2026-15612NoticeWallet

FDA Guides Industry on Skin Irritation Tests for Drug Patches and Creams

Published Date: 8/3/2026

Notice

Summary

The Food and Drug Administration (FDA or Agency) is announcing the availability of a revised draft guidance for industry titled "Assessing the Irritation and Sensitization Potential of Transdermal and Topical Delivery Systems for ANDAs." This revised draft guidance provides recommendations for the design and conduct of studies to evaluate the in vivo skin irritation (and sensitization, if applicable) potential of a proposed transdermal or topical delivery system (collectively referred to as TDS). The recommendations in this revised draft guidance relate to studies submitted in support of an abbreviated new drug application (ANDA). The revised draft guidance is intended to clarify FDA's recommendations and expectations related to in vivo skin irritation and in vivo combined skin irritation and sensitization studies. This draft guidance replaces the draft guidance "Assessing the Irritation and Sensitization Potential of Transdermal and Topical Delivery Systems for ANDAs" (April 2023).

Analyzed Economic Effects

2 provisions identified: 2 benefits, 0 costs, 0 mixed.

FDA draft guidance for TDS studies

FDA published a revised draft guidance titled "Assessing the Irritation and Sensitization Potential of Transdermal and Topical Delivery Systems for ANDAs" that provides recommendations for the design and conduct of in vivo skin irritation and combined irritation/sensitization studies for transdermal or topical delivery systems submitted with an ANDA. This revised draft replaces the April 2023 draft and the Agency is accepting comments on it through October 2, 2026.

Clarifies when sensitization tests unnecessary

The revised draft guidance clarifies circumstances when an in vivo sensitization study for a transdermal or topical delivery system may not be needed for an ANDA submission. FDA requests comments on this point (and on scoring scales and comparative assessment methods) and is accepting comments through October 2, 2026.

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Key Dates

Published Date
Comments Due
8/3/2026
10/2/2026

Department and Agencies

Department
Independent Agency
Agency
Health and Human Services Department
Food and Drug Administration
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