Last week’s round-up; 06 -10 July 2020

167th session of the Ph. Eur. Commission

The Ph. Eur. Commission held its 167th session on the 23 June 2020. Due to restrictions imposed by the COVID-19 pandemic the session was held online to ensure continuity of the work of the Ph. Eur. Commission. During the session, the Commission adopted 75 texts for publication in Ph. Eur. Supplement 10.5, including 64 revised texts and 11 new texts, including a revised text on Parenteral Preparations (0520) which had been significantly modified to update the requirements for testing for visible and subvisible particles, the definitions given and the uniformity requirements. The adopted texts will come into effect on the 1st July 2021. The next session of the Ph. Eur. Commission will take place in November 2020.

EC Health Safety Committee (HSC) meeting summary report

The ECs HSC has issued a brief summary report following its recent audio meeting. In it the EC presented the revised vaccination plan blueprint for COVID-19, including major points on objectives, vaccination coverage, priority groups and number of doses needed for the EU, as well as comments received from the HSC. Other main topics included discussions on risk assessment for resurgence of the virus, exit strategies for lockdowns, impact of deconfinement measure and superspreading events.

The report can be found under this link:

Q&A on ICH M7

The EMA has released a questions & answers document on ICH guideline M7 on assessment and control of DNA reactive (mutagenic) impurities in pharmaceuticals to limit potential carcinogenic risk (step 2b). This document is intended to provide additional clarification and to promote convergence and improve harmonization of the considerations for assessment and control of DNA reactive (mutagenic) impurities. It also provides further insight into the information that should be provided during drug development, marketing authorization applications and/or Master Files. The EMA’s questions & answers document is open for public consultation until the 3rd October 2020.

EUnetHTA launches its COVID-19 related repository of publications and outputs

EUnetHTA, the European Network for Health Technology Assessment, has just launched a repository of related material for the COVID-19 pandemic. This responds to the EC communication on “Guidelines on COVID-19 in vitro diagnostic tests and their performance”, and is linked to the database recently set up by JRC devoted to testing devices. The repository gathers publications by EUnetHTA and by HTA organisations on testing methods and devices, treatment options, and other public health measures relevant to COVID-19.

A link the repository can be found here:

EMA issues a new medicines agency network strategy to 2025.

Recognising that the current challenges we face go well beyond the remit of medicines regulation, and will need to be addressed by the EU and its Member States as a whole and individually. Learning from this experience presents an opportunity to shape the future role of medicines regulation nationally and at the EU level, and enhance the partnership approaches that we need to ensure that we are proactively positioned to deal with similar emergencies.A new European medicines agencies network strategy to 2025 has been issued by EMA setting the direction for the Network’s response. It focuses on areas such as; Availability and accessibility of medicines; Data analytics, digital tools and digital transformation; Innovation; Antimicrobial resistance and other emerging health threats; Supply chain challenges; Sustainability of the Network and operational excellence.

The document and a public consultation on the strategy have been launched on the EMA site under this link

Lapatinib product-specific bioequivalence guidance

The second draft of the EMA’s Lapatinib film-coated tablet 250 mg product-specific bioequivalence guidance is available for public consultation until the 30th September 2020. A second public consultation of the guidance is underway as the first draft was significantly revised in response to the comments received during the first public consultation.

EMA issues first edition of the Clinical Trial Information Systems (CTIS) Newsletter

As reported last week, EMA has now issued the first edition of the CTIS Newsletter as we move towards the go-live of this eagerly awaited IT system. It is envisaged to be issued on a twice yearly basis.

The newsletter in full can be found under this link

Ph. Eur. updates

The following information regarding Ph. Eur. Supplement 10.3 has been published: · The contents of the supplement. The document includes a list of new and revised texts which will be implemented by the 1st January 2021, a list of corrected texts which should be taken into account by the 31st August 2020, as well as texts whose titles have changed and deleted texts. · New reagents have been added to the list of reagents published in chapter 4 of the Ph. Eur. · Comments concerning revised texts published in Supplement 10.3. This document contains details of the technical modifications that have been made to the revised texts.

