Therapeutic Equivalence Codes (TE Codes) Explained: How Generic Drugs Are Approved and Substituted

Therapeutic Equivalence Codes (TE Codes) Explained: How Generic Drugs Are Approved and Substituted

When you pick up a prescription, you might not notice the difference between the brand-name pill and the generic one sitting in your bag. But behind that swap is a detailed, science-backed system called Therapeutic Equivalence Codes-or TE codes-that tells pharmacists whether it’s safe to substitute one drug for another. This isn’t just a bureaucratic label. It’s what keeps millions of Americans on affordable meds without risking their health.

What Are TE Codes and Why Do They Matter?

Therapeutic Equivalence Codes are a rating system created by the U.S. Food and Drug Administration (FDA) to identify which generic drugs can be safely swapped for their brand-name counterparts. They appear in the FDA’s Approved Drug Products with Therapeutic Equivalence Evaluations, better known as the Orange Book. First introduced in 1984 after the Hatch-Waxman Act, TE codes were designed to bring clarity to a messy system where pharmacists in different states had different rules about swapping drugs.

The goal? Save money without sacrificing safety. Generic drugs with a TE rating typically cost 80-85% less than brand-name versions. In 2022 alone, over 6 billion generic prescriptions were filled in the U.S.-most of them because of TE codes. Without this system, pharmacies couldn’t automatically substitute generics, and patients would pay hundreds more each year for the same active ingredient.

How TE Codes Work: The A and B System

Every TE code starts with a letter: A or B. That’s it. But what those letters mean is everything.

- A means the generic drug is therapeutically equivalent to the brand-name drug. It has the same active ingredient, strength, dosage form, and route of administration. More importantly, it’s been proven to work the same way in the body-absorbed at the same rate and to the same extent. These are the drugs pharmacists can swap without asking the doctor.

- B means the FDA doesn’t consider the drug equivalent. This could be because of differences in how it’s absorbed, how stable it is, or even because it hasn’t been tested enough. These drugs are not approved for automatic substitution.

The second letter adds detail. For example:

- AA: Powder for oral solution (like some antibiotics)

- AN: Injectable solution

- AO: Oral solution

- AP: Powder for injection

- AT: Topical cream

These codes aren’t random-they reflect how the drug is made and how it behaves in the body. A generic with an AA rating for levothyroxine (a thyroid hormone) has been shown to deliver the exact same hormone levels as Synthroid. That’s why pharmacists can confidently switch patients between different AA-rated brands without causing side effects.

How the FDA Decides if a Drug Is Equivalent

The FDA doesn’t guess. They require hard evidence.

For a generic drug to get an A rating, the manufacturer must prove three things:

  1. Pharmaceutical equivalence: Same active ingredient, same dose, same form (pill, injection, etc.), same manufacturer (or licensed partner).
  2. Bioequivalence: The generic must absorb into the bloodstream at the same rate and to the same extent as the brand. This is tested using blood samples from healthy volunteers. The FDA requires that the generic’s absorption levels fall within 80-125% of the brand’s. That’s a tight window.
  3. Clinical equivalence: No meaningful difference in how the drug works in patients. This is often proven through bioequivalence data, but for complex drugs, additional studies may be needed.
These requirements are strict. A generic manufacturer must spend millions on testing and submit years of data just to get one TE code. And if the FDA finds a problem later-like a generic inhaler delivering inconsistent doses-it can pull the TE rating. That happened in 2019 with certain generic budesonide inhalers after reports of poor performance.

Patient and pharmacist facing off with warfarin vial and FDA Orange Book, showing blood level graphs.

Where TE Codes Work Best-and Where They Don’t

TE codes shine with simple, well-understood drugs. Take atorvastatin (the generic for Lipitor). Multiple studies, including a 2021 analysis in JAMA Internal Medicine, found no difference in cholesterol-lowering effects between brand and generic versions-even when patients switched between different generic brands.

But not all drugs are so straightforward.

