, product code number, patent
number, recycle logo and associated text, trademark and other such symbols
• inclusion or removal of date of manufacture of product
• inclusion or removal of foreign national registration number or serialisation pharmacode
(e.g. EU pharmacode)
• inclusion or removal of, or changes to, name and address of supplier in New Zealand
• change of typeface and increase in font size of print only
• change in web address, without a change in the content of the website
• change to the prefix used for batch and/or expiry details
• change in location of the prefix used for batch and/or expiry details.
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Conditions
• There must be strictly no other changes and the minimum letter height requirements of the
therapeutic goods order pertaining to labels are still observed.
• A change to barcodes may include 2-D matrix codes but not quick response [QR] codes.
• Other symbols that may be changed include ®, © and ™.
• The prefixes must be one of those stated in Section 6 of the Therapeutic Goods Order No. 91.
The batch number of the medicine must be preceded by the batch number prefix and the
expiry date of the medicine is preceded by the expiry date prefix.
1.11.2 Notifications
LOCI: Label - consequential change resulting from a change approved under

subsection 9D(3) or conditions imposed under subsection 28(3)
Conditions
• There must be no other changes to the label made under this change request.
• The changes must ensure continued compliance with the relevant TGO pertaining to labels
and not contravene labelling best practice.
Data requirements
• Copies of the existing labels (with tracked changes) and final copies or mock-ups of the
amended labels (for each strength, where applicable) which include any logos, design work
or graphics. The copies must be to scale and verify the size/dimensions of the labels and
indicate the colours to be used. Where there are multiple pack sizes available, one
representative label can be provided for each strength, as long as the only difference
between the labels is the pack size.
• Evidence of the approval of the previous change (such as a TGA submission number).
LPCL: Label – addition or deletion of, or change to, the company logo or
livery
Conditions
Data requirements
You must submit:
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LPCP: Label - addition or deletion of, or change to, the pictogram of a

product or its dosage form
Conditions
• The addition or change of a pictogram of a product or its dosage form must only be designed
to clarify information about the medicine which is useful for the patient, to the exclusion of
any element of a promotional nature.
• The change must not involve removal of information relating to the safe use of the product.
Data requirements
You must submit:
LPCS: Label – addition or deletion of, or change to, the name or address of
the Australian sponsor or supplier of the product
Conditions
• The new name or address must be the same as amended on the register.
Data requirements
You must submit:
LPDG: Label – deletion of existing graphics, pictures or diagrams, and any

associated text
Conditions
• The change must not involve removal of information relating to the safe use of the product.
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Data requirements
You must submit:
LPDR: Label - deletion of repeated text (present elsewhere on a label) from

selected side panels provided that the information is not mandatory
Conditions
Data requirements
You must submit:
LPIA: Label - addition of simple instructional/informational/anti-tampering

statements or information about a changed appearance of the dosage form
Conditions
Data requirements
You must submit:
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LPOP: Label - addition or deletion of, or change to, label text of outer
protective pouches or overwraps of the container or primary pack
Conditions
• The new text must not be confusing, promotional or contradictory to text on the container or
primary pack labels
Data requirements
You must submit:
LPPS: Label - adding information either on label or as insert advising of

patient support program (PSP)
Conditions
• All references to Patient Support Progams (PSPs) must have the following disclaimer
prominently stated - "Patient Support Program complies with the Medicines Australia code
of conduct, however it is not authorised or approved by the Therapeutic Goods
Administration".
Data requirements
You must submit:
indicate the colours to be used.
• Where there are multiple pack sizes available, one representative label can be provided for
each strength, as long as the only difference between the labels is the pack size.
LPQR: Label - inclusion of QR code

Conditions
• The link must be for an Australian owned and managed company and must not include any
element of a promotional nature.
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Data requirements
You must submit:
LPRP: Label - removal of phrases such as ‘New formulation’, ‘New

appearance’ after a period of time.
Conditions
• There must be a sufficient period of time that has elapsed to advise the market of the new
product.
Data requirements
You must submit:
LQAE: Label - addition of excipients

