Submitting a Marketing Authorization Application (MAA) to multiple Regulatory authorities can be a complex and time-consuming process, especially when it involves submitting the same Active Substance Master File (ASMF) to each authority. This is because different Regulatory authorities may have different requirements for ASMF submissions.

Coordinating dual ASMF submissions can help expedite the Regulatory approval process by allowing the Regulatory authorities to review the ASMF in parallel, rather than sequentially. This can reduce the time to market for a new medicinal product by several months. This blog will discuss the benefits and challenges of coordinating dual ASMF submissions, as well as provide tips for successful submissions.

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What are dual ASMF submissions?

Dual ASMF submissions involve submitting the same ASMF to multiple Regulatory authorities simultaneously. This can be done in cases where a medicinal product is being marketed in multiple countries.

Benefits of dual ASMF submissions

There are several benefits to coordinating dual ASMF submissions, including:

  • Reduced time to market: By submitting the ASMF to multiple Regulatory authorities simultaneously, the review process can begin earlier, leading to a shorter market time for the medicinal product.
  • Improved efficiency: Coordinating dual ASMF submissions can improve the efficiency of the Regulatory approval process by reducing the need for duplicate submissions and reviews.
  • Reduced costs: Coordinating dual ASMF submissions can reduce the costs associated with the Regulatory approval process by eliminating the need to prepare and submit multiple ASMFs.

Challenges of dual ASMF submissions

There are also some challenges to coordinating dual ASMF submissions, including:

  • Different Regulatory requirements: Regulatory authorities may have different requirements for ASMF submissions. This can make it difficult to prepare a single ASMF that meets all of the requirements.
  • Communication challenges: Coordinating dual ASMF submissions can be challenging due to the different time zones and languages involved.
  • Resource requirements: Coordinating dual ASMF submissions can require additional resources from the applicant.

How to coordinate dual ASMF submissions

To coordinate dual ASMF submissions, the applicant should:

  1. Identify the relevant Regulatory authorities.
  2. Review the Regulatory requirements for ASMF submissions in each country.
  3. Develop a submission plan that outlines the steps involved in submitting the ASMF to each Regulatory authority. The plan should include timelines and communication protocols.
  4. Communicate regularly with the Regulatory authorities throughout the submission process.
  5. Be prepared to promptly respond to Regulatory authorities' requests.

Tips for successful dual ASMF submissions

  • Submit a high-quality ASMF: The ASMF should be complete, accurate, and up-to-date. It should also be well-organized and easy to read.
  • Be proactive: Be proactive in identifying and addressing any potential issues with the ASMF. This will help to avoid delays in the Regulatory approval process.
  • Work with a qualified consultant: If needed, work with a qualified consultant who can help you coordinate dual ASMF submissions.


Navigating the Regulatory landscape for pharmaceutical products is undeniably intricate, but the strategic approach of coordinating dual Active Substance Master File (ASMF) submissions can significantly expedite the journey from development to market. Partnering with experienced Regulatory consultants like Freyr can enhance the process further by adhering to meticulous planning, understanding the varied requirements of Regulatory authorities, and fostering proactive communication, so pharmaceutical companies can surmount the challenges associated with dual submissions.


Sonal Gadekar


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