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Extractables & Leachables and USP <381>/<382> for Parenterals: Qualifying the Container Closure System under USP, ICH Q3E and FDA

Extractables & Leachables and USP <381>/<382> for Parenterals: Qualifying the Container Closure System under USP, ICH Q3E and FDA

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Second edition · first unified edition · regulatory cut-off 26 September 2026

From elastomeric component to leachable in the patient: the parenteral container closure system, qualified with the text next to every value.

USP <382> has been official since 01/12/2025 without the fragmentation section, which stays in USP <381>, and since 01/02/2026 the current text is the Revision Bulletin. ICH Q3E is a Step 2 draft of 01/08/2025, with Step 4 planned for June 2027; the August 2026 FDA draft on container closure systems is open for comment until 13/10/2026. This guide brings functional tests, extractables and leachables studies, SCT and AET thresholds, single-use and dossier together: 24 chapters in six parts, 6 appendices, 265 pages in the English edition, 267 in the Italian, and 16 editable tools, for €129.

265 pages (ENG) · 267 (ITA) · PDF A424 chapters in six parts + 6 appendices16 editable tools: 10 Excel + 6 WordUSP <381> · <382> · <661> · <665>Draft ICH Q3E · PQRI · 2026 FDA draft85 sources in the register99 decisions tracked
Two separate editions: you choose the language. The guide and the toolkit exist as an English edition and as an Italian edition, with identical structure. Choose the ENG - English or the ITA - Italiano variant: the purchase gives access to the edition you choose, with its 16 tools in the same language.
One guide that replaces two. This second edition combines and replaces two guides published in first edition: “USP 382 – Implementation Guide for Parenteral Closure Systems” (December 2025) and “Extractables & Leachables (E&L) GMP – Risk-Based Operational Guide for Defensible Decisions in FDA/EMA Audits” (January 2026). It has been rewritten from scratch: container closure system and E&L now sit on a single path, with a single toolkit. If you wrote protocols or SOPs on the first editions, the front matter lists what to review first: criteria attributed to <382>, fragmentation, applicability dates, use of the TTC, status of ICH Q3E. If you bought either guide, you receive this edition at no extra cost.

The problem: one system, three threshold frameworks, a USP chapter revised twice

A stopper that meets USP <381> does not make the system suitable. USP <382> tests how the component functions inside the system in which the drug reaches the patient: integrity, penetration, self-sealing, spike retention, plunger, tip cap. Fragmentation, which many test plans still list under <382>, was removed from the chapter before it became official: in the USA it stays in <381>, in the EU it is performed under Ph. Eur. 3.2.9.

On thresholds, three texts give different values for the same product, and none of them is binding as of 26/09/2026. The draft ICH Q3E ties the SCT to the duration of exposure: 1.5 µg/day above 10 years, 26 µg/day up to one month. PQRI 2021 uses an SCT of 1.5 µg/day and a QT of 5 µg/day; the August 2026 FDA draft gives 1.5 µg/day for most chronic-use drugs and no numerical QT. With the same extraction, the same stopper has an AET of 0.75 or 13 µg per stopper depending on the duration declared.

This guide sets every value next to the document, paragraph or line, status and market it comes from, and leaves to the company the choices that no text makes for it, each with its code, who decides and the document in which it is recorded.

The guide
24 chapters in six parts — the framework, components and functionality, extractables and leachables, process and single-use, dossier and lifecycle, readiness and verification — and 6 appendices. Every chapter follows the same path: component or system → function or risk → text → status → force in the market → value with its origin, or the silence of the text → company decision → document → evidence for the inspector or the assessor.
The toolkit
16 editable tools per edition: 10 Excel workbooks and 6 Word documents, each with instructions on purpose, inputs, outputs, who completes it, who approves it and its limits. Values from official texts sit in protected reference sheets, with document, point and label; every Excel tool has a “Check” sheet that recalculates the examples of the book and of Appendix F and flags any difference.
Lifetime updates
Some dates are already set: comments on the FDA draft close on 13/10/2026; Step 4 of ICH Q3C(R10) is planned for December 2026; Step 4 of ICH Q3E is planned for June 2027; and USP issues new Revision Bulletins. When the texts change, you receive the revised guide and toolkit at no extra cost.
€129, and a snapshot dated 26 September 2026

