FAQ
Q. I need a UNIII and cannot find the UNII for my substance in GSRS.
A. Include, if available, otherwise a UNII will be generated by the Agency after submission.
Q. Should reagents and solvents be included in the SD File?
A. No.
Q. Are reagents and solvents also starting materials?
A. No. According to FDA Guidance for Industry Q3A, 2008:
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A starting material is incorporated as a significant structural fragment into the
structure of the drug substance. Significant structural fragment in this context is
intended to distinguish starting materials from reagents, solvents, or other raw
materials. Commonly available chemicals used to create salts, esters, or other
simple derivatives should be considered reagents.
Starting Material: A material used in the synthesis of a new drug substance that is
incorporated as an element into the structure of an intermediate and/or of the new drug
substance.
Solvents are inorganic or organic liquids used as vehicles for the preparation of
solutions or suspensions in the synthesis of a new drug substance.
Reagent: A substance other than a starting material, intermediate, or solvent that is
used in the manufacture of a new drug substance
Guidance for Industry Q3A Impurities in New Drug Substances, 2008.
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/q3ar-
impurities-new-drug-substances (accessed February 1, 2024).
Q. I previously submitted a substance with a UNII. However, I cannot find the UNII in the GSRS
database.
A. It is possible the UNII is not public. Please move forward with submitting the SD File with the
UNII you have on file for your substance.
Q. Multiple UNIIs come up when I search for an ingredient by CAS (e.g., 9004-65-3,
Hypromellose). Which one should I pick?
A. UNIIs were created to meet FDA’s regulatory needs. Therefore, other identifiers or
monographs may not provide enough information to point to the precise UNII. Check the
technical data sheet or safety data sheet for the composition of the ingredient, physical and
chemical properties, or product name. Include the data sheet when contacting
FDA-
Q. Where should I put the SD File in the eCTD?
A. Chemical impurities that undergo a hazard assessment evaluated by (Q)SAR to predict
potential mutagenicity should be placed in Module 3 section 3.2.S.3.2 of the eCTD.
Q. We tabulated all chemical structures, UNII, and CAS in ChemDraw (.cdx file) and converted
to an SD File (.sdf). However, the SD File is missing data. Why?
A. ChemDraw will only create an SD File with structures regardless of any additional text that
may be in the .cdx file. We recommend generating the SD file using the software listed above
.
Updated February 7, 2024
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