Exploring Common CMC-Related Delays in Drug Product Development

Exploring Common CMC-Related Delays in Drug Product Development

Delays in drug development often trace back to overlooked CMC challenges. These technical details—how a drug is made, quality controlled, and tested—shape the path from lab to patient. A strong candidate can stall when formulation or manufacturing plans fall short. Teams that invest early in strategic CMC planning avoid costly surprises and keep development on track. Time lost here isn’t just financial—it’s a missed chance to help patients.

At DSI, we’ve seen how avoidable CMC hurdles can create significant roadblocks. Understanding these pitfalls is the first step toward eliminating them.

Typical CMC Bottlenecks in Development

Formulation Challenges

Countless variables must be navigated when bringing a stable, effective drug product to market—whether an oral tablet, injectable, or inhalable. Stability and processing issues, difficulty in achieving uniformity, or failure to scale a lab formulation into a manufacturable dosage form are all common causes of delay. In some cases, the drug degrades faster than expected or interacts unfavorably with excipients, requiring teams to reformulate. Such setbacks can push timelines by months, particularly when they occur late in development.

Process Scale-Up and Validation

What works at the lab bench doesn’t always translate to manufacturing scale. Process scale-up can introduce new complications: containment of potent compounds, unexpected impurities, or inability to replicate process with equipment at commercial sites. Furthermore, as development nears Phase 3 or commercialization, the process must be validated—demonstrated to produce consistent, quality product across multiple batches. Failure to meet validation criteria is a major reason for late-stage delays.

Analytical Method Gaps

Robust, validated analytical methods are the backbone of quality control. If these methods aren’t developed in parallel with the formulation and process, they can become bottlenecks. For example, if release testing methods aren’t ready or validated when material is needed for a pivotal trial, manufacturing is delayed. Likewise, if stability-indicating methods miss key degradants, entire studies may need to be repeated. Analytical oversight remains one of the most underestimated sources of CMC delays.

Supply Chain and Raw Materials

CMC also encompasses material sourcing. Delays often arise from long lead times on active pharmaceutical ingredients (APIs), reliance on a single-source supplier, or excipients/components with variable quality and/or long lead times. A single disrupted shipment or quality deviation can halt manufacturing, leaving development timelines at the mercy of external vendors.

Regulatory Setbacks from CMC Issues

Complete Response Letters (CRLs)

Regulatory agencies are increasingly citing CMC deficiencies in CRLs. These letters—issued when a marketing application cannot be approved in its current form—often stem from unresolved or poorly documented CMC work. Whether it’s inadequate process validation, insufficient stability data, or gaps in impurity characterization, these are avoidable delays that can cost companies millions and jeopardize launch timelines.

Clinical Hold Risks

At earlier stages, CMC issues can trigger clinical holds. Uncharacterized impurities, sterility assurance concerns, or insufficient stability data for clinical batches can prompt regulators to pause ongoing or planned trials. Resolving such issues can take months, affecting trial momentum and investor confidence.

Postponed Trials

Sometimes the regulatory red light isn’t formal—it’s operational. Companies frequently find themselves forced to delay a Phase 2 or 3 trial because the drug product isn’t ready or lacks sufficient shelf life to support study duration. These delays, while less dramatic than a formal hold, can still erode development efficiency and market positioning.

Strategies to Mitigate CMC Delays

Early CMC Planning

The foundation for timely development is laid early. A strategic CMC roadmap, synchronized with clinical milestones, ensures that formulation, process, and analytical development are progressing in tandem. Building in buffers for troubleshooting allows teams to address issues without derailing timelines.

CMC Risk Assessments

Proactive risk assessments, such as how BCS class affects filing requirements and Failure Mode and Effects Analysis (FMEA), help identify potential weak points in a process or formulation. Whether it’s a drug solubility/release, novel excipient, or scale-dependent impurity, flagging high-risk areas early allows for the implementation of mitigation strategies—such as developing alternate suppliers or backup formulations—before they become problems.

Phase-Appropriate Controls

Striking the right balance between rigor and pragmatism is essential. Early-phase development doesn’t demand perfection, but it does require solid foundations. An unstable formulation or unscalable process, even if acceptable in Phase 1, can become a liability later. Planning for scalability and robustness from the outset—without over-engineering—is the hallmark of effective CMC strategy.

Cross-Functional Coordination

Communication between CMC, clinical, and regulatory functions must be continuous. If a formulation change is proposed, clinical teams need to understand the impact on study timelines, and regulatory affairs must assess whether agencies should be informed. Coordinated decision-making helps resolve issues quickly and prevents downstream surprises.

DSI’s Approach to Preventing CMC Delays

Expert Oversight

DSI brings seasoned CMC expertise to the table—spotting red flags others might miss. Whether it’s a formulation that’s likely to fail scale-up or a process that lacks control, we help clients resolve these issues before they become delays. Our experienced drug product experts understand how to prioritize development activities to de-risk the development of a new product.

Strategic Project Management

We help sponsors design development plans that align CMC readiness with clinical and regulatory needs. From ensuring methods are validated ahead of pivotal trials to guiding stability study design for NDA submissions, our team ensures nothing is left to chance.

Regulatory Foresight

CMC submissions must meet evolving global standards. DSI’s regulatory experts help craft complete, high-quality CMC sections for INDs and NDAs—reducing the likelihood of questions, requests for clarification, or outright refusals.

Staying Ahead of CMC Delays

The path from molecule to market is highly complex, and drug product development is often derailed not by biology, but by CMC missteps. Sub-optimal formulation or process development, scale-up gaps, analytical bottlenecks, and raw material issues can all delay progress. But with the right foresight and expertise, these pitfalls can be avoided.

At DS InPharmatics, we partner with biotech and pharma innovators to build CMC strategies that align with their goals and mitigate risk. Our consulting services deliver practical, regulatory-informed solutions that keep development on track and products moving toward approval. 

Meranda Parascandola
Meranda Parascandola
Meranda Parascandola is a member of the DSInpharmatics team and has written a variety of blog posts which you can read here.