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Combination Products

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drug device combination products regulatory expertise

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The Best of both Worlds

  • Expertise in drugs, biologics, and devices
  • Experience in identifying and leveraging incentives and opportunities for accelerated development
  • At the forefront of breakthrough technologies and in direct contact with regulatory bodies, shaping the evolving regulatory framework

About Us

Comprehensive Product Expertise

We have hands-on experience covering a broad range of products such as drug delivery systems, photodynamic therapy products, sonodynamic therapy products, combined ATMPs, coated implantable devices, and scaffolds for grafts/implants for a wide range of applications.​

FAQs

What is a combination product?

Combination products are therapeutic and diagnostic products that combine drugs, devices, and/or biologics.

 

These can include products like drug-eluting stents, pre-filled syringes, and transdermal patches. Products may be combined via integral combination, co-packaging, or cross-labeling.

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How are combination products approved?

The approval process depends on the primary mode of action (PMoA) and type of combination.

 

If it is drug-led, the product is approved as a drug (MAA, NDA/BLA) and the device component will be evaluated by a notified body (CE-marking/NBOp) / FDA Center for Devices and Radiological Health (CDRH). Device-led products follow the device approval route (CE-marking, 510(k)/PMA), with the opinion on the ancillary drug component coming from the NCA/EMA and FDA CDER/CBER.

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What authorizations are required to conduct a clinical trial with a combination product?

The US and Europe show two different paradigms.

 

In the US, the FDA OCP clearly delineates the status of combination products (in the meaning of 21 CFR 3.2(e)) and clinical trials with a combination product are regulated either under an investigational new drug (IND) or an investigational device exemption (IDE) application, depending on the “primary mode of action (PMOA)” of the combination.

In Europe, with the UK currently rather aligned on the EU paradigm, the regulatory pathway primarily depends on whether the combination is deemed “integral” or not. If integral, the trial will either be regulated under the EU CTR (Regulation 536/2014) or the EU MDR (Regulation 2017/745), depending on the integral combination product’s primary mode of action. If not integral, then the trial will be regulated under both the EU CTR and the EU MDR; this requires two independent sets of authorizations for the trial.

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Related Glossary

Combination product
Breakthrough Device Designation
In Vitro Diagnostic Medical Device (IVDMD)
Medical Device Software
SaMD / SiMD
Medical Device (MDR definition)

Questions? Get the answers from our expert team ​

No two product development paths are the same. Talk to our experts about your development challenges and we will provide you actionable recommendations.​