Inclusion of the names of excipients on the medicine label, regardless of whether the substances
must be declared on a label to comply with a Ministerial standard.
Conditions
Data requirements
You must submit:
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LQAT: Label - amendment of expression of API content in topical

preparations as previously approved
Amendment to the expression of the proportion of active ingredient in a topical preparation.
Conditions
Data requirements
You must submit:
LQHI: Label - addition of 'hypotonic', 'hypertonic' and 'isotonic' for large-

volume injections
Addition of the terms hypotonic, hypertonic and isotonic on the labels of large-volume
injections.
Conditions
Data requirements
You must submit:
LQRT: Label - addition of a previously approved release rate for

transdermal patches
Addition of an approved release rate on the label of medicines that are transdermal patches.
Conditions
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Data requirements
You must submit:
• For changes to labels resulting from other regulatory actions that have been either already
notified or approved, appropriate evidence of the notification or approval (such as a TGA
submission number).
LWAH: Label - addition of a warning or cautionary statement where an

incorrect route for method of administration is hazardous
Addition of a warning or cautionary statement to a medicine label, to indicate that an incorrect
route or method of administration may be hazardous (e.g. ‘Not for injection’, ‘For external use
only’ and ‘Not for oral use’).
Conditions
Data requirements
You must submit:
LWSR: Label - changes to/addition of a warning or precaution statement

resulting from an approved safety-related variation to the PI
Change to, or addition of, a warning or cautionary statement on the medicine label, resulting
from or relating to a safety-related variation to the entry in the Register for the product made by
the Secretary under subsection 9D(2) of the Act, and an associated variation to the Product
Information for the product made by the Secretary under subsection 25AA(4) of the Act.
Conditions
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Data requirements
You must submit:
submission number).

LOAI: Label - addition of a new TGA-approved route of administration for

injectable medicines
Conditions
Data requirements
You must submit:
submission number).
LOCA: Label - changes as a result of approved corrections made to an entry

in the ARTG
Proposed changes as a result of approved corrections can be submitted as this variation type.
However, for changes to labels as a consequence of another change that are requested at the
same time, a separate variation type is not required. For further information and an example see
Multiple related changes in Variations to prescription medicines – excluding variations requiring
V3.1 January 2020
Conditions
• The amendments are due to implementation of corrections that have been approved under s.
9D(1) of the Therapeutic Goods Act 1989.
Data requirements
You must submit:
submission number).
LOCN: Label - change to names of actives, excipients or dosage forms

resulting from changes in the AAN, ingredients database or code tables in
TGA eBS
Conditions
Data requirements
You must submit:
submission number).
V3.1 January 2020
LOEI: Label - changes to the method of expressing the content of active

ingredients or excipients, in accordance with the current labelling TGO
Conditions
• The change is minor, such as changing from ‘0.5 mg’ to ‘500 micrograms’.
Data requirements
You must submit:
submission number).
LOPR: Label - changes as a result of product rescheduling (following from

changes to the Poisons Standard)
Conditions
Data requirements
You must submit:
submission number).
LOPS: Label - amendments due to implementation of changes that do not

require prior approval from the TGA
Refer to this guidance for the types of variations included within ‘Changes that do not require
prior approval’ from the TGA. For information about reporting on changes that do not require
prior TGA approval see Variations to prescription medicines – excluding variations requiring
V3.1 January 2020
Conditions
• The change can apply to manufacturers who are also product sponsors.
• The change to the address is allowable provided the actual site location does not change.
Data requirements
You must submit:
submission number).
LOSA: Label - amendments resulting from the implementation of a SAR that

is either submitted simultaneously or has been previously approved by the
TGA
Proposed changes as a result of approved SARs can be submitted as this variation type.
However, for changes to labels as a consequence of another change that are requested at the
same time, a separate variation type is not required. For further information and an example see
Multiple related changes in Variations to prescription medicines – excluding variations requiring
Conditions
Data requirements
You must submit:
submission number).
V3.1 January 2020
LOTG: Label - changes to comply with current TGOs for labels that have
previously been evaluated and approved by the TGA
Conditions
Data requirements
You must submit:
submission number).
LPCO: Label - addition/deletion of, or change to, the statement of country of

origin or manufacture for imported products
Conditions
• All changes to the label must be identified in the request.
• The changes must ensure continued compliance with the relevant TGO pertaining to labels.
• The change results from a requirement by other relevant Australian legislation.
Data requirements
You must submit:
• Copies of the existing labels and final copies or mock-ups of the amended labels, including
any logos, designs or graphics. The copy should preferably be of actual size and should
indicate the colours to be used. If there are multiple pack sizes or strengths, one
representative label or copy will be sufficient, provided that the only difference between the
labels is the pack size or strength, unless this would contravene the strength differentiation
requirement.
LPDL: Label - changes to the colour, design or layout of labels with no

change to content and retaining differentiation of strengths
Conditions
V3.1 January 2020
Data requirements
You must submit:
LPSP: Label - change to the layout or design of a physician sample pack

