Therapeutic Equivalence Codes: How the FDA Determines If Generics Can Be Swapped

Therapeutic Equivalence Codes: How the FDA Determines If Generics Can Be Swapped

Jan, 3 2026

When your pharmacist hands you a pill bottle with a different name than what your doctor wrote, you might wonder: is this really the same thing? The answer lies in a quiet but powerful system the FDA uses to rate generic drugs - therapeutic equivalence codes. These two-letter codes - like AB, BC, or BX - don’t just sit on a shelf in a government database. They decide whether you can safely swap a brand-name drug for a cheaper generic without asking your doctor again.

What Therapeutic Equivalence Really Means

Therapeutic equivalence isn’t just about having the same active ingredient. It means two drugs - one brand, one generic - will do the same thing in your body, at the same rate, with the same safety profile. The FDA doesn’t guess. They test. And they assign a code based on hard evidence.

The system lives in the Orange Book, officially called Approved Drug Products with Therapeutic Equivalence Evaluations. It’s been around since 1980, but it’s still the go-to tool for pharmacists, doctors, and state pharmacy boards. If a generic has an ‘A’ code, it’s legally interchangeable in 49 states. No extra approval needed. That’s why 90% of prescriptions filled in the U.S. are generics - and why they save the system about $370 billion every year.

The ‘A’ Code: Safe to Swap

If you see an ‘A’ at the start of the code, you’re good. The FDA has confirmed the generic matches the brand in every way that matters: same active ingredient, same strength, same form (pill, liquid, injection), and - most importantly - it gets into your bloodstream at the same rate and amount. That’s bioequivalence. Proven through studies. Not theory. Real data.

But ‘A’ isn’t just ‘A’. There are sub-codes like AB1, AB2, AB3, and AB4. Why? Because sometimes, the brand-name drug has more than one version on the market. Let’s say two different brands make the same 20mg tablet. The generic that matches Brand A gets AB1. The one that matches Brand B gets AB2. If your doctor prescribes Brand A, you can only get AB1 - not AB2 - unless your doctor says otherwise. It’s a detail most patients don’t know, but pharmacists check it every day.

The ‘B’ Code: Not Automatically Substitutable

A ‘B’ code is where things get tricky. It means the FDA hasn’t confirmed therapeutic equivalence. That doesn’t mean the generic doesn’t work. It just means they don’t have enough proof yet - or there’s something unusual about the drug.

Some ‘B’ codes are specific:

  • BC = Extended-release forms with potential bioequivalence issues
  • BT = Topical creams or ointments where absorption is hard to measure
  • BN = Inhalers or nebulizer drugs
  • BP = Products with known bioequivalence problems
  • BX = Not enough data to judge

Here’s the problem: some ‘B’-rated drugs are perfectly safe and effective. But because they’re complex - like a patch that releases medicine slowly over days, or an inhaler that needs precise particle size - the FDA’s standard tests don’t always capture how they work in the body. So they get a ‘B’ by default. That leads to confusion. A 2022 AMA survey found 42% of doctors didn’t understand what ‘B’ really meant. Some refused to let pharmacists substitute. Others didn’t realize the generic might still be fine.

FDA Orange Book glowing with animated therapeutic equivalence codes AB, BC, and BX.

Why This System Matters in Real Life

For pharmacists, the Orange Book is a daily tool. A 2022 survey of 1,200 independent pharmacists showed 87% use it weekly. Each time they fill a prescription, they check the code. If it’s AB, they swap. If it’s B, they call the doctor or hold the brand. That extra step takes about 2.7 minutes per prescription. Multiply that by millions of fills, and you get $1.2 billion in annual savings - not from wasted pills, but from avoiding unnecessary brand-name costs.

But it’s not perfect. A 2023 study found that 28% of pharmacists had refused to substitute a ‘B’-rated product that was actually clinically appropriate. Why? Because the code scared them. Or the doctor had written ‘dispense as written.’ Or the patient had a bad experience once with a generic and never trusted them again.

How It Compares to Other Countries

The U.S. system is unique. The European Medicines Agency (EMA) doesn’t use codes at all. Instead, they publish long scientific reviews for each generic. That’s thorough. But it’s not fast. In the U.S., a pharmacist can make a substitution decision in seconds. In Europe, the decision often goes back to the doctor - slowing things down and increasing costs.

The FDA’s system works because it’s simple. ‘A’ means yes. ‘B’ means ask. It’s built into state laws. It’s taught in pharmacy school. It’s searchable online. And it’s updated monthly. The FDA’s Orange Book website had 1.7 million unique visitors in just one quarter of 2023. That’s not patients. That’s professionals. Doctors. Pharmacists. Regulators. All checking the same source.

Patient receiving safe generic pill on one side, pharmacist hesitant with BX-coded inhaler on the other.

What’s Changing Now

The FDA knows the system struggles with complex drugs. Between 2018 and 2022, applications for ‘B’-rated complex generics jumped 22%. That’s because more drugs are being made as patches, inhalers, injectables, and slow-release tablets. The old bioequivalence tests - measuring blood levels after a single dose - don’t always apply.

In 2022, the FDA released draft guidance proposing new ways to evaluate these products. They’re looking at real-world data, better lab tests, and even patient outcomes. Their goal? Cut ‘B’ ratings for complex generics by 30% by 2027. That means more affordable options, without risking safety.

They’re also expanding Product-Specific Guidances - detailed rules for how to test each drug. There are now over 1,850 of them. For example, there’s a whole guide just for testing generic versions of the asthma drug albuterol. That kind of specificity is what’s making the system smarter.

What You Should Do

If you’re taking a generic:

  • Check the label. Does it say the same active ingredient as your brand?
  • Ask your pharmacist: ‘Is this an A-rated generic?’
  • If it’s a ‘B’, ask if it’s safe for you. Don’t assume it’s bad - just ask for the reason.
  • If you’ve had a bad reaction to a generic before, tell your doctor. It might be the drug, not the code.

Most generics are safe. Most are interchangeable. But the system isn’t magic. It’s science - and science evolves. The FDA isn’t trying to stop you from saving money. They’re trying to make sure you save it safely.

What’s Next for Generic Drugs

The future of generics isn’t just about more of them. It’s about better ones. As more complex drugs go generic - biologics, inhalers, injectables - the FDA will need better tools. That’s where real-world evidence comes in. Data from patients using the drug over months or years. That’s the next step. And it’s already starting.

For now, the Orange Book remains the backbone of generic substitution in the U.S. It’s not perfect. But it’s the most reliable system we have. And for millions of people, it means paying $10 instead of $100 for the same medicine. That’s not just policy. That’s real life.