Acrobat Font Embedding for FDA Submissions

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The U.S. Food and Drug Administration sets guidelines for electronic regulatory submissions for the Center for Drug Evaluation and Research (CDER) and the Center for Biologics Evaluation and Research (CBER).

The agency has long relied upon PDF because of Acrobat’s ability to faithfully render all aspects of printed pages including layout, tables, images and fonts (typefaces).

The last item—fonts—is a critical aspect of displaying documents.

Acrobat offers three choices that balance file size versus absolute fidelity:

  • Font Substitution
    Acrobat renders—on the fly—a “faux font” representation using typeface information included in the PDF.
  • Font Subsetting
    Only the typeface characters necessary to render the file are embedded. Typefaces may have thousands of characters. Only embedding the actual characters used can reduce file size.
  • Font Embedding
    All typefaces necessary to render a font are embedded in the file.

While Font Substitution keeps file sizes small, it can be problematic for submissions as non-standard fonts and specialized math symbols may not render faithfully for reviewers.

Font Subsetting is a tempting choice because it renders all the characters in a document accurately while keeping file size to a minimum. However, subsetting can result in “file bloat” if you regularly combine files. The Acrobat Distiller Reference Manual discusses this issue:

When Acrobat merges two PDF files, each containing a subsetted version of the same font, it produces a new PDF file that retains both subsetted fonts. The net size of the two subsetted fonts may be larger than the full font would have been.

For the reasons cited above, the FDA recommends that all fonts used in PDF submissions be completely embedded. See Providing Regulatory Submissions in Electronic Format – General Considerations.

Unfortunately, the “Standard” conversion setting in Acrobat does not embed the most common office fonts. These fonts such as Arial and Times Roman are normally installed as part of the operating system.

A recommended best practice is to create a new PDF Conversion setting which embeds all fonts and use it for creating all PDFs.

Read on to learn how . . .

Creating an “Embed All” Setting

Follow these steps to create PDF setting that embeds all fonts:

  1. In Acrobat, choose Edit—> Preferences.
  2. Click on the Convert To PDF category item in the list at left
  3. Select Microsoft Word from the middle list
  4. Click the Edit Settings button
    Edit Settings veiw
  5. In the Adobe PDF Settings window, click the Edit button:
    Choosing the right conversion setting
  6. Select the Fonts category from the list at left and uncheck “Subset Embedded Fonts… “
    Turn off Subset Fonts
  7. Select all the fonts listed in the "Never Embed" list on the right. Click the Remove button.
    Saving a new setting

    Tip: Shift-click to select multiple entries in the list.

  8. Click the Save As . . . button:
    Save As to create a new setting

  9. Name the file. It will be saved in the users default Acrobat job options folder:
    Naming the conversion setting
  10. Click Save, then OK twice.

Multiple Ways to Create PDF

Acrobat offers a multitude of methods for creating PDFs from Office documents:

  • Via the AdobePDF Print driver
  • Via the PDFmaker buttons installed into popular office applications
  • By combining native documents using the Combine function in Acrobat

Each approach will require some set-up to ensure that all documents created have fonts embedded.

Setting Embed All for the Adobe PDF Print Driver

Follow these steps to set the Adobe PDF Print Driver to always use the Embed All setting:

  1. From any application, choose File—> Print.
  2. Select the Adobe PDF from the Name list.
    Click the Properties button
    Changing Adboe PDF print driver setting
  3. Choose the Embed All from the Default Settings list
    Click OK.
    Choosing Embed All setting

Setting the Embed All setting for Office PDF Makers

Acrobat Professional installs 1-button PDF conversion toolbars and menus into popular Office applications such as Word, Excel, PowerPoint, Visio, Project and Internet Explorer.

Follow these steps to set an Office PDFmaker button to always use the Embed All setting. The example below is from Microsoft Word.

  1. Launch the application of your choice, but do not open a document.
  2. Choose AdobePDF—> Change Conversion Settings
  3. Choose Embed All from the Conversion Settings list
    Choosing Embed All from the PDF Maker
  4. Click OK

Setting Embed All for Combine or Create from Desktop in Acrobat

Acrobat allows users to convert several different kinds of native files using the Combine function or via the desktop.

When conversion takes place using these direct methods, you need to specify the desired conversion setting in Acrobat Preferences for each application supported.

  1. In Acrobat Professional, choose Edit—> Preferences
  2. Click on the Convert to PDF category from the list at left
  3. Click the Edit Settings button
    Acrobat conversion Prefs
  4. In the Edit Settings window, change the Conversion Setting to “Embed All”
    Changing the setting in Prefs
  5. Click OK
  6. Repeat for all applications

Final Thoughts

Since it is not possible in Acrobat to embed missing fonts in a document after PDF creation, it is critical to choose the proper conversion setting in Acrobat.

Proper preparation of documents can avoid problems downstream.