Conditions
• May include changes in content if this is to ensure compliance with Australian
pharmaceutical industry codes of conduct.
Data requirements
You must submit:
LPWS: Label - addition or deletion of, or change to, the website address of
an Australian owned and managed company
Conditions
Data requirements
You must submit:
• For addition of, or changes to, a company website address, an assurance that the sponsor has
full control over the content of the site.
V3.1 January 2020

LCDE: Label changes - any changes requiring evaluation

Any proposed changes to the label can be submitted as part of this Category 3 variation type.
Conditions
Data requirements
You must submit:
• Description of the proposed changes.
• Copies of both the currently approved labels and the changed labels. The proposed labels
should meet the format requirements of Module 1.3.3 of the CTD format to the stated scale.

(separate and distinct good) – Retaining AUST R number
DTTR: Trade name replacement – Retaining AUST R number

Replacement of trade name.
Requires update to ARTG data: Good Name.

Under s. 16(1) of the Therapeutic Goods Act 1989, a change in trade name
means that the renamed product is a separate and distinct good from the
existing product, and this requires a new ARTG entry. However, the provisions
of the Therapeutic Goods (Groups) Order No. 1 of 2001 allow the AUST R
number of the existing product to be retained for the new product, if the new
product replaces the existing product.
Conditions
• Only the trade name — not the nonproprietary name of the drug substance — can be
changed under this application type.
• The details of the product, including indications and sponsor, should remain the same.
Data requirements
You must submit:
• Proposed replacement trade name.
• Revised labels.
V3.1 January 2020
Regulations 1990).
• A clean copy of the PI must be provided. Where the proposed change would involve approval
of a new PI, a marked-up copy should also be provided, as outlined in the Variations to
prescription medicines – excluding variations requiring evaluation of clinical or
• If submitting the application on behalf of another sponsor and/or using your name, contact
details or livery on the labels, a letter of authorisation from the sponsor authorising you to
submit the application and permission for your contact details and livery to be used on the
labels.
Associated changes
trade name. Associated variation types that you can include with DTTR are:
• ZFRC: ARTG data – Container and shelf life changes associated with DFCF/PFCF or DTTR –
• ZFRM: ARTG data – Manufacturer changes associated with DFCF/PFCF or DTTR – Retaining
AUST R number
• ZFRO: Other consequential changes to the dossier associated with DFCF/PFCF or DTTR –
• ZFRP: ARTG data – Pack size and poison schedule changes associated with DFCF/PFCF or
• ZFRS: ARTG data – Sterility changes associated with DFCF/PFCF or DTTR – Retaining AUST
R number
• ZFRV: ARTG data - Visual identification changes associated with a result of DFCF/PFCF or
DTTR – Retaining AUST R number.
1.12 Other changes

1989. Alternatively, the Secretary can make corrections to ARTG entries under s. 9D(1), at their
initiative. Refer to the Variations to prescription medicines – excluding variations requiring
CADF: Correct an ARTG entry - dosage form

Requires update to ARTG data: Dosage Form.
Conditions
V3.1 January 2020
Data requirements
You must submit:
request.
CAGN: Correct an ARTG entry - good name

Conditions
Data requirements
You must submit:
request.
CAIC: Correct an ARTG entry - indications

Requires update to ARTG data: Indications.
Conditions
Data requirements
You must submit:
request.
CANC: Correct an ARTG entry - ATC Nordic codes

Requires update to ARTG data: ATC Nordic Codes.
Conditions
V3.1 January 2020
Data requirements
You must submit:
request.
CAQI: Correct an ARTG entry - quality-related information, includes labels

Conditions
Data requirements
You must submit:
request.
CARA: Correct an ARTG entry - route of administration

Requires update to ARTG data: Route of Administration.
Conditions
Data requirements
You must submit:
request.
CASI: Correct an ARTG entry - sterility information

Requires update to ARTG data: Sterility Information.
Conditions
Data requirements
You must submit:
request.
V3.1 January 2020
CAVI: Correct an ARTG entry - visual identification / product description

Requires update to ARTG data: Visual Identification.
Conditions
Data requirements
You must submit:
request.

