Venturing into the Realm of Combination Products

In the intricate space where drugs, devices, and biologics intersect, the resulting products are known as combination products. This segment of the medical device and pharmaceutical industry is thriving. However, the path to developing, manufacturing, and marketing these products is fraught with complex regulatory requirements and operational challenges that demand meticulous attention to detail.

For anyone venturing into the realm of combination products, understanding the landscape and ensuring compliance with regulations is not just advisable—it’s imperative. This article is a brief introductory guide to the dynamics of combination products.

Introduction to Combination Products

A combination product is precisely what its name suggests—a mixture of two or more different products, referred to as constituents. Such as a drug/biologic and a device. These constituents can be combined, packaged together in a single unit, or separately presented for use. The primary purpose of developing combination products is to improve the safety, efficacy, and convenience of patient care by leveraging the unique properties of each constituent.

Some examples of combination products include:

  • Drug-eluting stents
  • Inhalers with medication
  • Prefilled syringes
  • Autoinjectors
  • On Body Injectors

In the United States, the Food and Drug Administration (FDA) categorizes combination products into three types based on their configuration and intended use. These are single-entity, co-packaged, and cross-labeled combination products. A single-entity combination product merges two or more regulated constituents, such as a drug and a device, into a single unit (for instance, a pre-filled syringe where the syringe is the device and the medication within is the drug). On the other hand, co-packaged products consist of two or more separate items that are packaged together (such as a surgical kit containing a wound healing drug and a bandage). Lastly, cross-labeled products are distinct products that are intended to be used together but are marketed separately, with labeling that indicates their combined use (an example could be a topical cream that is intended to be applied using a specially designed applicator where the applicator is sold separately).

These categories serve to streamline the regulatory process, ensuring that each combination product is reviewed and approved based on both its function and intended use, in a way that addresses all the complexities involved. Understanding these distinctions is crucial for manufacturers to navigate the approval process effectively and to meet the FDA’s safety and efficacy standards.

Why are these products significant in the healthcare industry? The answer lies in their potential to offer novel treatment therapies, enhanced patient convenience, and improved health outcomes. Combination products can tackle unmet medical needs and revolutionize how medicine is administered and received. They herald a new era of patient-centric care that merges technological innovations with therapeutic applications.

Regulatory Landscape

Navigating the regulatory framework that governs combination products is akin to traversing a complex maze. The U.S. Food and Drug Administration (FDA) is at the forefront of this endeavor, though international regulatory bodies play a significant role, too.

The FDA’s Office of Combination Products delineates which FDA center will have primary jurisdiction over a specific combination product, determining whether it is a drug, device, or biological product. This classification is crucial, as it shapes the regulatory pathway that the product will follow.

A key task for manufacturers is understanding the blend of cGMP and quality system regulations that apply to their specific combination products. This necessitates a deep understanding of not only FDA regulations but also the harmonization with international requirements for products that cross borders.

Recognizing the complexity of regulating combination products, the FDA has adopted a streamlined approach to facilitate the approval process while ensuring safety and efficacy. This approach hinges on the principle of “primary mode of action” (PMOA), which determines the leading function of the product, whether it is a drug, device, or biological product. The primary mode dictates which FDA center (Center for Drug Evaluation and Research, Center for Devices and Radiological Health, or Center for Biologics Evaluation and Research) will take the lead in the premarket review process. The PMOA not only guides which regulatory pathway a combination product will follow but also informs the manufacturer about specific regulations and guidelines pertinent to the product.

For instance, if a combination product’s primary mode of action is therapeutic (drug-based), then drug regulations primarily govern its pathway. Still, depending on its secondary constituents, it must comply with relevant device or biological regulations. This means adhering to certain Current Good Manufacturing Practices (cGMP) and Quality System (QS) Regulations. Through this synchronized regulatory framework, the FDA aims to ensure that combination products meet rigorous standards of quality, safety, and efficacy without stifling innovation.

Challenges and Opportunities

The duality of challenges and opportunities in the combination product space is apparent. Manufacturers must grapple with the complexities of harmonizing different regulations to ensure compliance. From establishing effective quality management systems to dealing with potentially conflicting manufacturing standards, every phase of the lifecycle poses its own set of hurdles.

Developing combination products requires a multidisciplinary team approach that can function within a regulated yet innovative environment. The interplay of drug and device development cycles brings to the forefront the need for seamless collaboration between traditionally siloed teams.

With every challenge, however, comes an opportunity. Manufacturers who can successfully overcome the regulatory and operational challenges stand to gain a competitive edge. This edge is founded on harnessing the synergy of different technologies and therapeutic functions to meet patient and market needs effectively.

Best Practices

Adhering to best practices is critical in the development and manufacturing of combination products. While there is no one-size-fits-all approach, certain strategies can enhance operational efficacy and regulatory compliance.

Real-world case studies serve as blueprints for success, illustrating how leading companies have navigated the regulatory maze. These exemplars highlight the application of innovative technologies, the adoption of robust and adaptable processes, and the cultivation of a corporate culture that prizes accountability and compliance.

One such best practice is the implementation of comprehensive design control activities, ensuring that all elements, from inputs to risk analyses, are rigorously managed and continually evaluated. The ability to execute these best practices distinguishes industry leaders from their competitors.

One example in the realm of combination products is the development and manufacturing of pre-filled syringes (PFS). These syringes, which often combine a therapeutic (biologic or drug) with a delivery device, exemplify the challenges and complexities inherent in combination product compliance.

Usually these types of PFS combination products will have a PMOA that is a therapeutic, with the syringe serving as the delivery mechanism.

Even within the streamlined approach, depending on the PMOA, manufacturers must comply with certain cGMP Regulations for drugs/biologics and the Quality System (QS) Regulations for devices. These drive rigorous drug testing for stability and compatibility with the syringe material over the product’s intended shelf life. Additionally, robust design control and human factors processes that extend from the initial concept phase through manufacturing must be implemented.

Future Outlook

The future of combination products is dynamic and promising. Emerging technologies such as AI, nanotechnology, and advanced drug delivery systems are opening new frontiers for product development. These innovations, combined with an increasing focus on personalized medicine, suggest that the potential of combination products is far from fully realized.

Trends such as the growth of connected health devices and the digital transformation of healthcare will further shape the landscape. Manufacturers who keep abreast of these developments and remain agile in their approaches stand to capitalize on the evolving demands of the market.


In the arena of combination products, the path to success is rife with complexities that demand a strategic, informed response. By understanding the regulatory framework, harnessing the synergies of different disciplines, and always being forward-looking, manufacturers can position themselves to lead in this exciting market segment.

For those entering the field or seeking to elevate their current operations, the learning never stops. Staying informed, engaging with industry peers, and participating in training and regulatory activities are essential commitments. It is through this continued engagement and growth that the full potential of combination products can be unlocked, benefiting both healthcare providers and the patients they serve.

Are you looking for help with a combination product? At Ventura Solutions, we specialize in guiding you through regulatory challenges, streamlining operations, and leading your product development in this rapidly evolving sector. Whether you’re new to combination products or seeking to improve your processes, our high-end consulting, staffing, and training services are here to accelerate your success. Stay ahead of the curve – subscribe to our newsletter for cutting-edge updates and connect with us to discover how we can support your combination product efforts.