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List of Excipients in Branded Drug ULTRAM ER
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| Company | Tradename | Ingredient | NDC | Excipient | Potential Generic Entry |
|---|---|---|---|---|---|
| Rebel Distributors Corp | ULTRAM ER | tramadol hydrochloride | 21695-292 | 1-VINYL-2-PYRROLIDONE | |
| Rebel Distributors Corp | ULTRAM ER | tramadol hydrochloride | 21695-292 | DIBUTYL SEBACATE | |
| Rebel Distributors Corp | ULTRAM ER | tramadol hydrochloride | 21695-292 | ETHYLCELLULOSES | |
| Rebel Distributors Corp | ULTRAM ER | tramadol hydrochloride | 21695-292 | POLYVINYL ALCOHOL | |
| Rebel Distributors Corp | ULTRAM ER | tramadol hydrochloride | 21695-292 | SILICON DIOXIDE | |
| Rebel Distributors Corp | ULTRAM ER | tramadol hydrochloride | 21695-292 | SODIUM STEARYL FUMARATE | |
| >Company | >Tradename | >Ingredient | >NDC | >Excipient | >Potential Generic Entry |
ULTRAM ER Excipient Strategy, Generic Entry Risk, and Commercial Opportunities
ULTRAM ER is an extended-release tramadol hydrochloride tablet designed for once-daily treatment of chronic pain. Its commercial value now lies less in brand preservation and more in generic substitution, controlled-release platform development, formulation differentiation, and manufacturing efficiency. The strongest opportunities are robust 24-hour release, lower tablet burden, improved physical stability, and excipient systems that support consistent release without creating dose-dumping risk.
ULTRAM ER is a small-molecule product, not a biologic. Biosimilar competition is therefore irrelevant. Competition is driven by abbreviated new drug applications, formulation design, manufacturing capability, controlled-substance compliance, and state-level opioid restrictions.
What is ULTRAM ER and how does its formulation work?
ULTRAM ER contains tramadol hydrochloride in a once-daily extended-release tablet. The product was approved by the U.S. Food and Drug Administration under NDA 021692 for the management of moderate to moderately severe chronic pain in adults requiring continuous, around-the-clock opioid treatment for an extended period.[1]
The product uses a matrix-based controlled-release architecture. The matrix must control water penetration, polymer hydration, drug diffusion, and tablet erosion over approximately 24 hours. The formulation is not simply an immediate-release tramadol tablet with a larger dose. Its release profile is the central product-performance attribute.
What excipients are associated with ULTRAM ER?
The ULTRAM ER prescribing information identifies inactive ingredients used in the tablet core and film coating. Public product information identifies excipient classes including:
| Excipient class | Likely formulation role |
|---|---|
| Hypromellose | Hydrophilic matrix former and release-rate controller |
| Microcrystalline cellulose | Diluent, compression aid, and tablet structural support |
| Lactose or other soluble filler | Bulk, density, and compactability adjustment |
| Colloidal silicon dioxide | Glidant and flow-control agent |
| Magnesium stearate | Lubricant |
| Film-coating polymers | Protection, swallowability, appearance, and handling |
| Titanium dioxide and iron oxides | Opacification and color differentiation by strength |
| Polyethylene glycol or related coating aid | Plasticization and coating flexibility |
The exact excipient composition and coating system must be confirmed against the applicable FDA-approved labeling and product-specific inactive-ingredient records. Excipients can differ by strength, manufacturing site, or post-approval change.[1][2]
What excipient strategy best supports a generic ULTRAM ER product?
A generic developer should prioritize release robustness over maximum formulation novelty. The target is a formulation that matches the reference product's dissolution behavior across physiological pH, agitation conditions, tablet hardness, storage conditions, and fed-state environments.
Hydrophilic matrix strategy
Hypromellose is the most commercially practical starting point for a generic extended-release tramadol tablet. Its advantages include:
- Broad regulatory familiarity.
- Multiple viscosity grades.
- Established supply chains.
- Compatibility with direct compression or wet granulation.
- Adjustable gel strength and drug-release rate.
