top of page

USFDA Draft Guidance: Development of Non-Opioid Analgesics for Chronic Pain

The U.S. Food and Drug Administration (FDA) has released a new draft guidance "Development of Non-Opioid Analgesics for Chronic Pain" on September 11, 2025, focused on the development of non-opioid analgesics for chronic pain management. This draft guidance builds upon the mandates of the SUPPORT Act and FDA’s commitment to combating the opioid crisis by supporting the development of safer, effective alternatives.


ree

1. Introduction

The guidance outlines FDA’s vision to:

  • Foster innovation in non-opioid pain therapies.

  • Reduce reliance on opioids, thereby minimizing risks of misuse, addiction, and overdose.

  • Provide clear regulatory pathways for phase 3 clinical trials of non-opioid analgesics targeting chronic pain.

2. Background

Chronic pain, typically defined as pain lasting longer than three months, affects millions worldwide and remains one of the leading causes of disability. Despite available treatments like NSAIDs, gabapentinoids, SNRIs, and topical anesthetics, many patients remain undertreated, leading to inappropriate reliance on opioids.

FDA emphasizes the urgent public health need to expand treatment options through mechanism-driven drug development, focusing on novel therapeutic targets, biomarkers, and patient phenotyping.

3. Development Programs for Non-Opioid Analgesics

A. Establishing Indications

  • Condition-Specific Indication: Focused on a single chronic pain condition (e.g., diabetic neuropathy).

  • Group-Specific Indication: Targeting a group of related conditions with shared pathophysiology.

  • General Chronic Pain Indication: Broadest claim, covering all chronic pain conditions, requiring strong mechanistic evidence and robust trial data.

B. Trial Design Considerations

  • Randomized, double-blind superiority trials are the gold standard.

  • 12-week treatment periods are typical, but shorter durations may be acceptable in severe pain conditions.

  • Enriched Enrollment Randomized Withdrawal (EERW) trials may be considered, though they have limitations in generalizability.

  • Trials should carefully manage rescue medication use and collect robust data on discontinuations.

C. Effectiveness Measures

  • Primary endpoints should be patient-reported pain intensity scores, typically via an 11-point numerical rating scale.

  • Secondary endpoints include:

    • ≥30% or ≥50% reduction in pain.

    • Changes in functional status, sleep quality, or daily living activities.

    • Rescue medication usage.

D. Evaluating Opioid-Sparing Benefits

The guidance introduces frameworks for demonstrating how non-opioid therapies can:

  • Avoid opioid initiation.

  • Eliminate ongoing opioid use.

  • Reduce opioid dosage while maintaining pain control.

These outcomes, if supported by robust trial data, may be reflected in product labeling.

E. Safety & Statistical Considerations

  • Sponsors must evaluate abuse potential, especially for CNS-active drugs.

  • Larger safety databases may be required for new molecular entities.

  • Analyses should use intent-to-treat principles, adjust for baseline covariates, and handle missing data with robust sensitivity analyses.

F. Expedited Programs

Non-opioid analgesics designed to avoid or reduce opioid use may qualify for expedited programs such as Fast Track, Breakthrough Therapy, Priority Review, or Accelerated Approval—though FDA notes challenges in identifying surrogate endpoints for pain.

4. Innovative Approaches

The FDA encourages sponsors to explore:

  • Adaptive and Bayesian trial designs.

  • Decentralized trials and digital health technologies.

  • Biomarkers to predict treatment response.

  • Real-world evidence (RWE) to complement traditional clinical data.


This draft guidance represents a critical step in advancing the development of safe, effective non-opioid analgesics for chronic pain. By clarifying expectations around trial design, endpoints, and regulatory flexibility, FDA is signaling strong support for industry innovation in tackling one of the most pressing public health challenges—the opioid crisis.

Stakeholders are encouraged to submit comments within 60 days of publication in the Federal Register, helping refine this framework for future drug development. Explore more and access the draft guidance:

I Sometimes Send Newsletters

Thanks for submitting!

  • LinkedIn
  • Facebook
  • Twitter
  • Instagram

DISCLAIMER

The views expressed in this publication do not necessarily reflect the views of any guidance of government, health authority, it's purely my understanding. This Blog/Web Site is made available by a regulatory professional, is for educational purposes only as well as to give you general information and a general understanding of the pharmaceutical regulations, and not to provide specific regulatory advice. By using this blog site you understand that there is no client relationship between you and the Blog/Web Site publisher. The Blog/Web Site should not be used as a substitute for competent pharma regulatory advice and you should discuss from an authenticated regulatory professional in your state.  We have made every reasonable effort to present accurate information on our website; however, we are not responsible for any of the results you experience while visiting our website and request to use official websites.

bottom of page