Why do I need to consider botanical drug IND?

Dietary supplements:

  • Can not make medical claims

  • Have low market barrier and high market competition

  • High product development cost results in low profit margin

Botanical Drug IND:

  • Ability to make unique medical claims and use that as a market barrier to reduce competition

  • No need to identify active ingredients

  • Can be a single plant or mixture of multiple plants

  • No need to describe mechanism of action

  • If an already known efficacious botanical product, success rate is much higher than synthesizing a new chemical molecule or purifying a chemical molecule.

  • Spend initial investment to obtain IND# from FDA or complete phase 1, then to out-license to big pharma. The fee received from out-licensing could be US$5~12M depending on indications and terms


​What is the difference between isolating active ingredients vs botanical drug approach?

​​Isolating active ingredients approach:

  • Identifying active ingredients responsible for medical benefits is time consuming

  • After isolating one active ingredient from a botanical product, whether that active ingredient is still producing the same medical benefits is uncertain

  • Isolated active ingredient is the traditional small molecule drug development approach in which sponsors need to describe mechanism of action

  • Studying mechanism of action takes time and resources


Botanical drug approach:

  • Under FDA botanical drug development category, no purification or isolation of active ingredients is required

  • A botanical drug product can be a single plant, a portion of a single plant, or mixture of multiple plants

  • No mechanism of action is required

  • As long as a final drug product shows safety and efficacy through FDA IND phase 1,2,3 trials, the product is approved as a prescription drug on the US market. FDA is looking for safety and efficacy for the totality of the drug product, not for ingredients inside.


Conclusion: The botanical drug IND development pathway is an efficient drug development pathway.

Botanical IND
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Botanical Drug Product Initial Assessment (Paid Service)

"Is my botanical product a good fit for the botanical drug IND process?"


The Drug Product Initial Assessment is a fee-based service used to evaluate data/material already collected, and to identify potential data gaps, as well as identify measures to close the gap

  • Review data/materials provided by sponsors

  • Assess data validity and usability for FDA botanical drug IND

  • Identify data gap

  • Identify measures to close a gap

  • Identify timelines and costs associated with closing a gap for the purpose of obtaining a FDA IND#

  • Advise on selection of medical indication

  • Estimate the success rate of gaining a FDA IND#

  • Estimate the likelihood to out-license a drug product after phase-1 to big pharma

Initial Assessment
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What data is required to open an IND with the FDA?

  • Product name, description of plant products, short description of the manufacturing process, and the final product formulation

  • Historical background information on the product development concept

  • HPLC full spectrum fingerprints of the final drug product

  • Product scale-up and final formulation, and animal and clinical studies plans

  • Proposed indication or context of product development

  • Summary of studies completed

  • Prior human experience, if any

  • Proposed clinical study plan, whether the animal efficacy rule is being considered

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Herbal & Herbal Product Preclinical Study Design Template (Paid Service)

​Different from a single molecule IND process, the preclinical development of drug products of mixed plants is much more complex. Although ingredients and indications differ among IND applications, all botanical drug preclinical studies share the same success formula. ABDA offers a preclinical study design template to assist those who want to initiate the FDA botanical drug IND process by themselves. The template covers instruction for the following areas:

  • Qualification and quantification of ingredients in a botanical drug product

  • Establish quality control mechanism for a botanical drug product

  • Identify unknown ingredients in a botanical drug product

  • Quantify known ingredients in a botanical drug product

  • In-vitro study for a botanical drug product with many ingredients

  • In-vivo study for a botanical drug product with many ingredients

  • Pre-clinical pharmacokinetics study for a botanical drug product with many ingredients

  • Dose-response study for a botanical drug product with many ingredients


FDA Botanical Drug pre-IND Briefing Package Development (Paid Service)

​Rather than handing over material and data to a CRO to develop FDA IND programs, some clients want to actively participate in the process as they know their products the best. ABDA offers an interactive development process in which clients and ABDA experts co-develop FDA documents: ABDA experts explain botanical Guidance and provide actionable direction on program development, clients collect and summarize product information and data, and develop contents; ABDA experts review and comment, and to finalize. This co-development model provides an cost-effective solution to the botanical IND development needs for start-up botanical drug companies.

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Certificate of Analysis (Paid Service)

ABDA affiliated labs are FDA and DEA certified with schedule I to V permits. ABDA provides Certificate of Analysis (CoA) for cannabis products and for herbal products:

  • Identification and quantification of THC according to FDA guidance

  • Full spectrum cannabis testing and fingerprint

  • Full spectrum herbal product testing and fingerprint

  • Identification of unknown ingredients

  • Quantification of known ingredients

  • Product stability test

  • Bioavailability test

  • Bioequivalence test


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