Development and Regulatory Status of Biosimilar Product: Brazil Marcelo Moreira Brazilian Health Surveillance – ANVISA Seoul, July, 10 2014 Development of Biological Products Regulation Law 6360/1976 – general regulation about medicines, including biological products RDC 80/2002 – first regulatory act specific for biological products. Same approach for new products and copies RDC 315/2005 – second regulation regarding biological products. Same approach for new products and copies, with more detailed informations RDC 55/2010 – current regulation. Specific approach for copies of biologicals Biological Products licensed in Brazil Vaccines; Hiperimmune sera; Blood products; Biomedicines: medicines obtained from biological fluids or animal tissues; medicines from biotechonological procedures. Monoclonal antibodies; Medicines containing live, attenuated or dead microorganims; Probiotics; Alergens. Regulatory acts concerning biological products RDC 47/09 e 60/12 Package insert RDC 71/09, RDC 168/02 RDC 61/12 Label RDC 81/08 Import Lei 6360/76 Dec. 8.077/13 RDC 55/10 Registration RDC 49/11 e 24/13 Post-approval RDC 46/00 Blood products RDC 233/05 Allergenics RDC 323/03 Probiotics RDC 50/11 e 25/13 Stability RDC 234/05 RDC 38/10 Quality control RDC 17/10 Good Manufacturing Practices Portaria 174/96 Antivenom serums Classification of Biological Products I – Biological product: is the biological drug that is not new or is known, containing molecule with known biological activity, already licensed in Brazil and that has undergone all stages of manufacturing RDC 55/2010 Classification of Biological Products II – New Biological Product: is the biological product containing molecule with known biological activity, not yet licensed in Brazil and that has undergone all stages of manufacturing RDC 55/2010 Classification of Biological Products III – Comparator Biological Product: is the biological product already licensed by Anvisa based on submission of a full dossier and that has already been sold in Brazil RDC 55/2010 Classification of Biological Products New Biological Product • not yet licensed in Brazil Biological Product • already licensed in Brazil Regulatory Pathways New biological product Biological product Individual route of development Complete dossier Complete dossier Comparative Phase III Non innovative biological product 9 Comparability development Comparability exercise Quality, Safety, Efficacy Biosimilar Individual Development Pathway It is the regulatory route that can be used to license a biological product, in which it’s necessary to present full data on the development, production, quality control and nonclinical & clinical data to demonstrate the quality, efficacy and safety of the product Individual Development Pathway Production and quality control data must meet the quality standards already established for the product to be licensed The extent of the nonclinical studies may be reduced, considering factors like molecule complexity, level of structure characterization, extent of characterization of the product’s level of impurity, mechanism of action of molecule, toxicity potential and therapeutic index Individual Development Pathway The extrapolation of indications is not applicable for biological products licensed by the individual development pathway Phase I and II clinical trials are not necessarily comparative Individual Development Pathway Phase III studies will be always necessary and must be comparative to new biological product When available, phase IV studies must be presented Comparability Development Pathway It is the regulatory route that can be used to license a biological product, in which the comparability exercise in terms of quality, efficacy and safety was used between the developed product and the comparator biological product Comparability Development Pathway The same comparator must be used in all stages of the comparability exercise If the comparator biological product is not available in the national market, the same product can be purchased in international market Comparability Development Pathway Non clinical and clinical data can be reduced Extrapolation of safety and efficacy data for other therapeutic indications of the biological product licensed through the comparability development pathway will be established through specific guides Comparability Development Pathway Requirements for extrapolation of data A sensitive test model has to be used, which has to be able to detect potential differences between the biosimilar and the comparator The mechanism of action and/or involved receptor(s) must be the same Safety and immunogenicity have to be sufficiently characterized General Considerations Clinical trials must be conducted with biological product submitted to registration Clinical trials must be approved by National Regulatory Authority in which country clinical trial was carried on All clinical trials conducted in Brazil must have previous authorization of Anvisa General Considerations The clinical trials reports must follow the document called “Guide for elaboration of clinical trials report to registration and post-registration changes of biological products” For both pathways is mandatory to present: immunogenicity study report; risk management plan; pharmacosurveillance plan. Guidelines Comparability exercise Guideline http://s.anvisa.gov.br/wps/s/r/lg Guidelines Heparin Guideline http://s.anvisa.gov.br/wps/s/r/lg Guidelines Interferon Alpha Guideline http://s.anvisa.gov.br/wps/s/r/lg Guidelines Guideline for elaboration of Clinical Study Reports http://s.anvisa.gov.br/wps/s/r/lg Thank you! Web Site: http://www.anvisa.gov.br Call Center: 0800 642 9782. Free call from any state of Brazil. Working hours from 7am to 7 pm, Monday to Friday, except holidays. Contact us: http://www.anvisa.gov.br/institucional/fal econosco/FaleConosco.asp http://portal.anvisa.gov.br/wps/portal/an visa/ouvidoria Twitter: @anvisa_oficial E-mail: [email protected] Phone number: + 55 (61) 3462 55 91
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