Draft Guidance Document of Biological Products
Draft Guidance Document of Biological Products
Draft Guidance Document of Biological Products
This draft guideline is uploaded on the official website of DRAP dated on 9th May, 2023, for seeking
comments and suggestions from stakeholders on the draft document. Stakeholders can submit their comments
and suggestions within 15 days of uploading this document using prescribed format, (further information on
comments submission can access on this link. Comments and suggestions can be forwarded via email to a
ahmad.ansari@dra.gov.pk copying at ahsan.hafiz@dra.gov.pk , or can be posted at mailing address, Director,
Biological Drugs, Drug Regulatory Authority of Pakistan, 4th floor TF Complex, 7th Mauve Area, G-9/4,
Islamabad.
1. HISTORY
This is the first edition of these guidelines after the introduction of Form-5F (CTD).
3. SCOPE
The scope of this Guideline is limited to application on Form-5F (CTD) for registration of biological
drug products for human use.
4. BACKGROUND
Section 7 (c) (ii, viii, ix) of DRAP Act 2012, mandated the registration of therapeutic goods,
implementation of internationally recognized GLP, cGMP etc and systematic implementation of
internationally recognized standards of World Health Organization, International Conference on
Harmonization (ICH), and Food and Drug Administration guidelines etc.
These guidelines conform and shall be read in consistence to DRAP Act, 2012 and Drugs Act 1976 and
Rules framed there under.
1
The Guidance document is prepared by Drug Regulatory Authority of Pakistan for better illustration of data
requirements of the Form 5-F (CTD). However, content of guidance document only reflects the current thinking
perspective of the Authority on the subject and does not create or confer any rights for or on any person and does not
operate to bind the Authority or the public.
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Contents
1. INTRODUCTION .................................................................................................................. 5
1.5 Detailed Information of Drug, Dosage From & Labeling Claims ............................................. 8
REFERENCES ............................................................................................................................ 41
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GLOSSARY
ACRONYMS
API Active Pharmaceutical Ingredient
BAN British Approved Name
BCS Biopharmaceutics Classification System
BP British Pharmacopoeia
BSE Bovine Spongiform Encephalopathy
CAS Chemical Abstract Service
CEP Certificate of Suitability
CoA Certificate of Analysis
CPP Critical Process Parameters
CQA Critical Quality Attribute
CTD Common Technical Document
DML Drug Manufacturing License
DRAP Drug Regulatory Authority of Pakistan
EPAR European Public Assessment Report
FDA Food & Drug Administration of United States
GCP Good Clinical Practices
GLP Good laboratory Practices
GMP Good Manufacturing Practices
ICH International Conference on Harmonization
INN International nonproprietary name
IR Infrared
JP Japanese Pharmacopoeia
LR&A Licensing, Registering & Advertising
MS Mass Spectrometry
NMR Nuclear Magnetic Resonance
OSD Oral Solid Dosage form
PAR Public Assessment Report
Ph.Eur European Pharmacopoeia
Ph.Int International Pharmacopoeia
PMDA Pharmaceuticals and Medical Devices Agency of Japan
RRA Reference Regulatory Authority
SAE Serious Adverse Events
TSE Transmissible Spongiform Encephalopathies
USAN United States Adopted Name
USP United States Pharmacopoeia
UV Ultraviolet-Visible
WHO World Health Organization
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Guidance Document for Submission of Application for Registration of Biological Products on Form 5-F (CTD) (Edition 1)
1. INTRODUCTION
This guidance is developed to assist manufacturers and importers in developing their applications for
registration of human biological drug products. Drug Regulatory Authority of Pakistan (DRAP) has
adapted CTD format for registration of all such drugs vide SRO-713(l)/2018 dated 8th June 2018. The
detailed guidance regarding the data requirement for CTD format has been provided in ICH M-4
guidelines. Since the DRAP is introducing the CTD in a progressive manner, therefore, initial guidance
to applicants would be helpful for harmonization and appropriate data submission to achieve consistency
and uniformity of application.