This edition is written on the sources as read on 26 September 2026. Every document cited carries a status label — current, draft, in development, superseded — and, wherever a sentence could read as an obligation, a nature label: requirement, guidance, good practice, GuideGxP elaboration. The register lists 85 sources with their access date, and the 99 decisions the guide leaves to the company are tracked with who decides, on what basis and where it is recorded.

The price is €129.00. Second edition, September 2026, version 2.0, first unified edition: 265 pages in the English edition, 267 in the Italian, 24 chapters, 6 appendices and 16 editable tools.

The 16 tools in the toolkit

Ten Excel and six Word files, 16 per edition. No operational value is preloaded. Extraction solvents, temperatures and times, surface-to-volume ratios, number of batches and time points, identification criteria, functional test criteria, sample sizes, internal limits, notice periods and frequencies are <to be defined> placeholders, each with its decision code. Values from official texts appear only in the reference sheets, with document, point and label; USP values carry the public-summary statement. Example rows concern Arvena Pharma, a fictitious company, and are marked EXAMPLE.

EXCEL
01 · Market and component applicability matrix
What applies in which market, from when and with what force: document × market matrix, divergences between PQRI, the draft Q3E and the FDA draft, relevance by product and verification log.
EXCEL
02 · E&L risk assessment by component and system
E&L risk factors for each component, with source and score on the company's own scale, through to the justified type of study and the cumulative risk. Flags a direct-contact component left with no study and no justification.
EXCEL
03 · SCT/AET calculator (draft Q3E, PQRI, M7) with examples
SCT and AET by product and scenario with the threshold framework declared: the four scenarios of the draft Q3E, comparison with PQRI, LOQ against AET, Class 1 limits. Flags a typed-in SCT and a maintenance dose used as the MDD.
EXCEL
04 · USP <382> functional test plan by system type
Which functional tests are needed by system and market, and on which text: system × test matrix without criteria, plan, results and a Criteria sheet where the company records the criteria it read in USP–NF, with version and date. Flags fragmentation planned under <382>.
EXCEL
05 · Component and supplier data register
A single master record of product-contact components: compliance by market, supplier data against the AET, elements without a PDE, change notifications and supplier monitoring.
EXCEL
06 · Extractables study planner
The study design before the protocol: calculated surface-to-volume ratio, solvents and conditions with their rationale, techniques, targeted Class 1 tests, reporting. Flags an LOQ above the AET with no strategy.
EXCEL
07 · Leachables register and toxicological assessment
Exposures, classes of the draft Q3E, margins on the three threshold frameworks, elements, biologics and correlation with the extractables, with a dossier view of the peaks above the AET.
EXCEL
08 · Single-use risk assessment <665>/BPOG
The risk of single-use manufacturing components against the process AET: level, bridging or simulation, receipt criteria (Annex 1 §8.138). Flags USP <665> treated as mandatory.
EXCEL
09 · Component and supplier change impact assessment
From the change to the plan: functional, E&L and integrity studies to repeat, last-time buy, first batch after approval, Module 3 sections.
EXCEL
10 · E&L and closure programme gap assessment with dashboard
The programme measured against the applicable texts, with the verb of the source, by requirement, product and market. No “Compliant” without evidence, no gap against a draft text.
WORD
11 · SOP — E&L programme and container closure system qualification
The framework procedure of the programme: responsibilities, definitions, sixteen procedure sections and annexes, built on the decisions taken in tools 01–10.
WORD
12 · Extractables study protocol
Type of study, processed samples, AET and threshold framework, solvents and conditions, techniques, Class 1 and elements, identification, reporting, laboratory.
WORD
13 · Leachables and simulation study protocol
Simulation, batches, conditions, AET and LOQ, target leachables, methods, integrity, correlation with the extractables, reporting.
WORD
14 · Leachables toxicological assessment report
From exposure to the signature of the qualified toxicologist: classes, mutagenicity under the principles of M7, PDE, local toxicity, elements, biologics, conclusion.
WORD
15 · Component supplier questionnaire and quality agreement
The questionnaire (sites, compound, compliance, E&L data, Class 1 precursors) and the agreement (responsibilities, change notification, last-time buy, audit, letters of authorisation).
WORD
16 · Inspection and assessment readiness kit
Evidence index, the teaching questions of Chapter 24 with expected evidence and red flags, independent review checklist, mock inspection and minutes. No real findings.

