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US FDAUnited StatesALApproval Letter

Approval Letter Other (Nov 13, 2025)

Issued November 13, 2025

Issued

November 13, 2025

Application

Other

Review center

Other

Stage

Final Decision

Letter type

Approval Letter

Response due November 23, 2025Product may be marketed.

Summary

The FDA issued a 'not approvable' letter for New Drug Application (NDA) 21-164 for Gepirone Hydrochloride Extended Release tablets, citing a lack of substantial evidence for its effectiveness in treating major depressive disorder (MDD) and several Chemistry, Manufacturing, and Controls (CMC) deficiencies. The agency found that only 2 out of 12 studies showed a significant effect, with active comparators often outperforming gepirone ER, and a meta-analysis of the failed studies showed no significant effect. Additionally, the longer-term maintenance efficacy trial yielded negative results, and the applicant's post-hoc attempt to repair it was deemed invalid. The FDA also noted deficiencies in impurity acceptance criteria and stability data.

Key points

  • Provide substantial evidence for the effectiveness of gepirone ER in the short-term or longer-term treatment of major depressive disorder (MDD).
  • Address the deficiencies related to the inconsistent antidepressant effect of gepirone ER across clinical trials, including those where active comparators demonstrated superiority.
  • Provide a credible and valid approach to address the negative outcome of the longer-term maintenance efficacy trial (study 28709).
  • Revise the acceptance criterion for Individual unspecified impurity to NMT % in accordance with ICH Q3B guideline.
  • Provide long-term and accelerated stability data for the commercial to-be-marketed drug product in each of the proposed packaging configurations to support the requested expiration date.
  • Amend the application, notify the FDA of intent to file an amendment, or follow other options under 21 CFR 314.120 within 10 days of the letter date.
  • Ensure any amendment responds to all listed deficiencies.
  • The application failed to provide substantial evidence for the effectiveness of gepirone ER in the short-term or longer-term treatment of major depressive disorder (MDD). Only two out of twelve studies showed a significant effect, while the remaining ten studies did not show evidence of an antidepressant effect or even favorable trends. Three trials showed active comparators were statistically superior to gepirone ER, and in two trials, active comparators were superior to placebo while gepirone ER was not. A meta-analysis of the ten failed studies showed an effect size of essentially zero. The negative outcome of the longer-term maintenance efficacy trial (study 28709) further casts doubt on the drug's effectiveness, and the post hoc attempt to repair the study by eliminating patients was deemed not credible or valid. The agency expressed low optimism for a path forward for this drug as an antidepressant.

Cited reasons

  • Lack of Substantial Evidence for Effectiveness in Major Depressive Disorder (MDD)
  • Impurity Acceptance Criterion Revision
  • Insufficient Stability Data for Expiration Date
  • The application was deemed 'not approvable' primarily due to a lack of substantial evidence for the effectiveness of gepirone ER in treating Major Depressive Disorder (MDD). Only two out of twelve clinical trials showed a significant effect, with several studies indicating inferiority to active controls or no favorable trends. Additionally, Chemistry, Manufacturing, and Controls (CMC) deficiencies related to impurity acceptance criteria and insufficient stability data were noted, requiring resolution.

Recommended actions

  • Provide substantial evidence for the effectiveness of gepirone ER in the short-term or longer-term treatment of major depressive disorder (MDD).
  • Address the deficiencies related to the inconsistent antidepressant effect of gepirone ER across clinical trials, including those where active comparators demonstrated superiority.
  • Provide a credible and valid approach to address the negative outcome of the longer-term maintenance efficacy trial (study 28709).
  • Revise the acceptance criterion for Individual unspecified impurity to NMT % in accordance with ICH Q3B guideline.
  • Provide long-term and accelerated stability data for the commercial to-be-marketed drug product in each of the proposed packaging configurations to support the requested expiration date.
  • Amend the application, notify the FDA of intent to file an amendment, or follow other options under 21 CFR 314.120 within 10 days of the letter date.
  • Ensure any amendment responds to all listed deficiencies.

Deficiency summary

The application was deemed 'not approvable' primarily due to a lack of substantial evidence for the effectiveness of gepirone ER in treating Major Depressive Disorder (MDD). Only two out of twelve clinical trials showed a significant effect, with several studies indicating inferiority to active controls or no favorable trends. Additionally, Chemistry, Manufacturing, and Controls (CMC) deficiencies related to impurity acceptance criteria and insufficient stability data were noted, requiring resolution.

Findings

Lack of Substantial Evidence for Effectiveness in Major Depressive Disorder (MDD)

Severity: critical

The application failed to provide substantial evidence for the effectiveness of gepirone ER in the short-term or longer-term treatment of major depressive disorder (MDD). Only two out of twelve studies showed a significant effect, while the remaining ten studies did not show evidence of an antidepressant effect or even favorable trends. Three trials showed active comparators were statistically superior to gepirone ER, and in two trials, active comparators were superior to placebo while gepirone ER was not. A meta-analysis of the ten failed studies showed an effect size of essentially zero. The negative outcome of the longer-term maintenance efficacy trial (study 28709) further casts doubt on the drug's effectiveness, and the post hoc attempt to repair the study by eliminating patients was deemed not credible or valid. The agency expressed low optimism for a path forward for this drug as an antidepressant.

Recommended response: Conduct additional well-designed, adequately powered clinical trials to demonstrate substantial evidence of effectiveness for gepirone ER in MDD, addressing the issues of effect size, comparison to active controls, and consistency across studies. Re-evaluate meta-analysis methodology and consider dose-ranging studies if an inadequate dose is suspected. A new clinical development program may be necessary.

Cited: 21 CFR 314.125(b), section 505(d) of the Act

Impurity Acceptance Criterion Revision

Severity: major

The acceptance criterion for Individual unspecified impurity needs to be revised to NMT % in accordance with ICH Q3B guideline. Any individual impurities at levels higher than the identification threshold should be specified by name, relative retention time, or some other suitable identifier.

Recommended response: Update the acceptance criteria for individual unspecified impurities to comply with ICH Q3B guidelines, ensuring all impurities above the identification threshold are properly characterized and specified.

Insufficient Stability Data for Expiration Date

Severity: major

The provided stability data for the original biconvex tablets and the Organon modified flat tablets is not sufficient to support the requested 36-month expiration date for the drug product. Long-term and accelerated stability data for the commercial to-be-marketed drug product in each of the proposed packaging configurations must be provided.

Recommended response: Generate and submit comprehensive long-term and accelerated stability data for the commercial formulation of gepirone ER in all proposed packaging configurations to support the requested 36-month expiration date.

Regulatory context

Submission stage
final decision
Regulatory pathway
NDA 505(b)

Impact

Impact score
0.95
Estimated delay
730 days
Estimated rework cost
$0
Subsequent action
resubmission

Strategic insights

The primary theme is a fundamental failure to demonstrate clinical efficacy for the proposed indication, compounded by secondary quality control issues. The agency's stance suggests a significant hurdle for future development, indicating that the current data package is insufficient to support approval and raises doubts about the drug's overall clinical value.

Regulatory change impact: Pending sponsor mitigation plan

Approval likelihood after response: 5%

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