This guidance document is developed on the basis of best available knowledge and scientific data /
evidence.
2. LEGAL PROVISIONS
Rule 26 of the Drugs (Licensing, Registering and Advertising) Rules, 1976, as amended vide S.R.O
713(I)/2018 dated 8th June, 2018, under 26(1) section provides the standard formats and requirements
for submission of registration application dossier on Form 5F (Common Technical Documents) for
registration of Human drugs.
1. Module 1 (Administrative part) shall be prepared as provided in Form-5F without deleting any
component. Applicant shall mention “Not applicable” with proper justification for those parts
which are not related to any particular application.
2. Quality Overall Summary (QOS) in module 2 shall be prepared using WHO QOS-PD template
or template provided hereinafter without deleting any component / table of the template.
Applicant shall mention “Not applicable” with proper justification for those parts which are not
related to any particular application.
3. The Quality overall Summary (QOS) prepared as per WHO QOS-PD template or template
provided hereinafter needs to be submitted as “MS Word document” in CD / USB as well.
4. Application shall be submitted along with complete data as per the module 3.
5. Each section / sub section of CTD application shall be properly segregated using page separators.
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This point requires the status of applicant for the instant product. The applicant must select one of the
above-mentioned options.
• A manufacturer will provide all the requisite information as per Registration procedure of
Pakistan, subsequently mentioned in 1.3.4-1.3.5.
• An importer shall provide Certificate of Pharmaceutical Product (CoPP) / Free Sale
certificate and GMP certificate of the Manufacturer issued by relevant regulatory authority
in the country of origin and name of exporting country.
• “c” is for Contract Manufacturing as per Rule 20-A of Drugs (Licensing, Registering and
Advertising) Rules, 1976.
1.3.4. Valid Drug Manufacturing License (DML) of manufacturer / Applicant or Drug Sale
License, whichever is applicable.
a) For drug to be locally manufactured, copy of valid Drug Manufacturing License (DML) issued
by Licensing Division, DRAP.
b) For drugs to be imported, copy of valid Drug Sale License (DSL) issued by relevant licensing
authority. The address of applicant mentioned on Drug Sale License (DSL) shall match with
the information provided in sub-section 4.3.1 and sole agency agreement / letter of authorization
between applicant and marketing authorization holder (abroad).
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1.4.3. Contract Manufacturing as per Rule 20-A of Drugs (Licensing, Registering and
Advertising) Rules, 1976.
Domestic Manufacturing
Export Purpose Only
a) Provide notarized copy of Contract manufacturing agreement.
b) Provide documents confirming number of approved sections of the applicant (DML holder).
c) Provide details of already registered drug products of contract giver on contract manufacturing.
1.5.1. Generic name with chemical name & synonyms of the applied drug.
The following necessary information shall be provided in this sub-section:
a) (Recommended) International Non-proprietary name (INN):
b) Compendia name, if relevant:
c) Chemical name(s):
d) Chemical Abstracts Service (CAS) registry number: (where applicable)
The submission of following is optional
a) Company or laboratory code
b) Other non-proprietary name(s) (e.g. national name, USAN, BAN):
1.5.2. Strength / concentration of drug of Active Pharmaceutical ingredient (API) per unit
a) Strength of Active ingredient shall be stated clearly.
For example, each tablet contains, each ml contains in case of Injectable. However, description
like each ampoule / vial contains shall be avoided.
1.5.3 The proposed proprietary name / brand name under which the drug is intended to be sold
with trade mark certification / clearance.
a) The proposed brand name shall be justified keeping in view the LASA (Look alike and Sound
alike) with specific emphasis on prefix, mid-name and suffix.
b) An undertaking in this regard that the applicant shall be responsible to change the name in case
the name resembles with already approved / registered names.