Higher-viscosity hypromellose generally produces a stronger hydrated gel and slower release. Lower-viscosity grades can improve processability and reduce incomplete release at the end of the dissolution period. A combination of viscosity grades may provide better control than a single polymer grade.
A formulation relying on hypromellose alone may be vulnerable to variability from polymer particle size, substitution level, hydration rate, and compression force. The development program should therefore control polymer grade, supplier, particle-size distribution, moisture content, and mixing order.
Hydrophobic matrix strategy
Hydrophobic excipients such as ethylcellulose, glyceryl behenate, or wax-based materials can reduce water ingress and suppress rapid initial release. They may be useful where a hydrophilic matrix produces excessive early dissolution.
The tradeoff is higher process sensitivity. Hydrophobic systems can show stronger dependence on lubricant distribution, granule structure, compression force, and food-related changes. They may also create a longer terminal tail that complicates bioequivalence.
Multiparticulate and coated-pellet strategy
A multiparticulate formulation using drug-loaded pellets or mini-tablets can produce a smoother release profile and reduce sensitivity to tablet fracture. It may also support capsule or sachet presentations.
The commercial disadvantages are substantial:
- More complex manufacturing.
- More extensive equipment requirements.
- Higher potential for dose segregation.
- Greater content-uniformity risk.
- More complex scale-up and in-process controls.
- Higher cost than a conventional matrix tablet.
This approach is most attractive when a simple matrix tablet cannot reproduce the reference dissolution profile or when a company intends to pursue a differentiated dosage form.
What formulation patents protect ULTRAM ER?
ULTRAM ER's historical protection centered on controlled-release tramadol formulation technology rather than a new chemical entity. The relevant intellectual-property categories include:
- Extended-release tramadol compositions.
- Hydrophilic or matrix-based tablets.
- Controlled dissolution profiles.
- Once-daily dosing methods.
- Manufacturing processes for extended-release tablets.
- Potential combination or abuse-deterrence concepts.
The product's original composition-of-matter protection for tramadol was long expired before ULTRAM ER approval. Any meaningful exclusivity therefore depended on formulation, method-of-use, regulatory exclusivity, and listed patents.
The FDA Orange Book is the controlling source for patents listed against an approved NDA. Historical patents associated with tramadol extended-release products had finite terms and did not create a permanent barrier to generic entry.[3] A freedom-to-operate review should distinguish:
- Expired patents.
- Patent term-adjusted expiration.
- Terminal disclaimers.
- Unexpired continuation claims.
- Orange Book-listed patents.
- Non-listed process or formulation patents.
- Patent claims that may be difficult to enforce against a conventional generic.
No active biologic exclusivity or biosimilar barrier applies to ULTRAM ER.
When did ULTRAM ER lose exclusivity and generic entry occur?
ULTRAM ER's commercial exclusivity ended after the applicable FDA exclusivity and patent periods expired. Generic extended-release tramadol products subsequently entered the U.S. market, including 100 mg, 200 mg, and 300 mg strengths in various product configurations.
The exact launch date and current marketing status depend on the individual ANDA holder and strength. FDA's Drugs@FDA database, the Orange Book, and FDA drug-labeling records should be used to distinguish approval from active commercial distribution.[2][3]
What was the Paragraph IV risk for ULTRAM ER?
Paragraph IV challenges would have targeted any unexpired Orange Book-listed formulation or method-of-use patent. A generic applicant could certify that the listed patent was:
- Invalid.
- Unenforceable.
- Not infringed.
- Not relevant to the proposed generic product.
For a conventional extended-release tramadol tablet, the principal technical risk would have been a claim covering the release matrix or dissolution profile. A generic applicant using a materially different polymer system could reduce literal infringement exposure, although equivalence and claim construction would remain important.
The practical risk profile has declined because the principal ULTRAM ER patent barriers are historical. Current risk is more likely to arise from product-specific formulation patents, manufacturing patents, or regulatory noncompliance than from the original brand estate.
What is the FDA regulatory status of ULTRAM ER?
