Biosimilars: Regulatory Outlook
Biosimilars offer a chance to improve access to, and reduce spending on, life-saving biologic therapies. But could regulators do more to support the market? While experts believe significant regulatory progress has been made in recent years, clarity is distinctly lacking on certain issues, such as interchangeability and naming.
FirstWord’s Biosimilars: Regulatory Outlook provides insight and opinion on why. This 64 page report gives in-depth and candid views on what eight industry and biosimilar experts see as the areas that require the most attention within biosimilar regulation.
You’ll discover expert concerns and views on critical, market-shaping issues, and understand how they see biosimilar regulations evolving in the future in areas such as indication extrapolation, interchangeability, naming, terminology and the amount and type of clinical data needed to support regulatory approvals.
“The EMA has set the tone when it comes to biosimilar regulation. A pathway that, quite rightly, is seen as the gold standard pathway around the world.” EU Biosimilars Expert.
Answering key questions
Get answers to key questions about the regulation of biosimilars, and how the area is set to evolve:
About FirstWord
FirstWord is an innovative industry intelligence leader serving over 240,000 Pharma and MedTech professionals worldwide. FirstWord offers a range of products and services designed to help your company gain a competitive edge by making key business decisions with speed and confidence.
FirstWord Pharma PLUS is a personalised and comprehensive intelligence service delivering up-to-the-minute pharma news, insight, analysis and expert views of importance to your company’s success.
FirstWord Reports deliver timely, need-to-know intelligence about your products, your competitors and your markets. Covering biosimilars, market access, medical affairs, sales & marketing, technology and therapy areas, FirstWord Reports provide expert views and intelligence on the challenges facing pharma today.
FirstWord’s Biosimilars: Regulatory Outlook provides insight and opinion on why. This 64 page report gives in-depth and candid views on what eight industry and biosimilar experts see as the areas that require the most attention within biosimilar regulation.
You’ll discover expert concerns and views on critical, market-shaping issues, and understand how they see biosimilar regulations evolving in the future in areas such as indication extrapolation, interchangeability, naming, terminology and the amount and type of clinical data needed to support regulatory approvals.
“The EMA has set the tone when it comes to biosimilar regulation. A pathway that, quite rightly, is seen as the gold standard pathway around the world.” EU Biosimilars Expert.
Answering key questions
Get answers to key questions about the regulation of biosimilars, and how the area is set to evolve:
- Approval timelines: The European Medicines Agency (EMA) takes – on average – 18 months to review a biosimilars application, while the U.S. Food and Drug Administration (FDA) took just ten months to approve Sandoz’s Zarxio (filgrastim-sndz); is this EMA’s timeline fixed, or can FDA-like improvements be made?
- Analytical vs. Clinical? Will the FDA’s focus on analytics continue to have an influence on global biosimilar regulations, or will agencies continue to adopt a more clinically focused approach like the EMA?
- Naming: The FDA, EMA and World Health Organization (WHO) all have different proposals for naming conventions – what are the merits of each and how will this influence market dynamics?
- Interchangeability: What’s needed to demonstrate that a biosimilar is interchangeable? What will be the burden of proof? And will there be any commercial advantage? How this plays out in the future could ultimately come down to cost savings.
- Extrapolation of indications: An area of fierce and continuing debate, with regulators taking differing views on the same product: will a consensus view emerge?
- Emerging markets: Achieving wider patient access has led to a thriving “non-comparable biologics” market in certain emerging markets; will these markets continue to focus on patient access or align themselves with western regulatory models to gain wider access?
- Different paths to a common goal: Understand how differing regulators are approaching biosimilar regulation and know how this could impact product development strategies.
- What’s in a name? Confusion in naming conventions in the U.S. and Europe are compounded by a further proposal from the WHO. Understand the significance of this and how it might impact the industry.
- Interchangeability: While the FDA has a clear remit to approve biosimilars as interchangeable, it has yet to publish guidance. In contrast, European countries make their own decisions on interchangeability and substitution, with the EMA having no remit in this area. The impact of switching to biosimilars can be significant, as demonstrated by developments in Denmark and Norway with biosimilar infliximab, but will it be the case in other markets?
- Extrapolation across indications: While the scientific principles off indication extrapolation are accepted by most of the leading regulatory agencies, it’s the application that sometimes differs. These differences of opinion create uncertainty for industry and have significant commercial implications.
- It’s not just about the U.S. and Europe: Get an international perspective by knowing how biosimilar regulation is evolving in other markets, including Australia, Japan and Canada, and evaluate the progress in developing robust biosimilar regulations in markets such as India, South Korea and Brazil.
- Will biosimilars ever be approved without clinical trial data to support the application, or will regulators always need some form of clinical data to satisfy any residual uncertainty?
- Non-comparable biologics have found favour in certain emerging markets and patient needs are being met; could these markets move to meet the more stringent standards of the EU and U.S. and be considered biosimilars, or will ensuring patient access always be the number one priority?
- Are regulators supporting the industry in achieving biosimilar approvals, or could they do more?
- Is it now easier or more difficult to get approval for biosimilars, and does this vary by class of product and type of molecule?
- What are the key differences in regulatory approaches around the world, and how are they impacting regulatory and clinical strategies?
- Hoss Dowlat is Vice President Regulatory Affairs, Global Strategy at PharmaBio Consulting.
- Cecil Nick is Vice President (Biotechnology) at Parexel Consulting.
- Gillian Woollett is Senior Vice President at Avalere
- Florian Strohmaier is Director of Regulatory Affairs & Quality Management at a pure play biosimilar company based Germany.