Further details concerning these Ph. Eur. updates may be viewed here:

EMA endorsement of joint statement on prioritisation of COVID-19 clinical trials

The EMA has endorsed a joint statement on prioritisation of COVID-19 clinical trials published by the International Coalition of Medicines Regulatory Authorities (ICMRA). Its underlying aim is to step up global collaboration, facilitation and evaluation of COVID-19 treatments. Within the statement, key characteristics of clinical trials that enable accelerated approval are described. These include robust methodology and endpoints, realistic recruitment and completion capacity, and testing of repurposed drugs or those at advanced stages of development. Treatments addressing the most severe complications of COVID-19 and those with simpler routes of administration and treatment duration are also highlighted for priority. (more…)

Last week’s round-up; 15 – 19 June 2020

Ph.Eur. Supplement 10.3

The EDQM has published the contents of the Ph.Eur. Supplement 10.3. The list includes several new texts, such as the new monograph for testing bacterial endotoxins using recombinant factor C (2.6.32), as well as many revised general chapters and monographs. These new and revised texts will be implemented by 1st January 2021. Several corrected texts are also included in the list and these should be implemented by 31st August 2020. The list also includes texts that will be deleted from the Ph.Eur.

The entire list of contents of Supplement 10.3 may be viewed here: 

New EMA Bioequivalence Guidance for Levothyroxine Tablets and Abiraterone Tablets

The EMA has released the following draft product-specific guidelines: • A new bioequivalence guideline for Levothyroxine tablets 12.5 mcg, 25 mcg, 50 mcg, 75 mcg, 100 mcg (and additional strengths) and 200 mcg. • An updated bioequivalence guideline for Abiraterone tablets, which includes the addition of the 500 mg strength.

These draft guidelines are open for public consultation until 30th September 2020.

EMA, EC and Health Canada Confidentiality Arrangement

EMA, the European Commission and Health Canada signed a confidentiality arrangement in 2007. This was renewed in 2013 and 2020. The most recent changes introduced in 2020 include references to personal data legislation and to ensure the permanent validity of the arrangement.

The full document is available here:

FDA testing methods to detect nitrosamine impurities in Metformin

The FDA has published two analytical methods that regulators and pharmaceutical companies may use to detect nitrosamine impurities in metformin APIs and drug products: • LC-HRMS method: an LC-MS method for the detection of NDMA in metformin drug substance and drug products. • LC-ESI-HRMS method: an LC-HRMS method for the measurement of amounts of eight nitrosamine impurities in metformin drug substance and drug products. Users are required to validate these methods if the resulting data is used to support a quality assessment of the API or drug product or regulatory submissions: 

Global regulators work towards alignment

The International Coalition of Medicines Regulatory Authorities (ICMRA) convened its regular meeting on 12 June 2020 to discuss high-level policy and regulatory approaches in response to COVID-19. They agreed that a clear distinction between exploratory clinical trials and confirmatory studies with investigational or repurposed medicines for treatment of COVID-19 is critical for prioritisation. Regulators also shared concerns about the discontinuation of clinical trials globally and the growing number of underpowered studies that might not generate the robust data required for decision-making. Full details of the output from the meeting can be found here

EDQM companion list of training materials for vaccines

In order to support vaccine developers during the COVID-19 pandemic, the EDQM has made the Ph.Eur. quality standards for vaccines freely accessible through an online database on the EDQM website. Further to this, the EDQM has now also compiled a companion list of training materials related to vaccines. The document is intended for COVID-19 vaccine developers, including universities and small and medium-sized enterprises, with the intention to fast track their understanding of the Ph. Eur. and to help them to apply the relevant texts. The EDQM’s companion list includes hyperlinks to various presentations that were originally given at an EDQM Training Session on Biologicals held in February 2020 and any content of specific interest for vaccine developers is highlighted.

The list is not exhaustive and will be reviewed and updated as required.

EMA and HMA news:  Mandate of the European Innovation Network

EMA and HMA have issued an update to the document describing the mandate of the European Innovation Network (EU-IN), which seeks to coordinate and integrate views of national agency innovation offices and EMA’s Innovation Task Force for the early identification of promising developments, integration in the EU adaptive pathways, facilitate national designation of small and medium enterprises (SMEs) and to investigate the establishment of harmonised criteria for borderline products.

The full mandate can be found here:

Last week’s round-up; 01 -05 June 2020


We are delighted to have Michael Edwards join the team at Real Regulatory as a Senior Regulatory Consultant. Michael has worked in regulatory affairs since 2000, having held positions in the UK medicines competent authority, a couple of CRO/consultancies, a couple of small/medium pharmaceutical companies, and as an independent consultant, as well as taking some time out during that time to do post-graduate research and complete a PhD investigating the vascular bioactivity in vitro of the phenolic phytochemicals anthocyanins, and their in vivo degradation products or metabolites, in the Department of Nutrition at Norwich Medical School. His first degree was BSc Pharmacology with Toxicology (First) at King’s College London, including a year-long industrial placement in a large pharmaceutical company research centre. His regulatory experience includes clinical phase through post-marketing authorisation, national and European procedures. Michael will be a valuable asset to our company and to our clients.