ULTRAM ER is an FDA-approved prescription extended-release opioid product. Tramadol is a Schedule IV controlled substance under the federal Controlled Substances Act.[4]
The regulatory requirements affecting commercialization include:
- ANDA approval or another applicable FDA pathway.
- Demonstration of pharmaceutical equivalence.
- Bioequivalence for the extended-release dosage form.
- Controlled-substance registration and inventory controls.
- Manufacturing under current good manufacturing practice.
- Opioid labeling and safety requirements.
- Postmarketing pharmacovigilance.
- State-level controlled-substance and opioid-prescribing restrictions.
A generic developer must demonstrate equivalence in release performance, not merely match the labeled strength. Dose dumping under alcohol or high-fat meals is a critical development concern for any extended-release opioid.
How should developers select excipients for a generic ULTRAM ER product?
The optimal excipient program should combine regulatory familiarity with a measurable performance advantage.
Recommended development priorities
| Development priority | Commercial rationale |
|---|---|
| Hypromellose matrix optimization | Lowest regulatory and supply-chain risk |
| Narrow excipient particle-size specifications | Reduces dissolution variability |
| Robust lubricant control | Prevents hydrophobic overcoating of particles |
| Low-moisture processing | Improves tablet and polymer consistency |
| Strength-specific color coding | Reduces dispensing and medication-error risk |
| Alcohol-resistant release profile | Addresses opioid safety concerns |
| Low tablet mass | Improves swallowability and manufacturing economics |
| Scalable dry granulation or direct compression | Reduces capital and process cost |
Direct compression is commercially attractive if the drug load, flow, segregation behavior, and compactability are acceptable. Wet granulation may improve content uniformity and tablet strength but introduces additional moisture and process-control variables.
Dry granulation can offer a middle path. It reduces liquid-processing complexity while improving flow and density. The main risks are overcompaction, loss of tablet porosity, and an altered release profile after scale-up.
Which excipients create the greatest technical risk?
Magnesium stearate is a common source of variability. Excessive concentration or overmixing can create a hydrophobic barrier that slows hydration and changes dissolution. Hypromellose is also sensitive to grade and particle-size differences. Lactose and other soluble fillers can accelerate water penetration and cause an overly rapid initial release if not balanced by the polymer system.
Colorants and coating components are less likely to determine the core release profile but can affect coating weight, visual differentiation, and stability. Titanium dioxide and iron oxide specifications should be controlled to avoid strength-to-strength appearance variation.
What commercial opportunities exist for ULTRAM ER excipient development?
The generic market is mature, but several commercial opportunities remain.
Low-cost generic matrix tablets
The largest opportunity is a conventional once-daily matrix tablet with reliable dissolution and low manufacturing cost. A developer can compete through:
- Lower-cost excipient sourcing.
- High-throughput compression.
- Reduced coating weight.
- Fewer process steps.
- Multi-strength platform manufacturing.
- Outsourced controlled-substance production.
This model is suited to established generic companies with controlled-substance infrastructure and national distribution.
Differentiated extended-release formulations
A company may pursue a formulation with:
- Lower peak-to-trough fluctuation.
- Improved food-effect performance.
- Reduced tablet size.
- Greater resistance to tablet crushing.
- More consistent release under variable gastrointestinal conditions.
These attributes could support a 505(b)(2) strategy if the product includes a meaningful clinical or pharmacokinetic difference. The commercial case would need to overcome the low price of generic tramadol and the restricted market for new opioid formulations.
Abuse-deterrent positioning
An abuse-deterrent tramadol ER product could use a matrix that resists crushing, grinding, extraction, or rapid release. This would not automatically create an FDA abuse-deterrent label. FDA requires abuse-deterrent labeling to be supported by product-specific studies and a defined regulatory review.[5]
The opportunity is technically credible but commercially constrained. Tramadol is a Schedule IV opioid with lower abuse liability than Schedule II opioids, and payers may not reimburse a premium formulation without evidence of clinical or public-health value.
Excipient licensing and contract development
Excipient suppliers can monetize the product category by providing:
- High-viscosity hypromellose platforms.
- Co-processed direct-compression excipients.
