A mid-sized pharmaceutical manufacturer near Frankfurt produced over-the-counter pain relief tablets that were sold across Europe and had recently entered the US market. Their drug establishment was registered. Their products were listed with valid NDC numbers. The Drug Facts panel was compliant. Everything was in order — until accounts payable missed an invoice.
The invoice
The FDA issues annual Generic Drug User Fee Act (GDUFA) invoices to every registered drug establishment. The fee for FY2026 was approximately $5,800 for a foreign finished dosage form facility. The invoice was sent to the company's headquarters in Germany. It landed in the general accounts payable inbox, was mistaken for a routine vendor invoice, and was routed to a queue that processed payments on a 60-day cycle.
The FDA payment deadline passed. The FDA sent a reminder. The reminder was overlooked. Sixty days after the original due date, the FDA placed a hold on the establishment's registration.
The consequences
A registration hold means that the FDA will not accept any new drug applications from the establishment, and — more immediately — that the establishment's products are subject to import refusal. The company discovered the hold when their US distributor tried to import a routine shipment and was notified by their customs broker that the FDA had flagged the entry.
The shipment was valued at €42,000. It sat at the port while the company scrambled to pay the overdue fee, confirm receipt with the FDA, and wait for the hold to be lifted. The hold was removed 9 business days after payment was received — a fast resolution by FDA standards, but 9 days of port storage and a distributor who had already sourced the product from a competitor.
The fix
We took over their US Agent and registration management. We now track every GDUFA and PDUFA fee deadline for their facility and send payment reminders 30 days before the due date. The invoice goes to a designated compliance contact — not the general accounts payable inbox — and payment confirmation is verified with the FDA before the deadline passes.
Drug establishment fees are not optional. They are not negotiable. And they will shut down your US market access if they go unpaid. If you are a foreign drug manufacturer and you are not sure who is tracking your fee deadlines, contact us at fdabridge.com/drug.
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