OCPS: medicines and poisons - change in scheduling

Changes to medicines and poisons scheduling

Any changes to the Standard for the Uniform Scheduling of Medicines and
Poisons signal heading and cautionary statements are matters for the states
and territories, and therefore should be handled through state and territory
authorities.
If a medicine has been rescheduled from Schedule 4 or 8 to Schedule 2 or 3,
any necessary changes to the product should be handled according to the
Australian Regulatory Guidelines for Over-the-Counter Medicines, where
appropriate.
Conditions
• The change in scheduling is from a Schedule 2 or 3 medicine to a Schedule 4 or 8, or from a
Schedule 4 to a Schedule 8 medicine, or
• The medicine has been rescheduled from Schedule 4 or 8 to Schedule 2 or 3, but continues to
be regulated as a prescription medicine (see Part 1 of Schedule 10 of the Therapeutic Goods
Regulations 1990).
Data requirements
You must submit:
• Relevant evidence of the change, such as a copy of the final Advisory Committee on
Medicines Scheduling (ACMS) decision.
V3.1 January 2020
• A copy of the revised label.

• A clean and marked-up copy of the proposed amended PI, as outlined in the Variations to
prescription medicines – excluding variations requiring evaluation of clinical or
SARO: Other self-assessable changes - an application using this type must

include written advice from the TGA
Conditions
Data requirements
You must submit:
• Written advice from the TGA advising the use of this variation type.
• Details of the proposed changes and appropriate supporting data relevant to the change(s)
concerned.
• Details of the variation should be described in both the cover letter and in the comments
field of the e-form.

OCQD: Other quality changes that do not create a separate and distinct good
This can include quality-related changes that do not create a separate and distinct good that are
not covered by a variation type described in this document.
Conditions
• The variation does not create a separate and distinct good.
Data requirements
You must submit:
• Details of the proposed changes and appropriate supporting data relevant to the change(s)
concerned.
• Details of the variation should be described in both the cover letter and in the comments
field of the Variation e-form.
V3.1 January 2020
1.13 Associated changes

When requesting a change that will result in a new and distinct good, there may be situations
where your variation requires multiple PAR fields to be updated. For example, varying the
formulation of your product may result in the need to update the visual identification
information.
To prevent the creation of unnecessary separate submissions you can use the ‘Associated
changes.’ These variation types are listed here. They can only be selected in combination with
the variation type specified in the conditions. Variations that can be requested as ‘Associated
changes’ must be described in other parts of this guidance and must not require evaluation of
clinical or bioequivalence data. The conditions stated in other parts of the guidance for related
variation types would also apply to the associated variation types.
See also:
• Associated changes in Variations to prescription medicines – excluding variations requiring
• Associated changes to product information (PI).
1.13.1 Changes associated with DFCI and DFFC
ZFSM: ARTG data - Manufacturer changes associated with DFCI or DFFC

Change to data within ARTG Manufacturers associated with a change to an inked imprint or to a
colouring agent, flavour or fragrance.
Requires update to ARTG data: Manufacturers.
Conditions
• This variation type can only be selected in combination with either:
- DFCI: Formulation - addition or deletion of, or variation to, an inked imprint
- DFFC: Formulation - change relating to colouring agent, flavour or fragrance.

• This change that is associated with DFCI or DFFC is not a category 3 change requiring the
submission of data for evaluation. If this associated change is a category 3 change, select a
category 3 formulation variation type first, then an associated change. See DFCF:
Formulation – changes (CE) – Retaining AUST R number and DFNA: Formulation changes
(CE) – New AUST R number.
• This change does not require evaluation of clinical or bioequivalence data and is described in
other parts of this guidance. The conditions outlined in the relevant variation type are
satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Manufacturers variation types.
V3.1 January 2020
ZFSV: ARTG data - Visual identification changes associated with DFCI or

DFFC
Change to data within ARTG Visual Identification as a consequence of a change to an inked
imprint or to a colouring agent, flavour or fragrance.
Conditions
• This variation type can only be selected in combination with either:
- DFCI: Formulation - addition or deletion of, or variation to, an inked imprint
- DFFC: Formulation - change relating to colouring agent, flavour or fragrance.

• This change that is associated with DFCI or DFFC is not a category 3 change requiring the
submission of data for evaluation. If this associated change is a category 3 change, select a
category 3 formulation variation type first, then an associated change. See DFCF:
Formulation – changes (CE) – Retaining AUST R number and DFNA: Formulation changes
(CE) – New AUST R number.
satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Visual Identification variation types. For example
the new product description.
1.13.2 Changes associated with DFCF and DTTR
ZFRC: ARTG data – Container and shelf life changes associated with
DFCF/PFCF or DTTR – Retaining AUST R number
Change to data within ARTG Container & Shelf Life associated with a s.23 Category 3 change to
formulation or trade name.
Conditions
• This variation type can only be selected in combination with:
- DFCF: Formulation – changes (CE) – Retaining AUST R number
- DTTR: Trade name replacement – Retaining AUST R number.

