Where the story stands today is more nuanced than the tape action around the January disappointment made it look. The FDA did not throw out the Anaphylm package because the drug failed on efficacy, because the core clinical bridge broke, or because major chemistry, manufacturing, and controls issues surfaced. The company’s February disclosure said the Complete Response Letter was focused on administration, labeling guidance, human factors deficiencies, and one supportive pharmacokinetic study tied to the packaging and labeling changes. In plain English, this was bad news, but it was not the same thing as a fundamental collapse of the program.
The market then needed a second question answered: would management actually get the FDA onto a defined remediation path, or would this turn into a vague, open-ended delay? The March 30 Type A meeting update is important because it is the first sign that the post-CRL process is becoming more concrete. AQST said the FDA gave clarifying feedback on both the PK and human factors study designs, acknowledged the changes to the pouch opening mechanism, and aligned on the concept of using labeling language to manage potential chewing of the film rather than demanding additional clinical data. That does not mean approval is in the bag. It does mean the company has moved from uncertainty to a more actionable playbook.