The document proposes a Topical Drug Classification System (TCS) to classify topical drug products based on their qualitative (Q1) and quantitative (Q2) composition and microstructure (Q3) arrangements. TCS is combined with in vitro drug release testing and is meant to justify waiving in vivo studies for generic topical drugs. It classifies products as TCS Class 1-4 depending on their similarity to the reference listed drug for Q1, Q2, and Q3. Only Class 1 and 3 products are eligible for biowaiver based on in vitro tests, while Class 2 and 4 require in vivo studies. The goal of TCS is to streamline generic approval while ensuring safety and efficacy.