• The change is only to container material or shelf life.
• This change that is associated with DFCF or DTTR is not a change that requires a new AUST
R number. If this associated change requires a new AUST R number use DFNA: Formulation
changes (CE) – New AUST R number then changes associated with DFNA and PCCT.
satisfied.
V3.1 January 2020
Data requirements
You must submit:
• Appropriate stability data as described in relevant Container & Shelf Life variation types.
ZFRM: ARTG data – Manufacturer changes associated with DFCF/PFCF or

Change to data within ARTG Manufacturers associated with a s.23 Category 3 change to
formulation or trade name.
Conditions

satisfied.
Data requirements
You must submit:
ZFRN: ARTG data – Good name changes associated with DFCF/PFCF –

Change to data within ARTG Good Name associated with a s.23 Category 3 change to
formulation.

Under s. 16(1) of the Therapeutic Goods Act 1989, a change in trade name
means that the renamed product is a separate and distinct good from the
existing product, and this requires a new ARTG entry. However, the provisions
of the Therapeutic Goods (Groups) Order No. 1 of 2001 allow the AUST R
number of the existing product to be retained for the new product, if the new
product replaces the existing product.
Conditions
- DFCF: Formulation – changes (CE) – Retaining AUST R number.

• This change that is associated with DFCF is not a change that requires a new AUST R
number. If this associated change requires a new AUST R number use DFNA: Formulation
changes (CE) – New AUST R number then changes associated with DFNA and PCCT.
V3.1 January 2020
satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Good Name variation types.
ZFRO: Other consequential changes to the dossier associated with

Change to data within the dossier associated with a s.23 Category 3 change to formulation or
trade name.
Conditions

satisfied.
• This change does not require an update to ARTG data.
Data requirements
You must submit:
• Appropriate data as described in relevant variation types.
ZFRP: ARTG data – Pack size and poison schedule changes associated with
Change to data within ARTG Pack Size & Poison Schedule associated with a s.23 Category 3
change to formulation or trade name.
Conditions

satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Pack Size & Poison Schedule variation types.
V3.1 January 2020
ZFRS: ARTG data – Sterility changes associated with DFCF/PFCF or DTTR –

Change to data within ARTG Sterility associated with a s.23 Category 3 change to formulation or
trade name.
Requires update to ARTG data: Sterility.
Conditions
– DFCF: Formulation – changes (CE) – Retaining AUST R number
– DTTR: Trade name replacement – Retaining AUST R number.
satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Sterility variation types.
ZFRV: ARTG data - Visual identification changes associated with DFCF/PFCF

or DTTR – Retaining AUST R number
Change to data within ARTG Visual Identification as a consequence of a s.23 Category 3 change
to formulation or trade name.
Conditions
– DFCF: Formulation – changes (CE) – Retaining AUST R number
– DTTR: Trade name replacement – Retaining AUST R number.
satisfied.
Data requirements
You must submit:
V3.1 January 2020
1.13.3 Changes associated with DFNA and PCCT
ZFNC: ARTG data – Container and shelf life changes associated with
DFNA/PFNA – For the new AUST R number
Change to data within ARTG Container & Shelf Life associated with a s.23 Category 3 change to
formulation.
Conditions
- DFNA: Formulation changes (CE) – New AUST R number.

satisfied.
Data requirements
You must submit:
• Appropriate stability data as described in relevant Container & Shelf Life variation types.
ZFNM: ARTG data – Manufacturer changes associated with DFNA/PFNA or

Change to data within ARTG Manufacturers associated with a s.23 Category 3 change to
formulation or container type.
Conditions
- DFNA: Formulation changes (CE) – New AUST R number
- PCCT: Packaging - changes to container type – New AUST R number.

satisfied.
Data requirements
You must submit:
V3.1 January 2020
ZFNN: ARTG data – Good name changes associated with DFNA/PFNA or

Change to data within ARTG Good Name associated with a s.23 Category 3 change to formulation
or container type.
Conditions

satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Good Name variation types.
ZFNO: Other consequential changes to the dossier associated with

DFNA/PFNA or PCCT – For the new AUST R number
Change to data within the dossier associated with a s.23 Category 3 change to formulation or
container type.
Conditions

satisfied.
• This change does not require an update to ARTG data.
Data requirements
You must submit:
• Appropriate data as described in relevant variation types.
ZFNP: ARTG data – Pack size and poison schedule changes associated with
Change to data within ARTG Pack Size & Poison Schedule associated with a s.23 Category 3
change to formulation or container type.
V3.1 January 2020
Conditions

satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Pack Size & Poison Schedule variation types.
ZFNS: ARTG data – Sterility changes associated with DFNA/PFNA or PCCT –