1.5.4 Proposed Pack size and Proposed unit price of drug e.g., per tablet / capsule. Maximum Retail
Price (MRP) per pack shall also be mentioned.
a) The applicant needs to submit the proposed pack size as well as demanded price for each pack
size.
1.5.5 Pharmacotherapeutic Group of Active Pharmaceutical Ingredient (API)
a) Indicate Pharmacological class of the API (drug substance) with proper reference.
b) Also, state the WHO ATC code for each distinct therapeutic indication.
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• Int. Ph.
• JP
• Pharmacopoeia of any Reference Regulatory Authority
• Manufacturer’s specifications.
• Specifications as per Innovator’s product
• Any other (specify exact reference)
• Any other pharmacopoeia as mentioned in Drug specification rules. (Specify the exact
reference).
1.5.8 For Biosimilar Drug Product, reference of other similar approved medicines with
information pertaining to Manufacturer name, brand name, strength, composition, registration
number & dosage form, Pack size and Price.
If the applicant has selected Biosimilar Drug Product (GDP) in sub-section 1.4.1, the reference of already
registered product including the following details needs to be submitted.
• Brand name
• Manufacturer/Registration holder
• Registration number
If the applicant has selected New Drug Product (NDP) in sub-section 1.4.1 “Not applicable since this is
a new drug” needs to be mentioned against this point.
1.5.9 The registration status of applied drug in same molecule and salt, strength, dosage form,
container closure system, indications and route of administration etc. in other countries. The status
in reference regulatory authorities is mandatory to mention.
Evidence of approval / registration / marketing status of the applied formulation in the same composition,
salt form and dosage form in one of the reference regulatory authority specified by Registration Board.
The name of the reference authority shall be mentioned as adopted by Board currently.
Mention the name of innovator product in case of non-pharmacopoeial product.
1.5.11 Proposed label [outer (secondary) & inner (primary)] & colour scheme in accordance with
Drug (Labelling & Packing) Rules, 1986 along with specimens
The submission against this point is optional.
1.5.13 Training evidence of technical staff with respect of manufacturing of applied drug
(mandatory in case of specially designed pharmaceutical product / Novel Dosage Form).
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The submission against this point is optional.
1.5.14 Summary of Product Characteristics (SmPC) including Prescribing Information (PI) along
with Patient information Leaflet (PIL) of the Finished Pharmaceuticals Product (FPP).
The submission against this point is optional.
I / We hereby undertake that the above given information is true and correct to the best of my / our
knowledge and belief.
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1.5.21 Protocols along with the commitment to follow Good Laboratory Practices (GLP) by the
Manufacturer.
The submission against this point is optional.
1.6.2 Appendix
For applications of imported drug product(s), the submission against this point is not required.
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<For testing of Pharmacopeial Drug Substance, the use of primary reference standard is recommended,
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however for non-pharmacopeial Drug Substance, a secondary reference standard provided by the Drug
Substance manufacturer is acceptable>
2.3.P.1 Description and Composition of the Drug Product (name, dosage form)
Information from 3.2.P.1 should be provided.
Composition from 3.2.P.1 should be provided.
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2.3.A Appendices
<Provide a list of manufacturing and testing facilities / equipment available with reference to the applied
drug product>
2.3.A.3 Excipients
<For excipient(s) used for the first time in a drug product or by a new route of administration, full details
of manufacture, characterization, and controls, with cross references to supporting safety (nonclinical
and/or clinical) data shall be provided>
<Provide copy of Batch Manufacturing Record (BMR) for all the batches of drug product for which
stability studies data is provided in Module 3 section 3.2.P.8.3>
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This point is only for Biosimilar Drugs. The applicant shall submit summary of quality comparison of
their product with Innovator product.
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• explore unresolved issues, explain why they should not be considered as barriers to approval, and
describe plans to resolve them.
• explain the basis for important or unusual aspects of the prescribing information.
The Clinical Overview should generally be a relatively short document (about 30 pages). It is not intended
that material presented fully elsewhere be repeated in the Clinical Overview; cross-referencing to more
detailed presentations provided in the Clinical Summary or in Module 5 is encouraged.
