Insights

REGULATORY AFFAIRS – MANDATORY USE OF COMMON EUROPEAN SUBMISSION PORTAL FOR MUTUAL RECOGNITION PROCEDURE/DECENTRALIZED PROCEDURE

According to the eSubmission Roadmap, from July 1st 2019, the use of the Common European Submission Portal (CESP) has become mandatory also for AIFA.

This system is applicable only to mutual recognition and decentralized procedure (MRP/DCP) submissions, for the moment, while for the national procedures, companies should follow the same rules.

However, in order to ensure an appropriate implementation of the CESP program, despite the submission via CESP, AIFA recommends maintaining the same submission modalities (following the dispositions of 20th December 2018): for new MAA/line extension submitted through national, mutual recognition, repeat use and decentralized procedures, the eCTD sequence should still be provided to AIFA in a CD-ROM by courier with the relevant cover letter and eAF (original signed paper copy or digital signed electronic copy).

For variation applications and renewals, the upload on the AIFA Front END system is still required, together with the cover letter and eAF (original signed paper copy or digital signed electronic copy). In this case, the submission of the CD-ROM is required only when the size of the documentation does not allow the upload on the system.

As for the Active Substance Master File (ASMF), the dossier should be submitted in eCTD format in a CD-ROM by courier, together with a submission letter and signed letter of access (original signed paper copy or digital signed electronic copy).

RPN has created its own CESP account and is able to support companies with the submission through the portal.

Insights

REGULATORY AFFAIRS – RISK EVALUATION ON NITROSAMINES STEP 1 – EXTENDED TO 1 OCTOBER 2020

Due to the severe impact of COVID-19 pandemic, the European Medicines Regulatory Network has agreed to extend the deadline to complete and submit the outcome of step 1, risk evaluation of all human medicines containing chemically synthesized active substances for the presence of Nitrosamines, which was foreseen for 26 March 2020, according to the “Information on nitrosamines for marketing authorization holders”. The deadline has been shifted to 1 October 2020 and marketing authorization holders are encouraged to provide the outcomes before this date, following the same procedure.

Insights

REGULATORY AFFAIRS – COVID-19 RESTRICTIONS: WHAT TO KNOW ABOUT GMP/GDP ISSUES

Covid-19 pandemic has led to different restrictions that may also have an impact on some on-site Good Manufacturing Practices (GMP) and Good Distribution Practices (GDP) inspections.

The Q&A recently issued by the European Commission, EMA and the European medicines regulatory network has articulated appropriate measures to address such restrictions and minimize risks of shortages while ensuring that the high standards of quality, safety and efficacy of medicines made available to patients in the EU are maintained.

The measures put in place in order to guarantee the continuous respect of GMP and GDP requirements are the extension of the validity until the end of 2021 for:

  • GMP certificates and authorizations to the manufacture and importation of medicinal products (using different approaches for sites located in the EEA and outside the EEA)
  • GDP certificates and authorizations to wholesalers and distributors

Some adaptations (always in respect of the GMP requirements) have been introduced also to the role of the Qualified Person (QP), such as:

  • remote batch certification
  • remote audits of the active substance manufacturer
  • remote batch release of investigational medicinal products imported from third countries.

 

Regulatory Pharma Net team is available to fully support companies for any query.

Insights

REGULATORY AFFAIRS – COVID-19: EMA INITIATIVES

Due to the current COVID-19 pandemic, EMA has taken lots of initiatives (EMA/213341/2020) to accelerate the development support and evaluation procedures for COVID-19 treatments and vaccines.

These measures concern the following aspects:

  • Rapid Scientific Advice, which leads developers to a prompt guidance on the best methods and study design to generate adequate data on medicine and vaccines.
  • Rapid agreement of Paediatric Investigation Plan (PIP), which offers to establish a rapid and flexible approach for a PIP, deferral or waiver for treatments and vaccines for COVID-19.
  • Rolling Review, which is an ad hoc procedure used in an emergency context to allow EMA to continuously assess the data for an upcoming highly promising application as they become available.
  • Marketing Authorisation to encourage applicants to contact EMA early in the product development to discuss scientific and regulatory aspects of their planned application for the prevention or treatment of COVID-19.
  • Extension of indication and of marketing authorisation to encourage Marketing Authorisation Holders (MAH) to share early information about their planned development for already authorised products for the treatment or prevention of COVID-19.
  • Compassionate use programme in order to facilitate the availability to patients of new COVID-19 treatment or prevention options that are under development.

 

Regulatory Pharma Net team is available to support companies through all these procedures.

Insights

REGULATORY AFFAIRS – NEW PLATFORM FOR SCIENTIFIC ADVICE

Starting from October 19th, 2020, developers of human medicines should use the European Medicines Agency (EMA)’s IRIS Regulatory & Scientific Information Management Platform (which is currently used for orphan drug designation procedures), according to the last communication issued by EMA.

The IRIS platform will offer applicants and EMA to submit requests, communicate, share information and deliver documents concerning each scientific advice procedure. Therefore, developers who wish to apply for scientific advice must be first registered to use IRIS.

 

RPN is already registered to IRIS and can support companies through all the stages of the scientific advice procedure.

Insights

CONFIDENTIALITY ARRANGEMENT BETWEEN EU AND BRAZILIAN REGULATORY AUTHORITIES

The European Medicines Agency (EMA) and the European Commission’s Directorate-General for Health and Food Safety (DG SANTE) signed a confidentiality agreement, which came into effect on 26 March 2021, with the Brazilian Authority Agência Nacional de Vigilância Sanitária (ANVISA).

