The FDA has published an initial batch of 202 complete response letters (CRLs)—many of which were issued in response to applications submitted to the FDA between 2020 and 2024—that were seeking the approval of drugs or biologic products.1
Notably, 32 of the published CRLs were issued in response to submissions seeking the approval of oncology-related treatments and products.
The initial set of published decision letters is composed of those addressing deficiencies in since-approved applications, and is now accessible to the public at open.fda.gov. Parts of these CRLs have been redacted to protect confidential commercial information and trade secrets. The FDA plans to publish additional CRLs from its archives.
The publication of these CRLs reflects the FDA’s broader efforts to increase transparency surrounding the administration’s decision-making process, according to a news release from the FDA. The availability of these letters also gives the public greater insight into some of the most common deficiencies that the FDA cites for product sponsors to address before their product applications may be approved.
“For far too long, drug developers have been playing a guessing game when navigating the FDA,” Marty Makary, MD, MPH, FDA Commissioner, stated in the news release. “Drug developers and capital markets alike want predictability. So today we’re one step closer to delivering it to them, with an ultimate goal of bringing cures and meaningful treatments to patients faster.”
The FDA issues CRLs directly to product sponsors after completing the review process and determining that it cannot approve an application in its present form. CRLs may be issued for a variety of reasons, including safety concerns, efficacy concerns, bioequivalence issues, and manufacturing deficiencies. The specific reasons for each CRL are detailed in the letters, which may also include recommendations for addressing these deficiencies.
Historically, the FDA has not routinely published CRLs that have been issued for pending applications, which has led to discrepancies between the FDA’s rationales for its decisions and the sponsors’ representations of this decision-making to stakeholders and the public. For example, an analysis conducted by FDA researchers in 2015 revealed that in public announcements sharing that their product applications were not FDA approved, sponsors did not mention 85% of the FDA’s concerns regarding safety and efficacy. Furthermore, the study found that approximately 40% of CRL announcements by sponsors did not disclose when the FDA recommended the initiation of a new clinical trial for safety- or efficacy-related reasons. Additionally, there is a lack of disclosed explanations about the issuance of CRLs within the drug development industry, leading sponsors to repeat similar mistakes.
Notable CRLs in the initial published batch include those regarding the applications seeking the approvals of:
- Sodium thiosulfate (Pedmark) for the prevention of cisplatin-related ototoxicity in pediatric patients at least 1 month of age with localized, nonmetastatic solid tumors (August 2020)2; this agent was later FDA approved for this indication in September 2022.3
- Toripalimab-tpzi (Loqtorzi) plus gemcitabine and cisplatin for the first-line treatment of patients with advanced recurrent or metastatic nasopharyngeal carcinoma, as well as toripalimab monotherapy for the second-line and later treatment of patients with recurrent or metastatic disease (May 2022)4; these regimens were later FDA approved for their respective indications in October 2023.5
- Denileukin diftitox-cxdl (Lymphir) for the treatment of patients with relapsed/refractory cutaneous T-cell lymphoma (July 2023)6; this agent was later FDA approved for this indication in August 2024.7
- Zolbetuximab-clzb (Vyloy) for the treatment of patients with locally advanced unresectable or metastatic HER2-negative gastric or gastroesophageal junction adenocarcinoma whose tumors are Claudin18.2 positive (January 2024)8; this agent was later FDA approved in combination with chemotherapy for this indication in October 2024.9
References
- FDA embraces radical transparency by publishing complete response letters. FDA. July 10, 2025. Accessed July 10, 2025. https://www.fda.gov/news-events/press-announcements/fda-embraces-radical-transparency-publishing-complete-response-letters?utm_medium=email&utm_source=govdelivery
- FDA. Complete Response Letter for NDA 212937, Fennec Pharmaceuticals, Inc. Accessed July 20, 2025. https://open.fda.gov/apis/other/approved_CRLs/
- FDA approves sodium thiosulfate to reduce the risk of ototoxicity associated with cisplatin in pediatric patients with localized, non-metastatic solid tumors. FDA. Updated March 14, 2024. Accessed July 10, 2025. https://www.fda.gov/drugs/resources-information-approved-drugs/fda-approves-sodium-thiosulfate-reduce-risk-ototoxicity-associated-cisplatin-pediatric-patients
- FDA. Complete Response Letter for BLA 761240, Coherus BioSciences, Inc. Accessed July 10, 2025. https://open.fda.gov/apis/other/approved_CRLs/
- Coherus and Junshi Biosciences announce FDA approval of Loqtorzi (toripalimab-tpzi) in all lines of treatment for recurrent or metastatic nasopharyngeal carcinoma (NPC). News release. Coherus BioSciences and Shanghai Junshi Biosciences. October 27, 2023. Accessed July 10, 2025. https://www.globenewswire.com/news-release/2023/10/27/2768663/0/en/Coherus-and-Junshi-Biosciences-Announce-FDA-Approval-of-LOQTORZI-toripalimab-tpzi-in-All-Lines-of-Treatment-for-Recurrent-or-Metastatic-Nasopharyngeal-Carcinoma-NPC.html
- FDA. Complete Response Letter for BLA 761312, Citius Pharmaceuticals, Inc. Accessed July 10, 2025. https://open.fda.gov/apis/other/approved_CRLs/
- Citius Pharmaceuticals receives FDA approval for Lymphir (denileukin diftitox-cxdl) immunotherapy for the treatment of adults with relapsed or refractory cutaneous T-cell lymphoma. News release. Citius Pharmaceuticals. August 8, 2024. Accessed July 10, 2025. https://citiuspharma.com/investors/news-media/news/release-details/2024/Citius-Pharmaceuticals-Receives-FDA-Approval-for-LYMPHIR-denileukin-diftitox-cxdl-Immunotherapy-for-the-Treatment-of-Adults-with-Relapsed-or-Refractory-Cutaneous-T-Cell-Lymphoma/default.aspx
- FDA. Complete Response Letter for BLA 761365, Astellas Pharma US, Inc. Accessed July 10, 2025. https://open.fda.gov/apis/other/approved_CRLs/
- FDA approves zolbetuximab-clzb with chemotherapy for gastric or gastroesophageal junction adenocarcinoma. FDA. October 18, 2024. Accessed July 10, 2025. https://www.fda.gov/drugs/resources-information-approved-drugs/fda-approves-zolbetuximab-clzb-chemotherapy-gastric-or-gastroesophageal-junction-adenocarcinoma