Table of Contents:
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2.7.3.3 Comparison and Analyses of Results Across Studies
2.7.3.4 Analysis of Clinical Information Relevant to Dosing Recommendations
2.7.3.5 Persistence of Efficacy and/or Tolerance Effects
2.7.3.6 Appendix
2.7.4 Summary of Clinical Safety
2.7.4.1 Exposure to the Drug
2.7.4.2 Adverse Events
2.7.4.3 Clinical Laboratory Evaluations
2.7.4.4 Vital Signs, Physical Findings, and Other Observations Related to Safety
2.7.4.5 Safety in Special Groups and Situations
2.7.4.6 Post-marketing Data
2.7.4.7 Appendix
2.7.5 Literature References
2.7.6 Synopses of Individual Studies
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5. MODULE 3: (QUALITY / CMC)
*For a drug product containing more than one drug substance, the information requested for part “S”
should be provided in its entirety for each drug substance.
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A flow diagram should be provided that illustrates the manufacturing route from the original
inoculum (e.g. cells contained in one or more vials(s) of the Working Cell Bank up to the last harvesting
operation. The diagram should include all steps (i.e., unit operations) and intermediates. Relevant
information for each stage, such as population doubling levels, cell concentration, volumes, pH, cultivation
times, holding times, and temperature, should be included. Critical steps and critical intermediates for which
specifications are established (as mentioned in 3.2.S.2.4) should be identified.
A description of each process step in the flow diagram should be provided. Information should be
included on, for example, scale; culture media and other additives (details provided in 3.2.S.2.3); major
equipment (details provided in 3.2.A.1); and process controls, including in-process tests and operational
parameters, process steps, equipment and intermediates with acceptance criteria (details provided in
3.2.S.2.4). Information on procedures used to transfer material between steps, equipment, areas, and
buildings, as appropriate, and shipping and storage conditions should be provided. (Details on shipping and
storage provided in 3.2.S.2.4.)
Purification and modification reactions
A flow diagram should be provided that illustrates the purification steps (i.e., unit operations) from
the crude harvest(s) up to the step preceding filling of the drug substance. All steps and intermediates and
relevant information for each stage (e.g., volumes, pH, critical processing time, holding times, temperatures
and elution profiles and selection of fraction, storage of intermediate, if applicable) should be included.
Critical steps for which specifications are established as mentioned in 3.2.S.2.4 should be identified.
A description of each process step (as identified in the flow diagram) should be provided. The
description should include information on, for example, scale, buffers and other reagents (details provided
in 3.2.S.2.3, major equipment (details provided in 3.2.A.1), and materials. For materials such as membranes
and chromatography resins, information for conditions of use and reuse also should be provided. (Equipment
details in 3.2.A.1; validation studies for the reuse and regeneration of columns and membranes in 3.2.S.2.5.)
The description should include process controls (including inprocess tests and operational parameters) with
acceptance criteria for process steps, equipment and intermediates. (Details in 3.2.S.2.4.)
Reprocessing procedures with criteria for reprocessing of any intermediate or the drug substance
should be described. (Details should be given in 3.2.S.2.5.)
Information on procedures used to transfer material between steps, equipment, areas, and buildings,
as appropriate, and shipping and storage conditions should be provided (details on shipping and storage
provided in 3.2.S.2.4.).
Filling, storage and transportation (shipping)
A description of the filling procedure for the drug substance, process controls (including in-process
tests and operational parameters), and acceptance criteria should be provided. (Details in 3.2.S.2.4.) The
container closure system(s) used for storage of the drug substance (details in 3.2.S.6.) and storage and
shipping conditions for the drug substance should be described.
Reference ICH Guidelines: Q5A, Q5B, and Q6B
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Testing used to assess the impact of manufacturing changes on the drug substance(s) and the
corresponding drug product(s) can also include nonclinical and clinical studies. Cross-reference to the
location of these studies in other modules of the submission should be included.
