Glossary

Exhibit Batch

An exhibit batch is the batch made to support a generic drug application.

By Sunil Kumar, Managing Director - Sales · Updated 23 Oct 2026

On this page
  1. 01Definition
  2. 02Quick facts
  3. 03How big must an exhibit batch be?
  4. 04How many exhibit batches does an ANDA need?
  5. 05How much API does an exhibit batch consume?
  6. 06Exhibit batch vs pilot and validation batch
  7. 07What to lock before making the exhibit batch
  8. 08How Aarise Pharmaceuticals handles it
  9. 09Example
  10. 10Related terms
  11. 11Frequently asked

What is an exhibit batch?

An exhibit batch is the drug product batch made, tested and documented to support an ANDA, the abbreviated new drug application filed with FDA for a generic drug.

Key takeaways

  • For tablets and capsules, FDA recommends two of three stability batches at pilot scale (at least 10% of the commercial batch or 100,000 units, whichever is greater); the third can be as small as 25% of that size.
  • The commercial master batch record you submit cannot be for runs larger than 10 times the exhibit batch.
  • An exhibit batch at 10% scale does not replace process validation. FDA expects commercial-scale batches for that.
  • Fix the API source, lot and quantity before you make the batch. A second API source later means extra data.

Quick facts

Term status
Industry shorthand; FDA does not define it
Where it appears
ANDA sections 3.2.P.3.3 and 3.2.P.3.4
Tablet and capsule size
At least 10% of the commercial batch or 100,000 units, whichever is greater
Commercial batch ceiling
No more than 10 times the exhibit batch
Stability data
At least 6 months (180 days) of accelerated and long-term data on each batch

The term gets used for three different things: the first scale-up batch, a process validation batch, and the batch that goes into the filing. Only the last is an exhibit batch. The mix-up costs money, because the batch is sized, sourced and documented before anyone knows whether the filing will hold.

"Exhibit batch" is industry shorthand, not a term FDA defines. In FDA's ANDA content and format guidance (https://www.fda.gov/media/125312/download), it appears in section 3.2.P.3.4, where the applicant must show what was actually made. It also appears in section 3.2.P.3.3, where the commercial batch record is tied to the exhibit batch by a ceiling of 10 times.

That ceiling and a 100,000-unit floor set the batch size. They also set how much active pharmaceutical ingredient (API) you must buy, from which source, and with which certificate of analysis (COA). Those decisions come first, and this page works through them.

How big must an exhibit batch be?

For tablets and capsules, FDA's stability Q&A (May 2014) says two of the three batches should be "at least 10 percent of the proposed production batch or 100,000 finished dosage units, whichever is greater". It recommends a minimum of 100,000 units in all proposed presentations. FDA does not define "exhibit batch"; this stability batch size is read across to the exhibit batch.

Other forms differ. Powders, solutions and suspensions use 10% of the maximum commercial batch. Parenterals use at least 10% of the maximum commercial batch, 50 L (fill volume above 2.0 mL) or 30 L (fill volume up to 2.0 mL), whichever is larger. Transdermal patches use 10% or 25,000 units per strength, whichever is greater. Creams, lotions and gels use 100 kg or 10% of the production batch, whichever is larger.

How many exhibit batches does an ANDA need?

As of October 2026, FDA recommends three stability batches: three pilot-scale, or two pilot-scale plus one small-scale (stability Q&A, May 2014; ANDA content and format, September 2018). These are read as the exhibit batches. The guidance asks for at least 6 months (180 days) of accelerated and long-term data on each. For tablets and capsules, the third batch can be smaller than 10% but not under 25% of the pilot-scale batch.

Three stability batches that serve as exhibit batchesDiagram showing two options for the three stability batches: three pilot-scale batches, or two pilot-scale plus one smaller batch of at least 25% of pilot size.

The same guidance requires commercial master batch records "no more than 10 times the exhibit batch(es)", plus a table comparing equipment, process parameters and in-process controls between exhibit and commercial batches.

How much API does an exhibit batch consume?

API needed follows a simple model: units × strength in mg ÷ 1,000,000 = kg at 100% of label claim. Assay correction, overage and analytical material come on top, so treat these as minimums.

The table is arithmetic on the FDA figures above. The 100,000-unit floor keeps small commercial batches from shrinking the exhibit batch.