Narrow therapeutic index (NTI) drugs are a problem. These are medications where even tiny changes in blood levels can cause serious harm. Warfarin (a blood thinner), levothyroxine, and phenytoin (an anti-seizure drug) fall into this category. Even though many generics for these drugs have an A rating, some patients report feeling different after switching. A 2022 study in The American Journal of Managed Care found 12.7% of patients reported symptoms after switching-even when clinical tests showed no difference. That’s why some doctors still write “Do Not Substitute” on prescriptions for these drugs.

Complex products like inhalers, topical creams, and injectables are also tricky. The active ingredient might be the same, but the way it’s delivered can change how well it works. The FDA is working on new TE code extensions for these drugs, but as of 2025, the system still struggles with them.

How Pharmacists Use TE Codes Every Day

In a pharmacy, TE codes are checked in seconds. Most pharmacy systems-like Epic, Cerner, or even GoodRx-pull data directly from the FDA’s online Orange Book. When a prescription comes in for a brand-name drug, the system automatically flags if there’s an A-rated generic available.

Pharmacists don’t need to be experts. Pharmacy schools now teach TE codes as part of the core curriculum. Over 98% of 2022 pharmacy graduates passed the NAPLEX exam with solid TE code knowledge. And in practice? 91% of pharmacists say they have high confidence in substituting A-rated generics, according to the National Community Pharmacists Association.

The process is simple:

  1. Prescription comes in for brand-name drug (e.g., Prilosec).
  2. Pharmacy system checks Orange Book for generic equivalents.
  3. If an A-rated generic exists (e.g., omeprazole), the system suggests substitution.
  4. Pharmacist confirms no “Do Not Substitute” note from the doctor.
  5. Generic is dispensed.
This whole process takes less than 30 seconds. And it saves patients-and insurers-hundreds of dollars per prescription.

Holographic FDA Orange Book displays TE codes as patients receive generic pills from robotic arms.

Why TE Codes Are Different from Other Countries

The U.S. system is unique. In Europe, the European Medicines Agency (EMA) doesn’t use a standardized coding system. Instead, each country decides whether to allow substitution. In Canada, there’s a similar concept, but no uniform code. In Germany, the doctor decides-not the pharmacist.

The U.S. system works because it’s built into state law. All 50 states have laws that allow pharmacists to substitute A-rated generics unless the doctor says no. That means a patient in Texas can get the same generic drug as someone in Maine, and both are covered under the same safety standard.

What Patients Should Know

If you’re taking a generic drug, you’re not getting a “lesser” version. You’re getting a drug that’s been proven to work the same way. But here’s what you should do:

  • If you’re on a narrow therapeutic index drug (like warfarin or levothyroxine), stick with the same generic brand if possible. If you switch and feel different, tell your doctor.
  • Don’t assume all generics are the same. Two A-rated generics can still have different fillers or coatings. If you notice a change in how you feel after switching brands, report it.
  • Ask your pharmacist: “Is this the same TE code as my last prescription?” They can check the Orange Book in real time.
  • If your insurance pushes you to switch generics, ask if the new one has the same TE code. If it does, it’s safe.
Most patients report no issues. GoodRx ratings for TE-rated generics for conditions like high blood pressure and diabetes average 4.7 out of 5 based on over 2,000 reviews.

The Future of TE Codes

The FDA is updating the system. In 2022, they released new guidance to standardize how they evaluate complex drugs. By 2024, they plan to extend TE codes to biosimilars-generic versions of biologic drugs like Humira and Enbrel. These are far more complex than pills, and the current system isn’t built for them.

The agency is also testing ways to use real-world patient data-like electronic health records-to supplement lab tests. This could help catch subtle differences that lab studies miss.

By 2027, experts predict TE-rated generics will make up 93.4% of all prescriptions filled in the U.S. That’s up from 90.1% in 2022. The savings are huge: the Congressional Budget Office estimates TE codes will save $1.2 trillion between 2023 and 2032.

The system isn’t perfect. But for most people, most of the time, it works. And that’s what matters.