Change to data within ARTG Sterility associated with a s.23 Category 3 change to formulation or
container type.
Requires update to ARTG data: Sterility.
Conditions

satisfied.
Data requirements
You must submit:
• Appropriate data as described in relevant Sterility variation types.
ZFNV: ARTG data – Visual identification changes associated with

Change to data within ARTG Visual Identification associated with a s.23 Category 3 change to
formulation or container type.
Conditions
V3.1 January 2020
satisfied.
Data requirements
You must submit:
V3.1 January 2020
2. Product information (PI) changes

The Variation e-form has four category groups which are described in Variations to prescription
medicines – excluding variations requiring evaluation of clinical or bioequivalence data; Process
guidance:
• Correct an ARTG entry
• Notification
• Quality information
• Product information (PI).
Part 2 of this guidance describes the changes that can be made within the product information
category group. This includes changes to the PI that are minor editorial changes, safety related
requests and extension of indications to align with a reference product.
For changes to the quality aspects of the PI, corrections to the PI and self-assessable requests
(SARs) related to PI information see Part 1: Corrections, notifications and quality information
changes and Product information (PI) changes: Quality aspects, corrections and self-assessable
requests (SARs).
2.1 Product information (PI) changes: Minor editorial

changes and safety-related requests (SRRs)
All ARTG entries included in the PI document (and therefore will be affected by
a change to the PI) should be selected in the Variation e-form when requesting
the variation. If an ARTG entry included in the PI document is not selected, a
subsequent variation request will be required to be submitted.
For information about selection of ARTG entries for variations that are
consequence of a quality change see consequential changes to the product
information in Variations to prescription medicines – excluding variations
requiring evaluation of clinical or bioequivalence data; Process guidance.
2.1.1 Minor editorial changes to the product information under s. 9D(3)

This variation falls under s. 9D(3) of the Therapeutic Goods Act 1989.
Minor editorial changes to the product information under s. 9D(3)

In some cases, the only proposed variation to an ARTG entry is a change to the PI.
Most of these changes do not meet the criteria of a safety-related request or self-
assessable request. These are instead processed as minor editorial changes.
V3.1 January 2020
PIME: PI - make minor editorial changes

Conditions
• The only changes being requested are those identified under this request.
Data requirements
You must submit:
• Details of the safety-related request.
• A justification for the proposed variation.
2.1.2 Safety-related requests (SRRs)

Requests are assessed on a case-by-case basis and the proposed variation must meet the criteria
of being safety-related. Sponsors should be able to justify how a request meets these criteria.
Safety-related variations always require changes to the product information (PI).
PIID: PI - remove an indication with data

Conditions
Data requirements
You must submit:
• Revised labels, if applicable.
PIIN: PI - remove an indication - no data

Conditions
Data requirements
You must submit:
• Revised labels, if applicable.
V3.1 January 2020
PIOD: PI – make safety related changes with data

Conditions
Data requirements
You must submit:
• Revised labels if applicable.
PION: PI - make safety related changes no data

Conditions
Data requirements
You must submit:
• Revised labels if applicable.
2.2 Extension of indications

For proposed extension of indications that require evaluation of clinical, pre-clinical or bio-
equivalence data, submit an application using the Prescription Medicines Registration Process.
2.2.1 Extension of indications to align with a reference product

These variations fall under s. 23 of the Therapeutic Goods Act1989. Regulation 16G of the
Therapeutic Goods Regulations 1990 must apply, that is, evaluation of clinical, pre-clinical or bio-
equivalence data is not required.
PIES: Extension of specific indications to align with a reference product

Proposed extension of indications to align with a reference product where evaluation of clinical,
pre-clinical or bio-equivalence data is not required can be submitted as part of this variation
type.
V3.1 January 2020

Under s. 16(1) of the Therapeutic Goods Act 1989, a change in indication means
that the varied product is a separate and distinct good from the existing
product, and this requires a new ARTG entry. However, the provisions of the
Therapeutic Goods (Groups) Order No. 1 of 2001 allow the AUST R number of
the existing product to be retained for the new product, if the new product
replaces the existing product.
Conditions
• This request is not combined with any other application in the one submission.
• The proposed indication is identical to the approved indication for the reference medicine.
• Bioequivalence to the reference product has previously been demonstrated and evaluated by
the TGA.
• There is equivalence for all relevant pharmacokinetic parameters.
− For different indications, there can be different pharmacokinetic parameters that are
relevant to safety and/or efficacy. The pharmacokinetic parameters that we evaluated
previously in relation to the reference medicine should still be appropriate and suitable
for the new indication. This is because your generic medicine must have the same
safety and efficacy properties as the reference medicine (Schedule 9 of the Therapeutic
Goods Regulations 1990).
− Examples of pharmacokinetic parameters that are only relevant for some indications:
▪ the median Tmax is important for indications that require rapid release from an
oral dosage form
▪ partial AUC values are sometimes important.
− For more information see the TGA guidance on biopharmaceutic studies