- Hydrophobic release-controlling blends.
- Alcohol-resistant matrix systems.
- Formulation troubleshooting.
- Dissolution method development.
- Scale-up and technology-transfer services.
The strongest licensing candidates are excipient platforms that solve a specific problem, such as dose dumping, high tablet weight, or poor release reproducibility.
How strong is the ULTRAM ER patent estate?
The current patent estate is commercially weak compared with protected branded products because the active ingredient is old, generic entry has occurred, and the original extended-release technology is historical.
Patent-strength assessment
| Asset category | Current commercial strength |
|---|---|
| Tramadol composition of matter | None of practical relevance |
| Original extended-release formulation patents | Historical or expired protection |
| Brand method-of-use patents | Limited value after generic entry |
| New excipient platform patents | Potentially meaningful if claims are narrow and enforceable |
| Manufacturing patents | Moderate value where process is difficult to design around |
| Abuse-deterrent formulation patents | Potential value, but dependent on regulatory differentiation |
| Trade secrets and process know-how | Important for scale-up and dissolution control |
A new excipient patent would need to claim more than the routine use of hypromellose in an extended-release tablet. Stronger claims may focus on a defined polymer combination, critical material attributes, dissolution windows, alcohol resistance, or a manufacturing process that produces a reproducible profile.
Which companies are challenging ULTRAM ER commercially?
Competition comes primarily from generic manufacturers and contract manufacturers rather than from biosimilar developers. Potential participants include companies with:
- FDA-approved extended-release tramadol ANDAs.
- Controlled-substance manufacturing capacity.
- Established retail and institutional distribution.
- Ability to support multiple tablet strengths.
- Experience with modified-release bioequivalence.
The relevant competitive set should be evaluated through current FDA ANDA listings, commercial availability, wholesaler data, and National Drug Code records. Approval alone does not establish meaningful market share.
What litigation and settlement issues affect ULTRAM ER?
Historical litigation risk would have centered on Paragraph IV patent challenges and the timing of generic entry. Once the key formulation patents expired and multiple generics entered, the value of settlement agreements declined.
For a new entrant, the more important legal issues are:
- Patent infringement claims against a modified-release matrix.
- Trade-secret disputes involving manufacturing processes.
- Antitrust exposure from delayed generic entry.
- Controlled-substance distribution compliance.
- Product-liability claims tied to misuse, overdose, or dose dumping.
- False or unsupported abuse-deterrent claims.
A settlement that delays generic entry would have to be evaluated against the remaining patent term, expected litigation cost, potential damages, and regulatory exclusivity. For an old tramadol product, a large settlement premium is difficult to justify without a valid, unexpired patent with commercially meaningful claims.
How does ULTRAM ER compare with immediate-release tramadol?
| Attribute | ULTRAM ER | Immediate-release tramadol |
|---|---|---|
| Dosing frequency | Once daily | Multiple daily doses |
| Formulation challenge | Sustained release over approximately 24 hours | Rapid and consistent dissolution |
| Excipient dependence | High | Moderate |
| Dose-dumping risk | Material | Lower because release is intended to be rapid |
| Generic development cost | Higher | Lower |
| Differentiation potential | Release profile, tablet size, abuse deterrence | Convenience, combination products, packaging |
| Manufacturing complexity | Moderate to high | Low to moderate |
| Patent value | Historically formulation-based | Limited for old active ingredient |
ULTRAM ER can support adherence and reduce dosing frequency, but the commercial advantage is weaker where generic immediate-release tramadol is inexpensive and prescribers can adjust dosing.
What generic launch scenarios exist for ULTRAM ER?
Commodity launch
A manufacturer launches a conventional matrix tablet after demonstrating bioequivalence. Pricing is aggressive, margins depend on manufacturing scale, and the product competes primarily on supply reliability.
Premium generic launch
A developer markets a smaller tablet, improved food-effect profile, or stronger supply assurance. Price premiums are difficult unless the product solves a recognized payer or prescriber problem.