What does an A-rated TE code mean for my prescription?

An A-rated TE code means the generic drug has been proven by the FDA to be therapeutically equivalent to the brand-name version. It has the same active ingredient, strength, dosage form, and absorption rate. Pharmacists can legally substitute it without asking your doctor, and it will work the same way in your body.

Can I switch between different A-rated generics?

Yes, you can. Two different generics with the same A rating are considered interchangeable by the FDA. But if you’re taking a narrow therapeutic index drug like warfarin or levothyroxine, some patients report feeling different after switching brands-even if clinical tests show no difference. If you notice changes in how you feel, tell your doctor and ask to stick with one brand.

Why do some doctors write "Do Not Substitute" on prescriptions?

Doctors often write this for drugs with a narrow therapeutic index-like blood thinners, thyroid meds, or seizure drugs-where even small changes in absorption can cause serious side effects. While the FDA says A-rated generics are equivalent, some doctors prefer to avoid any risk, especially if a patient has been stable on one brand. It’s a precaution, not a reflection of the generic’s quality.

Are TE codes used outside the United States?

No, the TE code system is unique to the U.S. Other countries use different methods. The European Medicines Agency doesn’t have a standardized coding system. Canada and Australia have equivalence assessments but no official codes like the FDA’s. In Germany, substitution is decided by the doctor, not the pharmacist. The U.S. system is the only one integrated into state law and pharmacy practice nationwide.

How do I check if my generic drug has a TE code?

You can check the FDA’s Orange Book online at fda.gov/orangebook. Enter the brand name or generic name, and the system will show the TE code. Most pharmacy apps and insurance websites also display this information. If you’re unsure, ask your pharmacist-they can look it up in seconds using the same database.

12 Comments

  • Babe Addict
    Babe Addict

    Let me break this down for you people who think the FDA knows what they’re doing. TE codes? More like TE lies. The bioequivalence window of 80-125%? That’s not equivalence-that’s a goddamn lottery. I’ve seen patients on levothyroxine go from AA-rated Brand A to AA-rated Brand B and start having heart palpitations. The FDA doesn’t test for long-term effects, only blood levels. And don’t get me started on the manufacturers who pay for their own studies. This whole system is a corporate shell game dressed up as science.

  • Satyakki Bhattacharjee
    Satyakki Bhattacharjee

    People spend so much time on codes and numbers. But what is health? Is it just a pill? Or is it peace? If your body feels different, even if the numbers say same, then it is not same. We forget that medicine is not math. It is life. And life is not always measured in percentages.

  • Jane Lucas
    Jane Lucas

    so i switched from brand to generic adderall last year and my brain felt like it was wrapped in saran wrap for 3 weeks. i told my doc and they said 'it's the same TE code' but like… i know my body. now i just stick with the brand. worth the extra $80 a month to not feel like a zombie.

  • Elizabeth Alvarez
    Elizabeth Alvarez

    Have you ever wondered why the FDA only tests generics on healthy young men? What about women? Elderly? People with liver disease? The bioequivalence studies are designed to make generics look good-not to reflect real life. And the Orange Book? It’s not public data. It’s curated. There are dozens of generics with A ratings that were pulled from shelves in Canada and Europe for safety issues. They just don’t make it into the U.S. database. Why? Because the pharmaceutical industry owns the FDA. Big Pharma doesn’t want you to know that your $3 generic might be quietly killing you over time. They’re not testing for cumulative toxicity. They’re testing for a 12-hour blood spike. That’s not medicine. That’s a marketing tactic.

  • Miriam Piro
    Miriam Piro

    TE codes are just the tip of the iceberg. 🤫 The FDA doesn’t even test for the *inactive ingredients*-the fillers, dyes, binders. Ever notice how some generics give you migraines or rashes? That’s not your imagination. It’s the talc from China or the dye from India. And guess what? They don’t have to list those in the Orange Book. The whole system is a lie. The government wants you to believe generics are safe. But if you dig into the FDA’s own whistleblower reports, you’ll find that 1 in 4 generic manufacturers have been caught falsifying data. And they still get A ratings. 🤯 This isn’t healthcare. It’s a Ponzi scheme with pills.