At a recent virtual meeting of the ICH Assembly, the ICH has announced that Turkey’s Medicines and Medical Devices Agency (TITCK) is now one of its regulatory members and that Lebanon’s Ministry of Public Health (MOPH) is now a new observer. During the meeting, the Council also announced that the following guidelines have reached Step 4 in the ICH process: M8 electronic Common Technical Document (eCTD) v4.0 guideline; S11 Nonclinical Safety Testing in Support of Development of Paediatric Pharmaceuticals guideline; and S5(R3) Guideline on Revision of S5 Guideline on Detection of Toxicity to Reproduction for Human Pharmaceuticals. The Council has also announced that the Q3C(R8) guideline on residual solvents, which is currently under revision to include the permitted daily exposures for three new impurities, has reached Step 2 of the ICH process, and that the 4Q(R1) Common Technical Document (CTD) guideline will be revised.

Further updates given by the ICH during the Assembly may be found at the following link:


Joint procedural information is available from EMA and the FDA for medicine developers planning to submit a PIP to EMA and an iPSP, to the FDA, respectively, for a COVID-19 vaccine or treatment, the document can be found under this link

The joint document aims to make it easier for developers to submit paediatric development plans simultaneously to the regulators, to help speed up the development and approval of COVID-19 treatments and vaccines. Both agencies are encouraging medicine developers to submit PIPs and iPSPs early.


The FDA has just released 26 new and 43 revised draft product-specific guidances on the development of generic drugs. The documents are intended to clarify the FDA’s recommendations on demonstrating bioequivalence of generics to the corresponding reference products. The new drafts include recommendations to support ANDAs for generic versions of the acute myeloid leukemia drug gilteritinib, the PARP inhibitor talazoparib, the HIV-1 treatment dolutegravir/lamivudine, fish oil triglycerides, subcutaneous buprenorphine and extended-release metformin. The updated guidance documents include altered recommendations for generic versions of type 2 diabetes drugs dapagliflozin, dapagliflozin and saxagliptin, the renal failure treatment ferric citrate and transdermal buprenorphine.


The European Commission’s updated ‘Annex to the European Commission guideline on Excipients in the labelling and package leaflet of medicinal products for human use’ is effective from 22 November 2019. The guidance describes the information that should be available in the package leaflet on excipients that are known to have a recognised action or effect. In order to ensure compliance with the new guidance, marketing authorisation holders are required to submit a type IB variation within three years from the publication of the revised Annex. HPRA has pointed out that applicants should also be aware that some of the updates included in the Annex were also published in the previous version of the document, therefore, applicants are requested to submit the relevant variations by 9/10/2020.


New measures for all UK arrivals have been announced, including a 14 days’ self-isolation for anyone entering the UK, apart from a “short” list of exemptions. At moment of writing, these measures are due to come into effect on 8 June, although this could change given the backlash from the UK travel industry. The “short list of exemptions” is not really all that short, and amongst the many listed are including the following of note to the pharmaceuticals and clinical trials sectors: qualified persons and responsible persons for human medicines, clinical trials and pharmacovigilance quality assurance inspectors for human medicines sponsors and essential persons needed for clinical trials or studies The new measures can be found at:

The list of exemptions can be found at:


Horseshoe crabs’ blood has long been used in the pharmaceutical industry to detect the presence of bacterial endotoxins, causing concern amongst animal rights groups who are pushing for the use of synthetic alternatives. The USP Microbiology Expert Committee had proposed the inclusion of synthetic recombinant factors in ‘Chapter 85 Bacterial Endotoxins’. Based on public comments received, this will not happen. Instead, a new general chapter will be drafted, to provide guidance on the qualification of alternative tests by demonstrating comparability: <1085.1> Use of Recombinant Reagents in the Bacterial Endotoxins Test – Photometric and Fluorometric Methods Using Recombinantly Derived Reagents The proposed new general chapter should be available for public consultation by November 2020. More information may be found at the following link:

This matches the approach taken by Ph. Eur. in 2016 when ‘Chapter 5.1.10 Guidelines for Using the Test for Bacterial Endotoxins’ was updated. Ph. Eur. is further ahead as it has already published a new section ‘2.6.32 Test for bacterial endotoxins using recombinant factor C’ in supplement 10.3, effective from 1 January 2021.