• The currently registered strengths are appropriate for the recommended doses for the new
indication.
− Consider the appropriateness of the currently registered strengths of your medicine as

they relate to the recommended doses for the new indication.
− Be careful when using the product information (PI) for the reference medicine to
support your extension of indications application. If the range of strengths available for
the reference medicine differs from the range of strengths available for your medicine,
then you need to consider how strengths relate to dose. For example, if an indication
requires a maximum dose of 1 mg and the lowest strength of your medicine is a 5 mg
tablet, then the strength of your medicine is inappropriate for the recommended dose
for the new indication.
− If the range of strengths covered by the reference medicine is not the same as for your
medicines, consider adding information to the Dosage and administration section of the
PI, such as the advice “Use alternative brand for doses that cannot be achieved with
[your brand]. Do not name an alternative brand because this is advertising.
• There are no other safety or efficacy issues.
V3.1 January 2020
- Consider any other issues related to the need for data to demonstrate that your
medicine and the reference medicine have the same safety and efficacy properties.
- For example, for non-absorbable polymers, demonstration of safety and/or efficacy for
one indication cannot necessarily be used to support safety and/or efficacy for another
indication.
• The intention of this proposed change is to group the new medicine with an already
registered prescription medicine.
• Regulation 16G of the Therapeutic Goods Regulations 1990 applies and this application does
not need to be supported by clinical, pre-clinical or bio-equivalence data.
Data requirements
You must submit:
• The trade name, active ingredient(s), ARTG ID and dosage form of the reference medicine
and a copy of the reference medicine’s product information (PI).
• Justification of why supporting data is not required. Consider all of the following described
in the conditions above:
- identical indication to the reference medicine
- bioequivalence to the reference medicines
- equivalence of all relevant pharmacokinetic parameters
- strength is appropriate for the recommended dose
- other safety or efficacy issues.

• Justification of decision regarding pack sizes:
- If you are not applying for additional pack sizes, justify this in relation to the adequacy
of current pack sizes to cover the recommended dosage regimen(s) for the new
indications.
- If you are applying for additional pack sizes, justify this in relation to:
the inadequacy of current pack sizes to cover the recommended dose regimens for
the new indications
ability to add pack size without requiring new stability data.
• A clean and marked-up copy of the draft revised PI based on the most recent version of the
PI for the existing medicine that has been approved by the TGA. Do not make minor editorial
changes to the PI that are not necessary to meet current requirements. The only changes that
can be made to the PI are:
- because of the new indications
- in order to make the format of the medicine information meet current requirements
- because of the strengths available.

• A clean and marked up copy of the draft revised CMI.
• Comprehensive table of contents in the CTD.
V3.1 January 2020
• Biopharmaceutic studies summary. In module 1.11 provide:
- a tabulated summary of the pharmacokinetic parameters of the biopharmaceutical

studies previously submitted and evaluated by the TGA
- an explanation of why these data are applicable and satisfactory for the new
indications.
• Patent certification or notification
Do not submit:
• Labels. The only change you may make to labels is the pack size descriptor if additional pack
sizes are required as a consequence of the extension of indications. See PIEP: Additional
pack sizes resulting from extension of indications to align with a reference product.
Associated changes
If you are applying for additional pack sizes as a result of the extension of indications use
associated variation type:
• PIEP: Additional pack sizes resulting from extension of indications to align with a reference
product
2.3 Associated changes to product information (PI)

For information about associated changes see:
• Associated changes in this guidance
• Associated changes in the Variations to prescription medicines – excluding variations
requiring evaluation of clinical or bioequivalence data; Process guidance.
2.3.1 Changes associated with PIES
PIEP: Additional pack sizes resulting from extension of indications to align

with a reference product
Additional pack sizes as a result of PIES: Extension of specific indications to align with a
reference product:
Conditions
• Additional pack size(s) are:
- already registered to the reference medicine
- necessary for consumer compliance with one of the new indications
- not associated with any changes to container material, size or shape, or any other
change that may require the provision of stability data.
• The only change to the label is the pack size descriptor and the labels comply with the
current labelling order.
V3.1 January 2020
Data requirements
You must submit:
• Justification of why you are applying for additional pack sizes.
Do not submit:
• Labels. The only change you may make to labels is the pack size descriptor.
V3.1 January 2020
Version history
Version Description of change Author Effective date
V1.0 Original publication Scientific Operations June 2017