Use it tomorrow morning

The situationWhat you use
The stopper compound is being discontinued: you need a replacement stopperChapters 5, 13 and 20 + tools 05, 09 and 12: comparative extractables study, functional tests to repeat, recalculated AET, Module 3 sections. Case 1 of Chapter 24 follows a lyophilisate from the supplier's change notification to the dossier
The test plan lists fragmentation under <382>Chapters 5 and 6 + tool 04: the Revision Bulletin of 25/04/2025 removed it from <382> before the official date; it is planned as a <381> test in the USA and under Ph. Eur. 3.2.9 in the EU, with the version of the text consulted
Which SCT for an antibody in a prefilled syringe, lifelong therapy?Chapters 11, 14 and 16 + tool 03: for lifelong therapy the draft Q3E, PQRI and the FDA draft converge on 1.5 µg/day; the AET is calculated on the maximum dose in a day, that is the loading day, not on the maintenance dose
Infusion bag at 500 mL a day: the LOQ does not reach the AETChapters 14 and 15 + tools 03 and 13: an AET of 1.5 ng/mL against a screening LOQ of 10 ng/mL, required factor 6.67, 10× concentration and an effective LOQ of 1.0 ng/mL in the Arvena example
A product sold in the EU only: is USP <382> needed?Chapters 3 and 6 + tool 01: in the EU the mandatory pharmacopoeial references are those of the Ph. Eur., and USP chapters are the reference for the US market; using them as an internal reference is a choice that is recorded
Single-use bags, filters and tubing in downstream processingChapter 17 + tool 08: USP <665>, official since 01/05/2026 for manufacturing components, Annex 1 §§8.131-8.139, the BPOG protocol; the process AET is calculated on the minimum batch, not the typical one
A US dossier while the 2026 FDA draft is out for commentChapters 19 and 21 + tools 09 and 11: CTD 3.2.P.2.4, 3.2.P.7 and 3.2.S.6, DMFs; the draft is not final guidance and comments close on 13/10/2026; it refers to <381> for penetrability, fragmentation and self-sealing and does not cite <382>
An inspection or assessment is comingChapters 22-24 + tools 10 and 16: recurring errors in eight families, gap assessment in fourteen areas, four case studies on Arvena Pharma and 36 questions an inspector or assessor may ask, each with expected evidence and red flags
Why an E&L value without a document does not hold

A draft stays a draft. ICH Q3E is at Step 2 of 01/08/2025 and Step 4 is planned for June 2027: until then it indicates the expected direction and is not a requirement. Every value from the draft carries the same statement in the book, subject to change in the final version, and the main divergence is spelled out: the QT is 5 µg/day for PQRI, 12 or 26 µg/day for the draft Q3E.

The USP text is not reproduced. The official USP–NF texts were not consulted for this edition: status, dates and structure of the chapters come from USP notices and Revision Bulletins and from the official previews. The few numerical values come from public summaries by USP and leading suppliers, are marked as such and refer you to the current chapter; procedures and acceptance criteria are read in the official text. The book contains no USP table, transcribed or adapted.