The European Medicines Agency (EMA), European Commission and Heads of Medicines Agencies have updated their ‘Questions and answers on regulatory expectations for medicinal products for human use during the covid-19 pandemic’. The guidance document now includes a new section on temporary flexibilities for good manufacturing practice (GMP) and good distribution practice (GDP) that pharmaceutical companies may employ during the pandemic to ensure an adequate supply of medicines used to treat COVID-19 patients. A new section on the suspension of on-site inspections of plasma collection centres has also been included. Temporary flexibilities related to the duties of the responsible person (RP), the use of new equipment or newly authorized storage and distribution sites, and deviations from normal practice are also discussed in the document. Further information is available at the following link:

Last week’s round-up; 11 – 15 May 2020


The GCP IWP has published its meeting dates and a list of its priorities for 2020. The priorities of the group will continue with an EU focus and maintaining international relationships. However, of particular interest is the upcoming work to create and finalise a series of Q&As on the following noteworthy topics Q&A on inspectors’ access to patients’ medical records/data when the access of EEA inspectors to medical information is not clearly stated in the Informed Consent Form (ICF). Q&A on sponsor oversight of activities subcontracted to third parties. Q&A on expectations for provision of written information to clinical trial subjects in relation to new information requiring re-consent. Q&A on confidentiality undertaking of EU/EEA inspectors.

The full entirety of the work plan can be found under this link:


The EMA’s Dasatinib product-specific bioequivalence guidance is currently under revision. A revised draft guideline has been released for public consultation and comments will be received until 31st August 2020. The current adopted guidance concerns bioequivalence testing requirements for Dasatinib 20, 50, 70, 80, 100 and 140 mg film-coated tablets. The draft revised document also includes requirements for Dasatinib 10 mg/ml suspension and the additional requirement for a fed study for both dosage forms.


CMDh has updated the following guidance: – RMS validation checklist for human medicinal products in DCP – Data requested for New Applications in the MRP/DCP which are not stated in the current EU legislation and/or in Volume 2B, Presentation and format of the dossier Common Technical Document (CTD) and/or in the EEA approved Guidelines/Recommendation papers – Data requested for Variations and/or Renewal Applications in the MRP/DCP which are not stated in the current EU legislation and/or in Volume 2B, Presentation and format of the dossier Common Technical Document (CTD) and/or in the EEA approved Guidelines/ Recommendation papers – CMDh Best Practice Guide on the use of the electronic Common Technical Document (eCTD) in the Mutual Recognition and Decentralised Procedures – CMDh Questions & Answers on implementation of outcome of Art. 31 referral on angiotensin-II-receptor antagonists (sartans) containing a tetrazole group – Practical guidance for procedures related to Brexit for medicinal products for human use approved via MRP/DCP.

The updated documents (most with tracked changes) may be viewed here:


The MHRA has recently adopted a flexible and pragmatic approach to regulatory requirements for medical device clinical investigations during the COVID-19 pandemic. This is documented in Guidance “Medical devices clinical investigations (CIs) during the coronavirus (COVID-19) outbreak”. The updated guidance, which now includes a new section relating to COVID 19, details regulatory flexibilities introduced for ongoing and new submissions for CIs.

There is an expedited process in place for CIs directly relating to COVID-19. However, it states that if MHRA is unable to reach a decision by the new internal deadline, the 60-day assessment period still applies, and the applicant cannot start the study until they have received a final decision from the MHRA or until 60-days after the notification. The update also states that the MHRA is working on a process for studies where there is both a medicine and a medical device to allow for a single application via the Clinical Trials Unit to ensure a smooth and fast assessment of both elements.

The guidance document which can be accessed via this link: 


The EMA’s Committee for Medicinal Products for Human Use (CHMP) has recommended the precautionary suspension of all ranitidine medicines in the EU due to the presence of low levels of the potentially carcinogenic impurity, N-nitrosodimethylamine (NDMA).

Many European national authorities had already recalled ranitidine medicines as a precautionary measure during the EMA’s review. There is some evidence which shows that NDMA may form from the degradation of ranitidine itself over the course of its shelf-life, however, it is still unclear whether the impurity can also be formed from ranitidine inside the human body.

The CHMP recommendation will be forwarded to the European Commission, which will issue a final legally binding decision applicable in all EU Member States.


The 166th European Pharmacopoeia (Ph.Eur.) Commission session was still held electronically despite the restrictions and lockdowns brought on by the COVID-19 pandemic. During the Ph.Eur. Commission session, 91 texts, including 11 new texts, were adopted and will be published in the Ph. Eur. Supplement 10.4 and effective from 1st April 2021.