Management Section/SEB
V2.0 Inclusion of notifiable TGA December 2017

variations to registered
medicines.
Minor amendments to phrasing
and layout.
V3.0 Amended title Scientific Evaluation July 2019

Branch (SEB)
Inclusion of Extension of
indications to align with a
reference product
Additional information on:
• variation types that are
associated with a
mandatory PAR field update
• changes that do not need to
be notified to the TGA
• new variation types
(including Associated
changes and SARO).
Minor clarifications and
corrections to phrasing and
layout.
V3.1 Minor clarifications and Scientific Evaluation January 2020

corrections to: Branch (SEB)
• API changes that do not
require reporting to the
TGA
• CCSC: Container/closure
system - changes to
container components
and/or dimensions.
V3.1 January 2020
PO Box 100 Woden ACT 2606 Australia
Email: info@tga.gov.au Phone: 1800 020 653 Fax: 02 6203 1605
https://www.tga.gov.au
Reference/Publication # D19-5867799

Variations TGA

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Variations to prescription medicines

– excluding variations requiring

Version 3.1, January 2020

1.7.1 Changes that do not require reporting to the TGA -------------------- 71

2. Product information (PI) changes __________ 120

2.1 Product information (PI) changes: Minor editorial changes and

- changes that can be implemented without informing the TGA

Data supporting variation requests

Index of variation types – chemical entities

Part 1: Corrections, notifications and quality information changes

Active Pharmaceutical Ingredient (API) changes

API and intermediate manufacture - alternative Does not

Ingredients - change to contact details of the Does not

ACCS API container - changes to container/closure Notification

ACEP API Certificate of Suitability (CEP) - a revision Notification

AMBS API and intermediate manufacture - change to Notification

AMCS API site of manufacture - cessation Notification Manufacturers

AMIT API and intermediate manufacture - addition, Notification

AMMC API and intermediate manufacture - minor Notification

AMMF API starting material/intermediate site of Notification

AMTA API site of manufacture - transfer of/addition Notification Manufacturers

Variation Description Variation Requires update

ASAM API/starting material/intermediate Notification

ASDR API re-test period and storage conditions - Notification

ASID API/starting material/intermediate Notification

ASNL API/starting material/intermediate Notification

ASNT API/starting material/intermediate Notification

ASPC API specifications - changes to physicochemical Notification

ASPT API specifications - amendments resulting Notification

ADSL Shelf life - Changes to the retest period of the Category 3

AMAS API manufacture - changes to the site(s) of Category 3 Manufacturers

AMCM API manufacture - changes to the synthetic Category 3

ASCS API specifications - changes to the Category 3

Drug product manufacture changes - method, batch size or equipment

CAMC Correct an ARTG entry - manufacture Correction Manufacturers

DMBS Drug product manufacture - changes to batch Notification

Variation Description Variation Requires update

DMEL Drug product manufacture - changes to Notification

DMEO Drug product manufacture - changes to Notification

DMES Drug product manufacture - changes to Notification

DMIT Drug product manufacture - changes to in- Notification

DMRO Drug product manufacture - reduction or Notification

DMSE Drug product manufacture - changes to Notification

DMDS Drug product manufacture - changes to SAR Visual

DMCM Drug product manufacture – changes to the Category 3

Drug product - site of manufacture changes

Report Manufacturing - change to manufacturer’s Requires

DMDM Drug product site of manufacture - cessation of Notification Manufacturers

Variation Description Variation Requires update

DMPL Drug product site of manufacture - change to Notification Manufacturers

DMSL Drug product site of manufacture - change to Notification Manufacturers

DMSO Drug product site of manufacture - change to Notification Manufacturers

DMSS Drug product site of manufacture - change to Notification Manufacturers

DMTR Drug product site of manufacture - change to Notification Manufacturers

DMCS Drug product site of manufacture - changes to Category 3 Manufacturers

Drug product formulation changes

CAAO Correct an ARTG entry - animal origin Correction Formulation

CAFC Correct an ARTG entry - formulation Correction Formulation

DFCI Formulation - addition or deletion of, or SAR - Formulation

DFFC Formulation - change relating to colouring SAR - Formulation