Commercial batch (tablets)
500,000
Minimum exhibit batch: greater of 10% or 100,000
100,000
Minimum set (2 × exhibit + 25%)
225,000
Largest commercial batch it supports (10×)
1,000,000
Commercial batch (tablets)
2,000,000
Minimum exhibit batch: greater of 10% or 100,000
200,000
Minimum set (2 × exhibit + 25%)
450,000
Largest commercial batch it supports (10×)
2,000,000
Commercial batch (tablets)
5,000,000
Minimum exhibit batch: greater of 10% or 100,000
500,000
Minimum set (2 × exhibit + 25%)
1,125,000
Largest commercial batch it supports (10×)
5,000,000

Exhibit batch vs pilot and validation batch

FDA's process validation guidance (January 2011) says a manufacturer must complete process performance qualification (PPQ, the commercial-scale validation runs) before commercial distribution. Distribution should rest on commercial-scale batch data, with pilot data as added assurance.

Route any batch-size change through change control (the documented approval process for changing a batch size or process). For handover steps, see pharmaceutical technology transfer.

Aspect
Purpose
Exhibit batch
Supports the filing
Pilot batch
Builds process knowledge
Validation batch
Proves the process at commercial scale
Aspect
Basis for commercial distribution
Exhibit batch
At 10% scale, cannot replace validation; at full commercial size it may serve both purposes
Pilot batch
Added assurance only
Validation batch
Commercial-scale PPQ completed before distribution

What to lock before making the exhibit batch

Lock the API source, the lot, the quantity and the equipment comparison before the batch is made, because the filing records them. FDA's ANDA guidance asks for batch analysis, including COAs from the drug substance manufacturer, for the lots used to make the exhibit batch.

A second source needs a physico-chemical and impurity comparison and stability data on three batches of the first source. It also needs a pilot-scale batch of the second source with comparative dissolution data (FDA stability Q&A, May 2014). Confirm with your regulatory team that the API source can be referenced in your ANDA before committing the exhibit batch.

Check
API manufacturer and site
Pass
Named in writing and used in the batch formula
Fail
"To be confirmed"
Check
Lot COA
Pass
The COA lot number matches the batch record
Fail
No COA, or a different lot
Check
Quantity
Pass
API on hand ≥ set units × strength (mg) ÷ 1,000,000 ÷ assay (as a fraction), plus overage and testing margin
Fail
API for one batch only
Check
Second API source
Pass
Decided before filing
Fail
Added after the exhibit batches
Check
Equipment comparison
Pass
Commercial equipment train named
Fail
Commercial equipment unknown

How Aarise Pharmaceuticals handles it

Aarise Pharmaceuticals supplies evaluation quantities of API to qualified business buyers, subject to the product, availability and applicable regulatory requirements. Quantity, pricing and documentation are confirmed product by product. Documentation may include a COA, specifications and a safety data sheet (SDS/MSDS) where applicable. After successful evaluation and approval, it can support commercial and bulk requirements.

For a quote it asks for the product name or CAS number (Chemical Abstracts Service registry number), quantity, destination, grade or purity, documents, payment terms and Incoterms (shipping terms). The steroid API RFQ checklist shows how to write that request. Supplier choice for pilot-scale API is covered in who can run your steroid API pilot batch. Its steroid raw material catalog lists the categories it supplies. Aarise also provides oral-dose contract development and manufacturing, from product development through commercial manufacturing.

Example

For a 500,000-tablet commercial batch of 10 mg tablets, the exhibit set is 100,000 + 100,000 + 25,000 tablets, which needs 225,000 × 10 mg = 2.25 kg of API at 100% of label claim. The same set at 500 mg needs 112.5 kg. Assay correction, overage and analytical material come on top.

Frequently asked

Not at 10% scale. FDA's 2011 guidance bases the decision to distribute on commercial-scale batches, with pilot data as extra assurance. An exhibit batch made at full commercial size may serve both purposes, and any change in batch size should go through change control.
No, 100,000 units is the tablet and capsule figure; powders, solutions and suspensions use 10% of the maximum commercial batch, and parenterals, patches, creams and gels have their own rules, set out in the first section.
You can, but it adds work. A second API source needs a physico-chemical and impurity comparison and stability data on three batches of the first source. It also needs a pilot-scale batch of the second source with comparative dissolution data. Deciding the second source before filing avoids adding it after the exhibit batches.
The ANDA's batch analysis section includes COAs from the drug substance manufacturer for the lots used to make the exhibit batch. The COA lot number must match your batch record, so keep each lot's COA with the batch file.

Sources

  1. 1.FDA, ANDA Submissions: Content and Format, Guidance for Industry (September 2018), FDA, 2018-09
  2. 2.FDA, ANDAs: Stability Testing of Drug Substances and Products, Questions and Answers (May 2014), FDA, 2014-05
  3. 3.FDA, Process Validation: General Principles and Practices (January 2011), FDA, 2011-01

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