The new texts include general chapter 5.28 on Multivariate Statistical Process Control and monographs for Regorafenib Tablets, Riociguat Tablets, Rivaroxaban Tablets and Sorafenib Tablets. A list of the adopted texts will soon be available on the EDQM website. Monographs for sartan drug substances have also been revised to add a requirement for risk assessment of the manufacturing process and to replace interim limits for NDMA and NDEA with a 0.03 ppm limit. The next Ph. Eur. Commission session is due to take place on 23rd June 2020.

Last week’s round-up; 4 – 8 May 2020


EMA has published an overview of how the Agency will accelerate its regulatory procedures so that marketing authorisations of safe, effective and high-quality COVID-19 related medicines can be granted as soon as possible. The rapid procedures described in the inventory can accelerate every step of a medicine’s regulatory pathway and the Agency is fully mobilised to deliver these fast-track assessments in the shortest possible timeframes while ensuring robust scientific opinions are reached. The text of the press release can be found under


In particular, EMA will review applications for a PIP, deferrals or waivers for treatments and vaccines for COVID-19 in an expedited manner, in order to speed up an approval. The compliance check can also be expedited, if needed. For these products,

      1. No pre-specified PIP submission deadlines;
      2. Review of a PIP is reduced to a minimum of 20 days;
      3. EMA decision following a review is reduced to 2 days;
      4. Compliance check can be reduced to 4 days.


There is also a possibility for the developer to provide a focused scientific documentation, to be agreed on a case-by-case basis. Full details can be found under this link


EMA’s Scientific Advice Working Party (SAWP) has updated meeting dates in September 2020. The full tabulations under link include deadlines for submissions for scientific advice, protocol assistance, qualification of biomarkers and parallel consultation EMA/EUnetHTA requests.


An updated draft of the impurities guideline for residual solvents, ICH Q3C (R8), has been published. ICH Q3C recommends acceptable amounts for residual solvents in pharmaceuticals, and this draft only contains information on three additional solvents: 2-methyltetrahydrofuran, cyclopentyl methyl ether, and tertiary-butyl alcohol.

The Permitted Daily Exposure (PDE) for each has been set at 50mg/day, 15mg/day and 35mg/day respectively. The document is open for consultation until 30 July 2020. Once agreed upon, this data will be integrated into a complete ICH Q3C (R8) guideline document:


The EMA has released a new Clinical pharmacology and pharmacokinetics Question & Answer. The new Q&A (4.12) clarifies the EMA’s position on the demonstration of bioequivalence for the anticoagulant drug dabigatran etexilate. The following clarifications are provided:

        • A bioavailability study under fed conditions may not replace the comparative bioavailability study with proton pump inhibitors.
        • Dissolution tests at various pHs may not replace the comparative bioavailability study with proton pump inhibitors.
        • Demonstration that the effect of proton pump inhibitor on the bioavailability of dabigatran is equal or less than for the innovator product, is not sufficient.


Bioequivalence should also be demonstrated in the presence of proton pump inhibitors. Further details are available here:


A promising new model of the gastrointestinal tract could speed up drug development. Created by MIT engineers, the model tests how well drugs are absorbed in the small intestine and should help oral drug formulation. The model uses pig intestinal tissue, and more closely replicates the human intestine than the currently used approach of testing these formulations in human colorectal cancer cells.

The system can be used to test up to 10,000 samples per day and its results have been found to be 90% accurate, through tests carried out using 60 drugs already approved by the FDA. In contrast, tests using colorectal cancer cells have a near 50% percent accuracy:


The FDA has released draft guidance explaining how combination product developers can demonstrate that their emergency-use injectors will reliably deliver drugs as intended in a life-threatening emergency. The draft guidance specifically applies to emergency-use injectors that are prefilled or co-packaged with emergency drugs or biologics. The document expands on FDA’s ‘Technical Considerations for Pen, Jet, and Related Injectors for Use with Drugs and Biological Products’ guidance that was released in 2013.

The “FDA recommends that emergency-use injectors include design control specifications for successful injection reliability of 99.999% with a 95% level of confidence”, which ensures that the emergency-use injector performance is as safe and reliable as possible as well as feasible. The guidance also provides a model for establishing reliability and recommendations for completing a reliability report to submit premarket submissions for these products.


The European Commission has released some new questions and answers on regulatory expectations for medicinal products for human use during the COVID-19 pandemic. The document includes the following guidance (questions 2.2 – 2.4) on the manufacturing and importation of finished products and active pharmaceutical ingredients:


The EC has released the above guidance in order to prevent disruptions in the availability of medicines during the pandemic.