Panelists: impurity controls in intermediates can render primary DMFs inadequate

Jul 30, 2026

Speakers said even when a secondary DMF appears adequate, failure to control impurities in the primary manufacturing steps can make the primary DMF inadequate; reviewers frequently cite impurity profiles as top deficiencies.

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Panelists cautioned that adequate documentation in a secondary DMF does not automatically mean the primary DMF will be considered adequate if the primary applicant's manufacturing process does not demonstrate control of impurities. "Even though secondary DMF adequate, we had to make the primary DMF inadequate because of the not addressing the control of impurities," one panelist said, describing a situation where control measures were addressed only later in synthesis.

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