Reference should be made to the drug substance data provided in section 3.2.S.4.4.
Reference ICH Guideline: Q6B
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3.2.S.6 Container Closure System (name, manufacturer)
A description of the container closure system(s) should be provided, including the identity of
materials of construction of each primary packaging component, and their specifications. The specifications
should include description and identification.
For non-functional secondary packaging components (e.g., those that do not provide additional
protection), only a brief description should be provided. For functional secondary packaging components,
additional information should be provided.
The suitability should be discussed with respect to, for example, choice of materials, protection from
moisture and light, compatibility of the materials of construction with the drug substance, including sorption
to container and leaching, and/or safety of materials of construction.
b) Composition
List of all components of the dosage form, and their amount on a per unit basis (including overages*, if
any), the function of the components, and a reference to their quality standards (e.g. compendial
monographs or manufacturer’s specifications). * Overages are not acceptable unless fully justified
If the Drug product is formulated using an active moiety, then the composition for the active ingredient
shall be clearly indicated.
c) Description of accompanying reconstitution diluent(s)
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Provide information including type of diluent, its composition, quantity or volume, specifications (as
applicable) and regulatory status in Pakistan (as applicable) for the diluent which is to be provided along
with the applied drug.
Drug substance
The compatibility of the drug substance with excipients listed in 3.2.P.1 should be discussed.
Additionally, key physicochemical characteristics (e.g., water content, solubility, particle size
distribution, polymorphic or solid-state form) of the drug substance that can influence the performance
of the drug product should be discussed. For combination products, the compatibility of drug substances
with each other should be discussed.
Excipients
The choice of excipients listed in 3.2.P.1, their concentration, their characteristics that can influence the
drug product performance should be discussed relative to their respective functions.
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3.2.P.2.4 Container Closure System
The submission against this point is optional.
3.2.P.2.6 Compatibility
The compatibility of the drug product with reconstitution diluent(s) or dosage devices (e.g., precipitation
of drug substance in solution, sorption on injection vessels, stability) should be addressed to provide
appropriate and supportive information for the labeling.
3.2.P.3 Manufacture
3.2.P.3.1 Manufacturer
The name, address, and responsibility of each manufacturer, including contractors, and each proposed
production site or facility involved in manufacturing and testing shall be provided.
3.2.P.5.1 Specification(s)
A copy of the drug product specification(s) including tests, acceptance criteria and reference to analytical
procedure shall be provided. Specifications shall also include the details of impurities (as applicable).
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The justification of specification(s) for non-pharmacopeial products must be provided. Justification of
specification of non-pharmacopeial product shall be based on batch analysis results.
3.2.P.8 Stability
For the pre-market authorization stability studies for a period of 6 months accelerated and real time in
proposed container closure system is required in accordance with the Zone IVa conditions. Based on the
satisfactory results, a two years shelf life will be granted. For selection of number and size of batches
applicant may follow, any of the following options:
a) ICH/WHO guidelines.
b) At least 2 batches having the following minimum batch size considering the scientific reliability
• OSDs: 5000 Units
• Oral Liquids: 2000
• Injectable: 2000
c) At least 3 batches having scientifically rational batch size, sufficient enough to perform complete
testing till the claimed shelf life.
Storage Conditions: a)
General case
The general case applies if the drug product is not specifically covered by any other storage condition in
the subsequent sections.
Study Storage condition
Accelerated 40°C ± 2°C / 75% RH ± 5% RH
Long term 30°C ± 2°C / 65% RH ± 5% RH
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Product details:
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1. Approval of API/ DML/GMP certificate of API manufacturer issued by concerned regulatory
authority of country of origin.
3. Data of stability batches will be supported by attested respective documents like chromatograms,
Raw data sheets, COA, summary data sheets etc.