This represents a first step towards a mutual agreement between EU and Brasil, which both recognized the necessity of a regulatory harmonization to improve the human and animal health.

The Authorities are indeed exchanging information concerning the safety, quality and efficacy of both human and veterinary medicines (already authorised or under evaluation) as well as information on inspections, regulatory guidance and legislation.

Regulatory Pharma Net is available to provide additional insight and updates on the agreement status.

Insights

PILOT PROGRAM EMA-FDA PARALLEL SCIENTIFIC ADVICE FOR HYBRID/COMPLEX GENERIC PRODUCTS

The European Medicines Agency (EMA) and the U.S. Food and Drug Administration (FDA) have established a pilot program, starting from September 15th, to provide Parallel Scientific Advice (PSA) to applicants of marketing authorization applications (MAAs) for hybrid products (EMA) and abbreviated new drug applications (ANDAs) for complex generic drug products. This program aims at providing a mechanism for EMA and FDA to concurrently consider and jointly exchange with applicants the agencies’ points of view on scientific questions during the development phase of hybrid/complex generic products. Successful collaboration may provide applicants with a deeper understanding of the basis of regulatory decisions, optimize product development, and avoid unnecessary replication of studies or unnecessary testing methodologies. The agencies conduct PSA meetings under the confidentiality arrangement between the European Commission, the EMA, and FDA.

There are three stages in this pilot PSA meeting process:

1) Stage 1, applicants request a meeting with EMA and FDA;

2) Stage 2, EMA and FDA assess the meeting package, the agencies conduct a preparatory bilateral meeting, and then conduct a trilateral meeting with the applicant;

3) Stage 3, EMA and FDA communicate written responses to the applicant.

During and after conclusion of the pilot, each agency will evaluate the benefits and challenges of the program, including the resources required, and determine next steps.

Regulatory Pharma Net (RPN) has successfully supported companies in the early dialogue with EMA and FDA to optimize development in support of the targeted label indication and, to gain regulatory approval. RPN is ready to provide assistance with any new early dialogue procedures introduced by the authorities.

Insights

SCIENTIFIC ADVICE ON MEDICINE REPURPOSING

The European Medicines Agency (EMA) and National Competent Authorities (NCA) are working on a pilot project to offer scientific advice to not-for-profit organisations and academics (institutions and individuals) on repurposing an authorised medicine for a new indication.

The aim of this project is to gather or generate enough evidence to support a new indication with important public health benefits for a medicine whose marketing authorisation holder is otherwise unlikely to undertake the necessary research and regulatory steps.

The medicines that can undergo the repurposing need to have the appropriate eligibility criteria, such as to have a well-established active substance contained in a medicine with a valid marketing authorisation granted in a Member State or in the European Union, to be an authorised medicine (containing the concerned active substance) out of data exclusivity and market protection periods and out of basic patent/supplementary protection certificate (SPC) protection.

Scientific advice fees are waived automatically for eligible academic sponsors repurposing a medicine for an orphan condition. Fees will also be waived for a subset of other applicants based on the expected public health benefits and strength of the evidence in their application.

Sponsors wishing to seek EMA scientific advice should complete the submission form and submit it to EMA by February 28th.

Regulatory Pharma Net (RPN) has successfully supported companies in the optimization of the drug development strategies including assistance in the Scientific Advice procedure. RPN is ready to provide support and prompt updates about any new initiative launched by the authorities.

Feel free to contact us to know more at info@regulatorypharmanet.com

Insights

ADVANCED THERAPY MEDICINAL PRODUCT (ATMP) CLASSIFICATION

The European Medicines Agency (EMA) gives companies the opportunity to request the ATMP classification with the aim to confirm whether a product fulfils the definition of gene therapy medicinal product, somatic cell therapy medicinal product or tissue engineered product.

This procedure applies only to products based on genes, cells or tissues, as starting material, active substance or finished product including when combined with medical devices, bio-materials, scaffolds or matrices, and for which there are doubts as to whether or not they fall within the definition of an ATMP.

The relevant documentation needs to be prepared and sent to EMA, following the specific procedure timelines available on the EMA website.

The EMA’s Committee for Advanced Therapies (CAT) will deliver scientific recommendations on ATMP classification after consultation with the European Commission (EC) within 60 days after the receipt of the request.

The outcome of the assessment of the classification of ATMP will be published by EMA as summary reports.

Regulatory Pharma Net (RPN) has successfully supported companies in the early dialogue with EMA to optimize development in support of the targeted label indication and, to gain regulatory approval. RPN is ready to provide assistance with any early dialogue procedure including the ATMP classification request.

Insights

CRITERIA FOR MARKETING AUTHORIZATION (MA) NUMBER(S) ASSIGNMENT BY AIFA IN THE CONTEXT OF NEW MA/EXTENSION OR VARIATION APPLICATIONS

The Italian Medicines Agency (Agenzia Italiana del Farmaco, AIFA) has provided Marketing Authorization Holders (MAH) with the criteria used to assign different MA numbers during the initial marketing authorization process or when requesting new pack sizes in addition or in replacement of those already authorized. To facilitate future submissions, an explanatory table has been prepared that summarizes the most common cases.

This table includes information on:

  • The different cases identified;
  • When different MA numbers are assigned in the context of the procedure for the initial marketing authorization or variation application to add new pack sizes;
  • When different MA numbers are assigned within the procedure for the variation application to replace packaging;
  • Clarifications or particular cases to consider as exceptions.

Regulatory Pharma Net provides full regulatory assistance during the whole product lifecycle and is ready to support companies on all regulatory needs and to guide them through any new AIFA requirement/procedure.