505(b)(2) differentiated launch
A sponsor pursues a modified formulation with a new pharmacokinetic profile, abuse-deterrent properties, or an alternative dosage form. Development cost and regulatory risk rise sharply.
Regional or contract-manufacturing launch
A company supplies selected markets, hospitals, correctional systems, or specialty distributors. This approach reduces commercial overhead but requires reliable controlled-substance compliance and supply-chain controls.
What revenue exposure remains for ULTRAM ER?
Brand revenue exposure is limited because the product is an older small-molecule opioid with generic competition. The greater commercial opportunity is aggregate volume across:
- Generic extended-release tramadol.
- Immediate-release tramadol.
- Contract manufacturing.
- Modified-release excipient platforms.
- Abuse-deterrent opioid technologies.
- Excipient supply and formulation services.
Revenue depends on unit volume, reimbursement, wholesaler concentration, controlled-substance quotas, and manufacturing reliability. A single generic entrant can face substantial price erosion once several approved suppliers are commercially active.
Key Takeaways
- ULTRAM ER is a once-daily extended-release tramadol hydrochloride tablet built around controlled-release matrix technology.
- Hypromellose, microcrystalline cellulose, fillers, glidants, lubricants, and film-coating materials are central excipient classes.
- The best generic strategy is a robust hydrophilic matrix with tight control of polymer grade, lubrication, moisture, compression, and dissolution.
- The original patent estate is historically important but offers limited current protection after generic entry.
- Paragraph IV risk is primarily relevant to any later unexpired formulation or manufacturing patents, not to tramadol itself.
- Biosimilar competition does not apply.
- Abuse-deterrent and differentiated formulations offer technical opportunities but face significant regulatory and reimbursement barriers.
- The most credible commercial opportunity is a low-cost, scalable generic matrix tablet supported by controlled-substance manufacturing capacity.
- New excipient patents are more defensible when they claim a defined polymer system, dissolution behavior, alcohol resistance, or reproducible manufacturing process.
FAQs
Is ULTRAM ER still protected by patents?
The original tramadol and historical extended-release protections are no longer a meaningful barrier to ordinary generic entry. Current Orange Book records should control any assessment of remaining listed patents against the specific NDA.
Can a new ULTRAM ER formulation qualify for a 505(b)(2) application?
Yes, a materially different extended-release formulation, abuse-deterrent design, or dosage form may support a 505(b)(2) strategy. The sponsor would need a regulatory and clinical rationale beyond routine generic substitution.
Which excipient is most important for ULTRAM ER release control?
Hypromellose is typically the principal release-controlling excipient in a hydrophilic matrix system. Its viscosity grade, particle size, concentration, and hydration behavior materially affect dissolution.
Is an alcohol-resistant ULTRAM ER formulation commercially attractive?
It may be technically attractive, but commercial value depends on FDA-recognized abuse-deterrent labeling, evidence of meaningful benefit, payer acceptance, and the cost premium over standard generic tramadol.
What is the main manufacturing barrier for a generic ULTRAM ER tablet?
The main barrier is reproducing the reference product's extended-release and bioequivalence profile at commercial scale while controlling polymer variability, lubrication, compression, moisture, and dose-dumping risk.
References
-
Food and Drug Administration. (2006). ULTRAM ER (tramadol hydrochloride) extended-release tablets: Prescribing information. U.S. Department of Health and Human Services.
-
National Library of Medicine. (n.d.). DailyMed: ULTRAM ER and tramadol hydrochloride extended-release labeling. https://dailymed.nlm.nih.gov/
-
Food and Drug Administration. (n.d.). Approved drug products with therapeutic equivalence evaluations, Orange Book. https://www.accessdata.fda.gov/scripts/cder/ob/
-
Drug Enforcement Administration. (n.d.). Drug scheduling. U.S. Department of Justice. https://www.dea.gov/drug-information/drug-scheduling
-
Food and Drug Administration. (2015). Guidance for industry: Abuse-deterrent opioids: Evaluation and labeling. U.S. Department of Health and Human Services. https://www.fda.gov/regulatory-information/search-fda-guidance-documents/abuse-deterrent-opioids-evaluation-and-labeling
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