4. Record of Digital data logger for temperature and humidity monitoring of stability chambers (real
time and accelerated)
3.2.A Appendices
Excipients
For excipient(s) used for the first time in a drug product or by a new route of administration, full details
of manufacture, characterization, and controls, with cross references to supporting safety (non-clinical
and/or clinical) data shall be provided.
Comparability Protocols
For Biosimilar Drugs, the applicant shall submit complete quality comparison of their product with
Innovator product in light of guidelines approved by Registration Board in its 297th meeting.
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4.2.3.4.2 Short- or medium-term studies (including range-finding studies that cannot
appropriately be included under repeat-dose toxicity or pharmacokinetics)
4.2.3.4.3 Other studies
4.2.3.5 Reproductive and Developmental Toxicity (including range-finding studies and
supportive toxicokinetics evaluations) (If modified study designs are used, the following
sub-headings should be modified accordingly.)
4.2.3.5.1 Fertility and early embryonic development
4.2.3.5.2 Embryo-fetal development
4.2.3.5.3 Prenatal and postnatal development, including maternal function
4.2.3.5.4 Studies in which the offspring (juvenile animals) are dosed and/or further
evaluated.
4.2.3.6 Local Tolerance
4.2.3.7 Other Toxicity Studies (if available)
4.2.3.7.1 Antigenicity
4.2.3.7.2 Immunotoxicity
4.2.3.7.3 Mechanistic studies (if not included elsewhere)
4.2.3.7.4 Dependence
4.2.3.7.5 Metabolites
4.2.3.7.6 Impurities
4.2.3.7.7 Other
Module 5: (Clinical / Efficacy)
The table of contents for Module 5 should include all of the numerical items listed in the CTD
guidance in order to identify all of the important components of the application and should continue
down to at least the level of the clinical study report. Thus, each clinical study report should be identified
in the table of contents. The sections of a clinical study report (E3) could be identified in the Module 5
Table of Contents of the dossier or only in the table of contents of the individual clinical study report.
The study reports should be presented in following order:
Clinical Study Reports
5.3.1 Reports of Biopharmaceutic Studies
5.3.1.1 Bioavailability (BA) Study Reports
5.3.1.2 Comparative BA and Bioequivalence (BE) Study Reports
5.3.1.3 In vitro-In vivo Correlation Study Reports
5.3.1.4 Reports of Bioanalytical and Analytical Methods for Human Studies
5.3.2 Reports of Studies Pertinent to Pharmacokinetics using Human Biomaterials
5.3.2.1 Plasma Protein Binding Study Reports
5.3.2.2 Reports of Hepatic Metabolism and Drug Interaction Studies
5.3.2.3 Reports of Studies Using Other Human Biomaterials
5.3.3 Reports of Human Pharmacokinetic (PK) Studies
5.3.3.1 Healthy Subject PK and Initial Tolerability Study Reports
5.3.3.2 Patient PK and Initial Tolerability Study Reports
5.3.3.3 Intrinsic Factor PK Study Reports
5.3.3.4 Extrinsic Factor PK Study Reports
5.3.3.5 Population PK Study Reports
5.3.4 Reports of Human Pharmacodynamic (PD) Studies
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5.3.4.1 Healthy Subject PD and PK/PD Study Reports
5.3.4.2 Patient PD and PK/PD Study Reports
5.3.5 Reports of Efficacy and Safety Studies
5.3.5.1 Study Reports of Controlled Clinical Studies Pertinent to the Claimed Indication
5.3.5.2 Study Reports of Uncontrolled Clinical Studies
5.3.5.3 Reports of Analyses of Data from More Than One Study
5.3.5.4 Other Clinical Study Reports
REFERENCES
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DRUG REGULATORY AUTHORITY OF PAKISTAN
Telecom Foundation Complex, G-9/4, Islamabad, Pakistan
Email: addl-dir.pe.reg@dra.gov.pk Phone:92-51-9107416 www.dra.gov.pk
www.dra.gov.pk