RECORDREFERENCE OUTLINE

Compounding Route Assessment (503A or 503B)

Assessment that matches a compounding business model to section 503A or 503B of the FD&C Act: who orders and receives the drugs, a product screen against the bulk-substance, essentially-a-copy and withdrawn-drug restrictions, and the obligations each route then carries, from patient-specific prescriptions and USP chapters to FDA registration, semiannual reports, cGMP and labelling.

What a template is not

A template is a document baseline to adapt inside your own quality system. SPEQ does not approve, validate, or take responsibility for what you issue from it, and using one is not evidence of compliance.

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HOW TO FILL THIS IN
How to Choose Between 503A and 503B Compounding, step by step →
REGULATIONS MAPPED
FD&C Act §503AFD&C Act §503BUSP <795>USP <797>
DOCUMENT TYPE
Record
LAST UPDATED
October 2026
PURPOSE

An assessment that decides whether a compounding operation belongs under section 503A or section 503B of the FD&C Act, and then records how it meets that route’s obligations. The two routes carry different exemptions: 503A drugs are exempt from cGMP but must be patient-specific; 503B outsourcing facilities may supply without patient-specific prescriptions but must comply with cGMP, register, report and accept FDA inspection.

What's Inside

✓Business model questions that point to one route or the other
✓A product screen against bulk-substance lists, essentially-a-copy restrictions and the withdrawn-drug list
✓The 503A obligations, from prescriptions to interstate distribution
✓The 503B obligations, from registration and semiannual reports to cGMP and labelling

How to Use It

1Answer the business model questions honestly; the route follows from how products are ordered and supplied.
2Screen every product before it enters the formulary.
3Complete the obligations table for the selected route, with the procedure and owner for each.
4Revisit the assessment when the customer base, product list or distribution states change.
5For a 503B facility, file the first product report on registering, then diarise June and December, and the 1 October to 31 December registration window.
6Keep each bulk substance’s certificate of analysis and the evidence that its manufacturer is registered with FDA alongside the product screen.
DOCUMENT CONTENTS

The full section structure of this template — every section and sub-section, so you can use it as a baseline for your own site document.

—Document Control
› Document Information› Approval Signatures› Revision History› Distribution List
1Business Model
2Product Screen
3503A Obligations
4503B Obligations
AAppendix A — Approval
REGULATORY CONTEXT

Section 503A of the FD&C Act (21 U.S.C. 353a) exempts qualifying patient-specific compounding from sections 501(a)(2)(B), 502(f)(1) and 505, subject to its conditions on bulk substances, copies and interstate distribution. Section 503B (21 U.S.C. 353b) exempts drugs compounded by registered outsourcing facilities from sections 502(f)(1), 505 and 582, but not from cGMP, and sets registration, reporting, adverse-event, labelling and inspection requirements. USP <795> and <797> became official on 1 November 2023. The assessment structure is SPEQ practitioner synthesis.

MAPPED STANDARDS
FD&C Act §503AFD&C Act §503BUSP <795>USP <797>
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