Requirement or recommendation, and where. In the USA a USP general chapter below <1000> is a requirement when it applies to the product; from <1000> upwards chapters are informational; in the EU no USP chapter is mandatory. 21 CFR 211.94 is a requirement; the PQRI recommendations are industry good practice, not an FDA guidance. Labels state at every citation what applies and where.

No invented numbers. The inspector's questions are built for teaching purposes and do not reproduce actual findings; the published cases — EPREX, tungsten in prefilled syringes, bDtBPP in single-use bags — are cited with their source; the calculation examples are illustrative and none of them is a recommended value. Verification cut-off 26 September 2026, a register of 85 sources, 99 decisions tracked.

Regulatory status as of 26 September 2026

What is current, what is still a draft and what does not exist: the same snapshot as the status box that opens the book.

DateDocumentStatus
01/12/2025USP <382> official, without the fragmentation section (removed by the Revision Bulletin of 25/04/2025); the USP <381> revision official, which retains the fragmentation test; USP <661.1> and <661.2> applicable.CURRENT
01/02/2026USP <382> Revision Bulletin official: it is the current text of the chapter. Cartridge self-sealing at 1.0 times the maximum number of scheduled punctures, according to public summaries by USP and leading suppliers (official USP–NF text not consulted: verify against the current chapter).CURRENT
01/05/2026USP <665> official: it covers plastic manufacturing components (single-use systems), not primary packaging, and is not an applicable chapter unless referenced by the General Notices, a monograph or an applicable chapter.CURRENT
01/08/2025ICH Q3E, Step 2 draft: consultations closed in the EU (18/12/2025) and in the USA (30/01/2026); Step 4 planned for June 2027. It is not a requirement.DRAFT
13/10/2026Comments close on the August 2026 FDA draft on container closure systems (Federal Register notice of 14/08/2026): when final, it will supersede the May 1999 guidance.DRAFT
December 2026ICH Q3C(R10), with Step 4 planned: a planned date, not a certain one.IN DEVELOPMENT
—Not in existence as of 26/09/2026, in the sources consulted: a Ph. Eur. chapter dedicated to E&L and an EU equivalent of USP <382>. EMA Q&As dedicated to E&L could not be verified on an official source.DOES NOT EXIST

In the EU, Ph. Eur. 3.2.9 for rubber closures, chapters 3.1.16, 3.1.17 and 3.1.18 implemented from 01/01/2026, the EMA guideline on plastic immediate packaging materials and Annex 1 §§8.131-8.139 for single-use systems remain current; in the USA the May 1999 FDA guidance remains the published guidance until the 2026 draft is finalised.

Inside the guide

Part I — The framework (Chapters 1–4). How to read the book, with its labels and six reading paths by role; the 1999-2027 calendar and the status of the texts; legal force by market — USA, EU, ICH and other jurisdictions; the container closure system as a system: what has to be demonstrated, and with which data.

Part II — Components and functionality (Chapters 5–10). Elastomeric components: USP <381>, <1381> and Ph. Eur. 3.2.9; USP <382>: rationale, applicability by system type and relationship with <381>; vials, bags and delivery systems; prefilled syringes, cartridges, pens and autoinjectors; container closure integrity as an interface; plastics, glass and materials: <661.1>/<661.2>, <660>, Ph. Eur. 3.1/3.2 and the EMA guideline.

Part III — Extractables and leachables (Chapters 11–16). The E&L framework: definitions, ICH Q3E, USP <1663>/<1664> and PQRI; risk assessment by dosing, route, duration, contact and materials; extractables studies, with design, conditions, supplier data and bridging; analytics and thresholds: SCT, AET, identification and quantitation; leachables studies and simulation on stability; the toxicological assessment: PDE, TTC, M7, Q3D and the classes of the draft Q3E.