  • dean du plessis
    dean du plessis

    Interesting read. I’ve been on generic statins for years. No issues. But I do wonder how many people just accept the system without asking questions. Maybe that’s the real problem-not the codes themselves, but the lack of curiosity. People trust the machine too much. Still, if it saves money and works, why fight it? Just keep an eye on how you feel. That’s all any of us can do.

  • Kylie Robson
    Kylie Robson

    Actually, the bioequivalence criteria are far more rigorous than most realize. The 80-125% AUC and Cmax range is based on ICH guidelines, validated by over 40 years of pharmacokinetic modeling. The FDA’s requirement for intra- and inter-subject variability is stricter than EMA’s. And the ANDA submission process includes stability testing under ICH Q1A conditions-accelerated and long-term. The idea that A-rated generics are 'equivalent' is not a marketing slogan-it’s a statistically validated clinical reality. If you’re experiencing variability, it’s likely due to adherence, comorbidities, or drug interactions-not the TE code.

  • Caitlin Foster
    Caitlin Foster

    OMG I just realized I’ve been taking generic metformin for 5 years and never checked the TE code!! 😱 I’m literally a walking pharmaceutical experiment!! My insurance switched me 3 times!! I’m gonna go scream into a pillow now. Also, who’s the genius who decided we should trust a letter and a number to decide if our life-saving drug is safe?? I need a therapist and a new pharmacist.

  • Olivia Goolsby
    Olivia Goolsby

    They say TE codes are science. But science doesn’t hide behind ‘confidential business information.’ Science doesn’t let manufacturers self-report bioequivalence. Science doesn’t ignore real-world outcomes. The FDA’s Orange Book is a black box. The same companies that make the brand drugs also make the generics. Same factories. Same executives. Same lobbyists. And the FDA? They’re on the payroll. You think they’d let a generic with 118% absorption get an A rating? Of course they would. Because the goal isn’t safety. It’s profit. And you? You’re the cost center. Wake up. This isn’t healthcare. It’s a surveillance state disguised as a pharmacy.

  • Alex Lopez
    Alex Lopez

    While I appreciate the passion in the comments above, I must respectfully challenge the conspiracy framing. The FDA’s TE system, while imperfect, is the most transparent and data-driven drug substitution framework in the world. Yes, there are edge cases-NTI drugs, complex delivery systems-but those are actively being addressed through the 2022 guidance and real-world evidence initiatives. The fact that 91% of pharmacists report high confidence in substitution speaks to the system’s reliability. And yes, if you feel different after a switch, report it to MedWatch. That’s how the system improves. Skepticism is healthy. Paranoia is not. 🤝

  • Gerald Tardif
    Gerald Tardif

    Man, I used to think generics were just cheap knockoffs. Then I worked in a clinic where half our patients couldn’t afford brand-name insulin. Saw a guy go from diabetic ketoacidosis to stable HbA1c on a $4 generic. No drama. No side effects. Just… life. Yeah, there are weird cases. But for 95% of people? This system saves lives. Don’t let the noise drown out the fact that millions of folks get to breathe easier because of TE codes. Be smart. Be aware. But don’t throw the baby out with the bathwater.

  • Babe Addict
    Babe Addict

    Oh please. Alex, you sound like a paid FDA lobbyist. If the system’s so perfect, why do 12.7% of patients report symptoms after switching levothyroxine brands-even when labs are ‘normal’? That’s not ‘adherence.’ That’s bioavailability variance masked by sloppy testing. And don’t give me that ‘report it to MedWatch’ garbage. The FDA receives 500,000 reports a year and acts on less than 0.1%. You think your ‘data-driven’ system cares about a single person’s palpitations? Nah. It cares about the bottom line. Keep believing in the machine. I’ll keep checking my blood levels.

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