CRED 8 Presentations
01/07/2024
Common objections regarding WEU applications
• The applicant has not demonstrated that the active substance in the claimed therapeutic indication has been in well-established medicinal use within the Union for at least ten years, with recognised efficacy and an acceptable level of safety (see Chapter 1 of Volume 2A of the NtA). Medicinal use outside the Union cannot be used. Waiver for this requirement is not possible, e.g. for diseases that are not an endemic disease in the Union. Reference to treatment Guidelines not sufficient. Actual data on use in the Union needed • Bridging data to the products described in literature have not been provided. Bridging should be direct data versus product described in literature related to the pivotal studies or comparison with a product representative for product used in literature. In case no information is available on the composition used in literature an application based on WEU might not be feasible • The applicantuses data from literature which stillfall under data exclusivity
The Organisation for Professionals in Regulatory Affairs
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Generic/hybrid applications-important points to take into account:
Legal basis chosen e.g. different salt compared to reference product: 10(1) or 10(3)? Choice Reference product in all MSs (should belong to the same GMA for RMS and CMSs) Abridged applications of chemically manufactured generics of innovator products (recombinant manufacturing process); e.g. teriparatide, which legal basis is appropriate Non- EU reference products (NB UK not an EU MS anymore!) not acceptable also bio-equivalence study should be performed with reference product sourced in the EU Whether data exclusivity period has expired NB: Not possible to change the legal basis/Reference product after start of the procedure!
The Organisation for Professionals in Regulatory Affairs
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