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How eCTD v4.0 is Reshaping Regulatory Submissions: What Pharma Needs to Know in 2025

The Life Sciences Industry Faces a Regulatory Turning Point

The life sciences industry operates in one of the most complex regulatory environments, where compliance and speed-to-market are critical for success.

As regulatory frameworks evolve, organizations must navigate increasing complexities while ensuring efficiency and accuracy. At present, the pharmaceutical industry stands at the cusp of a significant shift in regulatory submissions. eCTD v4.0, the latest evolution of the electronic Common Technical Document, promises to streamline processes and enhance data exchange.

What Is eCTD and Why Is Version 4.0 So Important?

Electronic Common Technical Document (which we commonly refer to as eCTD) refers to the standard format for submitting regulatory information for medicinal products, across any country globally. eCTD v4.0 builds upon the foundation of the previous version of eCTD 3.2 but introduces significant enhancements in terms of structure, how data is exchanged between relevant parties, and overall efficiency. That key goal is for a more standardized and harmonized approach to regulatory submissions worldwide going forward.

Global Timelines for eCTD v4.0 Implementation

What are the global implementation timelines for eCTD v4.0? Also, why is Japan and PMDA the current focus of eCTD v4.0 discussions?

The implementation timelines vary for different regions.

 
The PMDA (Japan) is the first agency globally to make eCTD v4.0 mandatory from 2026 and they have already started accepting pilot submissions from 2022. Interestingly, Freyr is helping multiple clients in Japan for their first 4.0 submission in 2024 and 2025. We will talk about it a little later.
 
The EMA (European Medicines Agency) has a phased plan with certain procedures already requiring eCTD v4.0, aiming for mandatory adoption for all applications in the coming years.
 
The FDA (U.S. Food and Drug Administration) is also progressing with its plans, aiming for 2029 for mandatory submissions.
 
Health Canada & TGA Other regions like Health Canada and Australia's TGA are also working towards adoption with their own timelines.

Hence, it is of utmost importance for companies to stay updated on each relevant authority's specific guidance and work with the right regulatory partner for successful submissions in the first go.

CAP indicates Centralized Authorization Procedure

Acceptance of eCTD v4.0 submissions has been implemented by US FDA and Japan PMDA and will be implemented by other major health agencies in 2025/2026.
*CAP indicates Centralized Authorization Procedure.
** Other indicates MRP (Mutual Recognition Procedure), DCP (Decentralized Procedure) and NP (National Procedure)

What's New in eCTD v4.0 - Major Shifts and Enhancements

eCTD v4.0 brings many changes for PMDA and differs considerably from the current processes namely eCTD 3.2 and JP 1.0. Below we are highlighting some of the key changes

Single XML Backbone

Unlike the previous eCTD versions, eCTD v4.0 uses a single XML message to encompass Modules 1 through 5. This simplifies the structure and aims for greater consistency. Currently, PMDA deals with regional-specific XML structures in Module 1 alongside the ICH XML Modules 2-5.

Context of Use (COU)

The concept of a "leaf" is replaced by "Context of Use." COU defines the purpose and lifecycle of a document within the submission. This allows for more precise tracking and management of documents throughout the product's lifecycle. The current process relies on file tags and a hierarchical structure.

Controlled Vocabularies (CVs)

eCTD v4.0 mandates the use of standardized controlled vocabularies for metadata. PMDA has developed a Japan-specific controlled vocabulary (JP CV) to capture local nuances. This will improve data consistency and facilitate easier updates to regional requirements without major system changes.

Forward Compatibility

eCTD v4.0 is designed to be forward compatible with eCTD 3.2.2, allowing for the referencing and potential reuse of previously submitted content. However, there is no direct migration path from the older Japan-specific JP 1.0 format to eCTD v4.0, requiring a more significant preparation effort for submissions that were initially in that format.

