Beijing — China’s National Medical Products Administration (NMPA) expanded its generic drug quality and efficacy consistency evaluation program beyond oral solid dosage forms and injections, adding eye drops, transdermal patches, and sprays to the reform framework as Beijing deepens its push to upgrade the domestic pharmaceutical sector.
Policy Snapshot
| Attribute | Detail |
|---|---|
| Issuer | National Medical Products Administration (NMPA) |
| Announcement | 2026 No. 86 |
| Legal basis | State Council General Office Opinion on Deepening Drug and Medical Device Regulatory Reform (Guo Ban Fa [2024] No. 53) |
| Scope | Chemical generic drugs in non-oral, non-injectable dosage forms |
| Initial phase | Eye drops — effective immediately upon announcement |
| Second phase | Patches and sprays — effective July 1, 2027 |
| Reference standard | NMPA Chemical Generic Drug Reference Preparations Catalog |
Key Provisions
- Expanded coverage — The consistency evaluation regime, previously focused on oral solids and injections, now extends to eye drops, transdermal patches, and sprays. Marketing authorization holders must select reference preparations from the NMPA-published catalog and submit consistency evaluation applications.
- Technical alignment — Supplemental applications for consistency evaluation must meet the same technical standards as new chemical generic drug applications. Holders should conduct studies according to NMPA technical guidelines and Chinese Pharmacopoeia standards, with the option to reference foreign regulatory requirements. Application summaries follow the 2020 No. 2 CDE notice on injection consistency evaluations; other sections follow the current M4 CTD format.
- Clinical trial gate — Products requiring clinical studies must first obtain clinical trial permits from the CDE before initiating studies.
- Review process — The CDE conducts technical reviews, initiates verification inspections and testing, and issues comprehensive evaluation opinions. Approved products receive supplemental application approval certificates.
- Transitional rules — Unaddressed matters continue to follow the 2017 No. 100 and 2018 No. 102 announcements on consistency evaluation.
Market Impact Analysis
The phased rollout gives eye drop manufacturers immediate compliance obligations while granting patch and spray developers a roughly 10-month runway to prepare dossiers. The extension represents the final frontier of China’s decade-long generic drug quality overhaul, targeting dosage forms that have historically escaped bioequivalence scrutiny due to complex absorption profiles and limited reference standards.
For ophthalmic generics makers, the immediate launch means existing products face potential delisting if they fail to demonstrate therapeutic equivalence to reference preparations within forthcoming deadlines. The sector is fragmented among dozens of domestic producers of glaucoma, anti-inflammatory, and artificial tear formulations, suggesting consolidation pressure as smaller firms lack the R&D budgets to reformulate or conduct clinical endpoint studies.
Patch and spray manufacturers benefit from the delayed July 2027 start date but must begin reference preparation selection and formulation development now to meet what will likely be stringent pharmacokinetic or clinical efficacy requirements. The explicit permission to reference foreign regulatory standards offers a compliance shortcut for multinational subsidiaries with existing EU or U.S. approval packages, though all submissions must ultimately conform to the M4 CTD structure.
Forward-Looking Statement
Industry analysts expect the CDE to publish dedicated technical guidelines for eye drop consistency evaluation by late 2026 or early 2027, clarifying whether in vitro dissolution or clinical efficacy trials will serve as the primary equivalence benchmark. The patch and spray delay to July 2027 suggests regulators recognize the technical complexity of transdermal and pulmonary delivery systems and may use the interim period to develop specialized bioequivalence protocols. Pharmaceutical companies with portfolios spanning these dosage forms should prioritize reference preparation selection and pre-formulation studies immediately, as the supplemental application queue is likely to swell once all three categories are active. The reform aligns with Beijing’s broader industrial policy to elevate domestic generics toward global quality parity, potentially paving the way for increased export competitiveness in regulated markets.-China Health Reform Pulse
Policy Source: https://www.nmpa.gov.cn/xxgk/ggtg/ypggtg/ypqtggtg/20260902093151132.html