Part IV — Process and single-use (Chapters 17–18). Single-use systems: USP <665>/<1665>, BPOG and Annex 1 §§8.131-8.139; suppliers, third-party data and change notification.

Part V — Dossier and lifecycle (Chapters 19–21). The dossier: CTD 3.2.P.2.4, 3.2.P.7, 3.2.S.6, DMFs and the 2026 FDA draft; change control of the container closure system and requalification; texts on the move and how to monitor them.

Part VI — Readiness and verification (Chapters 22–24). Recurring errors in eight families, each measured against a text; the gap assessment of the E&L and closure programme in fourteen areas; four case studies on Arvena Pharma — the stopper change of a lyophilisate, the prefilled syringe of an antibody, the single-use systems of the drug substance, the infusion bag — and 36 questions an inspector or assessor may ask.

Plus 6 appendices. The register of 85 sources; the status matrix by jurisdiction; the 99 decisions, each with who decides, on what basis and where it is recorded; the sheets of the 16 tools; the glossary; and Appendix F, with the AET formulas of the draft ICH Q3E transcribed character for character, a source line under each block, and the calculation examples E1–E13 that the toolkit recalculates.

Read the extract before you buy

The free extract is made of real pages from the book, not a sales summary: 20 pages in the English edition, 20 in the Italian. It contains the regulatory status box with the labels and the way USP values are read, the complete table of contents with the real page numbers, from Chapter 14 the threshold chain — the SCT, the AET formulas, the uncertainty factor and the calculation examples —, from Chapter 6 the system categories, test families and system × test matrix of <382>, Case 1 of Chapter 24 in full — the stopper change of a lyophilisate, from the supplier's change notification to the dossier — and the overview of the 16 tools.

Specifications

FormatPDF A4 — 265 pages (ENG edition) · 267 pages (ITA edition)
EditionSecond edition · September 2026 · version 2.0 · first unified edition. Rewritten from scratch; replaces the two first-edition guides on USP 382 (December 2025) and E&L (January 2026).
Structure24 chapters in six parts + 6 appendices (A-F)
ScopeParenterals: container closure system (USP <381>/<382>, <1381>/<1382>, Ph. Eur. 3.2.9, plastics <661.1>/<661.2>, glass <660> as an interface), E&L (draft ICH Q3E, USP <1663>/<1664>, PQRI, ISO 10993-18/-17, ICH M7, Q3D and Q3C for toxicology), process single-use (USP <665>/<1665>, BPOG, Annex 1 §§8.131-8.139).
MarketsUSA (FDA, USP, 21 CFR), EU (Ph. Eur., EMA, Annex 1) and ICH; essential status for PIC/S, WHO, Canada, Switzerland, the United Kingdom and Japan.
Out of scopeFull container closure integrity qualification (methods, limits and validation: covered here only as an interface), the device part under the ISO 10993 series, non-parenteral dosage forms (for comparison only), variation procedures. Component preparation and stoppering, the CCS, cleaning HBELs, CTD structure and nitrosamines stay in the sister guides.
Toolkit16 editable tools per edition: 10 Excel workbooks and 6 Word documents
LanguagesThe guide and the toolkit exist as an English edition and as an Italian edition, with identical structure: choose the ENG - English or the ITA - Italiano variant.
SourcesRegister of 85 sources, with issuing body, title, code, version and access date
Decisions99 decisions tracked: what is decided, who decides, on what basis, where it is recorded
Regulatory cut-off26 September 2026
Free preview20 pages (ENG edition) · 20 pages (ITA edition)
Price€129.00
Delivery and licenceImmediate download after purchase. Individual use, internal to the purchasing company. Digital product: nothing is shipped.

Who it is for. QA and QPs, packaging engineering, E&L analytics, toxicologists, CMC and Regulatory Affairs, MSAT and single-use, supplier quality, consultants. It is written for whoever qualifies a container closure system, signs an extractables or leachables protocol, calculates an AET, assesses a component change or prepares Module 3 and needs to know which document every value comes from, in which version and in which market it applies.