Comparison - eCTD v3.2 vs eCTD v4.0

S. No. Concept eCTD v3.2 eCTD v4.0
1 XML Regional .xml Index .xml Single Submission unit.xml
2 Folder Structure Granular Folder Structure Flat Folder Structure
3 Metadata data ICH/ Regional Metadata Keywords replace the eCTD 3.2.2 attributes and valid value
4 Lifecycle

Document Life cycle Replace:

  • One to One

Replace:

  • One to One
  • Many to One
  • One to Many
5 Life cycle Operations New Append Replace Delete New Suspend Replace
6 Sequence Number Starts from 0000 or 0001 Sequence number starts from 1
7 Reuse of Content

Currently Possible but Difficult and Confusing

No UUID for documents

Unique Identifiers (UUID) for each document allow reuse of content across sequences,

regulatory activities and different applications. (Sponsors may

refer to previously submitted content and reduce the size of new sequences. Confusion over duplicate content is removed. Since the UUID is accepted globally, true harmonized submissions across agencies will become a reality)
8 STF (Study Tagging File) Single XML for each clinical studies Context of Use in Module 4 and Module 5 will replace the STF
9 Document Ordering Currently defined by each review tool; may not be the same between tools eCTD 4.0 allows the submitter to explicitly define the display order for files in a specific section
10 Keyword/ attribute modifications

Currently a slight misspelling in eCTD attributes (e.g.,

manufacturer) creates separate eCTD sections

 eCTD 4.0 user-defined keywords/ attributes are managed by the submitter and mistakes/ changes are easier to correct

Strategic Advantages of eCTD v4.0

Also, we are listing some of the key advantages of eCTD v4.0 over the current v3.2.2

Key Advantages

S. No. Key Advantage Details
1 Harmonized submission unit
  • All content from Module 1 through Module 5 is contained in one exchange message – i.e., an XML file covers both ICH and regional information
2 Document reuse
  • Once a document has been submitted, the document may be reused by referencing its unique identifier (ID) from the same or different submission
  • All the contents of the reused document, including references and hypertext links to other documents, should be relevant to any submission that uses it again
3 Context of Use (COU)
  • CTD Heading + Documents and Keywords
  • The Context of Use concept allows for advanced life cycle management operations. A Context of Use may be replaced by one or more Context of Use elements and vice versa (i.e., one to many, many to one) through the context of use life cycle
  • eCTD 4.0 also introduces the ability to apply changes to keyword definition display name values (e.g., drug substance/product names, manufacturers, dosage forms, indication, excipient, group title) without resubmitting the physical files or the Context of Use element
4 Group Title Keywords
  • Group title keywords are new in eCTD 4.0 and are a type of sender-defined keywords. The group title keyword allows the submitter to create further organization of documents under specified headings that allow for more than one document
  • Documents associated with a group title will be displayed separately under the eCTD heading and other associated keywords. The group title keyword will be applied to the lowest heading level.
5 Harmonized submission unit
  • Sets the order of documents within a CTD section
  • Explicitly defines display order of documents under a Context of Use (CoU) or Context Group
  • Sender may reorder submission content or insert submission content into a specificorder within the existing content over time
6 Document Identifier
  • Every document assigned a unique identifier
  • Unique identifier approach means documents can be referenced/reused more effectively without resubmitting the physical file
  • Across a Submission Unit (sequence)
  • Across regulatory activities with an application
  • Across different applications
  • Used to reference the document in a context of use or context group
  • Reuse document metadata (e.g., document title, location)
7 Forward Compatibility from v3.2. to v4.0
  • Transition XML
8 Controlled vocabularies (CV)
  • 5 types of CV (Specified by ICH, region, HL7, External organization and Sender defined)

How Freyr Can Help

Ready to streamline your regulatory submissions? In our next blog, we're pulling back the curtain on eCTD v4.0. We'll walk you through what a typical v4.0 submission looks like, uncover the critical regional variations, and share expert insights into navigating the distinct processes for Japan, the EU, and the US.

Freyr is already a trusted partner for many clients in Japan, the US, and the EU, guiding them through their live and pilot eCTD v4.0 submissions. By working hand-in-hand with the JP PMDA, US FDA, and EMA, we're committed to helping you accelerate the delivery of vital medicines to patients worldwide.

Curious about how we can help you achieve faster, more efficient submissions? Reach out to Freyr today!