Insights

PHARMACEUTICAL COMPANIES RELATIONSHIP WITH EXPERT PATIENTS – FARMINDUSTRIA REGULATIONS

Pharmaceutical companies frequently cooperate with patient associations by involving their representatives as speakers in events and meetings.

Relationships between pharmaceutical companies and patient associations are strictly regulated and no promotional purpose is allowed.

Farmindustria Code of Conduct provides guidelines and criteria companies should comply with when collaborating with patient associations.

With the latest version of the Code, released on 5th April 2022, Farmindustria has introduced the “Expert Patient”.

Patients are considered “Expert Patients” if, beyond having a direct experience and knowledge of the disease, have specific skills related to research, regulatory and advocacy activities – certifications and certificates might be made available.

The collaboration should comply with several criteria and Farmindustria provides a guideline for hospitality, fees for service, transparency rules etc.

Regulatory Pharma Net is available to provide your company with any updates and to support on all regulatory needs on this topic.

Do not hesitate to contact us at info@regulatorypharmanet.com

Insights

INSTITUTIONAL PROMOTION BEFORE THE MARKETING AUTHORISATION (MA) IN ITALY – CENTRALIZED REGISTRATIONS

If a medicinal product is not yet authorized in Italy, it is not possible to do promotional activities except for those of an institutional nature.

The three main scenarios described below can be outlined:

  1. Before the EC decision on the EU Marketing Authorisation

Since the topics of the event do not concern any authorised medicinal product, related to the concerned company:

  • no request of sponsorship can be done
  • the company can sponsor disease awareness events only through institutional activities
  • no promotional activities can be performed
  • Italian HCPs cannot be invited as participants.

 

  1. Following the EC decision and before the national Marketing Authorisation by AIFA

Since the topics of the events concern a medicinal product centrally approved, related to the concerned company:

  • request of sponsorship is mandatory and only disease awareness events can be performed
  • no promotional activities can be performed (i.e. no booth/ no promotional materials)
  • Italian HCPs can be invited as participants.

 

  1. Following the national Marketing Authorisation by AIFA

Since the topics of the events concern the medicinal product registered in Italy, related to the concerned company:

  • request of sponsorship is mandatory
  • promotional activities can be performed, provided that promotional materials have been deposited at AIFA and 10 days elapsed after the AIFA deposit without any comments raised by the Italian Authorities. Commercial materials are allowed.
  • Italian HCPs can be invited as participants

 

Regulatory Pharma Net (RPN) can provide any regulatory assistance on meetings/events planning and sponsorship.

Feel free to contact us at info@regulatorypharmanet.com

Insights

Local Recall Process for Quality Defects or Safety Issue in Medicinal Products in Italy

In case of a quality defect or safety issue of a medicinal product is identified and the product recall procedure is necessary, the Marketing Authorisation Holder (MAH) has to inform immediately AIFA and simultaneously starts an efficient and swift recall procedure to mitigate any potential risks associated with the defective product.

To effectively navigate this situation, the MAH along with all entities participating in the distribution of the medicinal product must establish comprehensive procedures, with a precise delineation of responsibilities, for managing the recall of medicinal product batches from the Italian market.

The MAH is expected to notify distributors, logistics partners, trade associations, and healthcare institutions to prevent further use of the medicinal product, verify both unsold and sold stock levels while identifying recipients, check for the product’s presence within the distribution network, and ensure full traceability of all product batches.

AIFA outlines the timeframe allotted to the Marketing Authorization Holder (MAH) for demonstrating the initiation of recall procedures and informs accordingly several trade associations, Italian databases, Istituto Superiore di Sanità (ISS), NAS (department of the National Military Police responsible for control of medicines), Regions, etc.

 

RPN will provide any further update and is available to support for these activities.