Who it is not for. It is not a guide to container closure integrity qualification, to medical devices or to oral and inhaled dosage forms. It does not replace the official USP–NF text, which remains the reference for procedures and criteria, and it is neither legal nor toxicological advice: derived PDEs belong to a qualified toxicologist.

Frequently asked questions

Is ICH Q3E mandatory?

No. As of 26/09/2026 it is a Step 2 draft of 01/08/2025, with Step 4 planned for June 2027. The guide uses it as the expected direction, marks each of its values as subject to change, and asks you to declare for each product the threshold framework adopted — draft Q3E, PQRI or FDA draft — as a recorded decision (Chapters 11 and 14, tool 03).

Does the guide give the numerical criteria of USP <382>?

No. The official USP–NF texts were neither consulted nor reproduced: status, dates and structure come from USP notices and Revision Bulletins, the few values from public summaries marked as such. Procedures and criteria are read in the current chapter; tool 04 has a Criteria sheet where the company records them with the version and date of the text consulted (Chapters 6, 7 and 8).

Is fragmentation still a <382> test?

No. The Revision Bulletin of 25/04/2025 removed it from <382> before the official date of 01/12/2025; in the USA it stays in USP <381>, in the EU it is performed under Ph. Eur. 3.2.9. The book explains what to review in plans written before that date (Chapters 5 and 6).

Is USP <382> needed for a product sold in the EU only?

In the EU the mandatory pharmacopoeial references are those of the Ph. Eur.; USP chapters are not mandatory and are the reference for the US market. Adopting <382> as an internal reference remains possible, as a recorded choice (Chapters 3 and 6, tool 01).

What changes with the August 2026 FDA draft?

It is a draft, open for comment until 13/10/2026; when final it will supersede the May 1999 guidance. It gives an SCT of 1.5 µg/day for most chronic-use drugs and no numerical QT, refers to <381> for penetrability, fragmentation and self-sealing, and does not cite <382> (Chapters 19 and 21).

I have one of the two first-edition guides: what do I receive?

This edition replaces both and is sent to you at no extra cost. It has been rewritten from scratch: the front matter lists what to review first in protocols and SOPs written on the first editions.

Which edition do I receive?

The one of the variant you choose: ENG - English or ITA - Italiano. Each edition contains the complete guide and the 16 tools in the same language.

Does it cover container closure integrity (CCI)?

Only as an interface: the integrity test of <382>, USP <1207> and the integrity paragraphs of Annex 1. Full integrity qualification — methods, limits and validation — is outside the scope of this guide (Chapter 9).

Do you need to qualify a container closure system, defend an AET or manage a component change?
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GuideGxP guides do not replace official regulations and compendia (USP–NF, European Pharmacopoeia, FDA, EMA, ICH, national authorities): they are operational support tools, and users remain responsible for applying the texts in force correctly in their own company context. Procedures and acceptance criteria of USP <381> and <382> are read in the current official text, which this guide does not reproduce; values from the draft ICH Q3E are subject to change in the final version. This guide is neither legal nor toxicological advice. The regulatory status described is the one verified as of 26/09/2026 and is to be re-verified after 13/10/2026, on publication of Step 4 of ICH Q3E and at every new USP Revision Bulletin. Arvena Pharma is a fictitious company: data, dates and codes in the examples are invented. Digital product: nothing is shipped.

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DECLARED REGULATORY BASIS

Built on the most up-to-date official sources.

Every guide is built from the official sources current at the editorial verification date stated in the document. The editions, revisions and cut-off dates used are declared and checked again for every new release; requirements are kept distinct from GuideGxP operational interpretation.

Main references for this guide USP <1663>/<1664> · PQRI recommendations · FDA/EMA guidance
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