About FirstWord
FirstWord is an innovative industry intelligence leader serving over 240,000 Pharma and MedTech professionals worldwide. FirstWord offers a range of products and services designed to help your company gain a competitive edge by making key business decisions with speed and confidence.
FirstWord Pharma PLUS is a personalised and comprehensive intelligence service delivering up-to-the-minute pharma news, insight, analysis and expert views of importance to your company’s success.
FirstWord Reports deliver timely, need-to-know intelligence about your products, your competitors and your markets. Covering biosimilars, market access, medical affairs, sales & marketing, technology and therapy areas, FirstWord Reports provide expert views and intelligence on the challenges facing pharma today.
1. EXECUTIVE SUMMARY
2. OBJECTIVES AND METHODOLOGY
3. HISTORICAL REVIEW OF BIOSIMILAR REGULATION
4. BIOSIMILAR REGULATORY OUTLOOK
5. EUROPE; BIOSIMILARS REGULATION IN THE EUROPEAN UNION HAS SHAPED GLOBAL THINKING, AND CONTINUES TO INFLUENCE REGULATORY POLICY AROUND THE WORLD
6. US: WHILE BEING LATE TO THE GAME, THE US HAS MADE SIGNIFICANT PROGRESS IN RECENT YEARS, BUT CHALLENGES REMAIN
7. JAPAN: UNDER THE JAPANESE BIOSIMILAR GUIDELINES, DEVELOPERS NEED TO MAKE HEAVIER INVESTMENT TO GET A BIOSIMILAR APPROVED COMPARED TO GENERIC DRUGS
8. THE IMPLEMENTATION OF BIOSIMILAR GUIDELINES ACROSS OTHER MARKETS HAS GENERALLY FOLLOWED THE
9. EMA’S MODEL, WITH SOME NOTABLE EXCEPTIONS
10. AUSTRALIA FOLLOWS EUROPE’S LEAD AND IMPLEMENTS THE EMA’S GUIDELINES EN BLOC
11. BRAZIL LEANS ON THE WORLD HEALTH ORGANIZATION’S SIMILAR BIOTHERAPEUTIC PRODUCT GUIDANCE FOR INSPIRATION
12. CANADA BORROWS ELEMENTS FROM THE EUROPEAN GUIDELINES AND PROVIDES INSPIRATION FOR THE
13. FDA’S GUIDELINES
14. CHINA BOWS TO INTERNATIONAL PRESSURE AND CREATES A NATIONAL BIOSIMILARS PATHWAY, BUT MAINTAINS ACCESS AS AN IMPORTANT ELEMENT
15. INDIA’S GUIDELINES GENERATE CONTROVERSY DUE TO TIMING AND CONTENT
16. KOREA’S EARLY FORAY INTO DEVELOPING GUIDELINES SEEN AS SUPPORTIVE OF LOCAL INDUSTRY
17. RUSSIA REMAINS WITHOUT A FORMAL BIOSIMILAR PATHWAY, BUT GUIDELINES EXPECTED IN THE NEAR TERM
19. CURRENT REGULATORY SITUATION AND KEY CONTROVERSIES
20. BIOSIMILAR APPROVALS IN KEY DEVELOPED AND EMERGING MARKETS
21. EUROPE LEADS THE WAY WITH 21 BIOSIMILAR APPROVALS AND MORE EXPECTED WITHIN THE NEXT 6-12 MONTHS
22. HAVE THE ‘GREEN SHOOTS’ OF THE US BIOSIMILARS MARKET FINALLY BEEN SEEN? 28 JAPAN’S BIOSIMILARS MARKET GATHERS PACE WITH SEVERAL APPROVALS SINCE 2009
23. OTHER KEY DEVELOPED AND EMERGING MARKETS 31 REGULATORY CONTROVERSIES, CONCERNS AND CONFUSION
24. DESPITE THE EMA’S STATUS AS THE LEADING BIOSIMILAR REGULATOR, IMPROVEMENTS IN REVIEW TIMELINES ARE NEEDED
25. UNNECESSARY CLINICAL DATA IS BEING GENERATED BY SOME BIOSIMILAR DEVELOPERS, WITH POTENTIAL ETHICAL RAMIFICATIONS (LILLY/GLARGINE)
26. SOME CLASSES OF COMPLEX PRODUCT ARE BEING REGULATED AS BIOLOGICS IN SOME REGIONS, BUT NOT AS BIOLOGICS IN OTHER REGIONS
27. THE EXTRAPOLATION OF INDICATIONS IS BEING HANDLED DIFFERENTLY BY DIFFERENT REGULATORY AUTHORITIES, DESPITE THE SAME DATA SET BEING REVIEWED
28. DIFFERENCES OF OPINION BETWEEN REGIONAL AND NATIONAL REGULATORY AGENCIES ON THE SUBJECT OF SWITCHING PATIENTS FROM THE BRAND TO THE BIOSIMILAR CONTINUE TO EMERGE
29. TRANSITION PROVISIONS WITHIN THE BPCIA REMAIN A CAUSE OF CONFUSION AND CONCERN FOR THE INDUSTRY
30. FUTURE REGULATORY CHALLENGES IN THE BIOSIMILARS MARKET
31. ANALYTICS: ADVANCES IN NON-CLINICAL ANALYTICS COULD REDUCE THE AMOUNT OF CLINICAL DATA NEEDED, BUT WON’T REMOVE THE NEED FOR IT COMPLETELY
32. EMERGING MARKETS: THESE REMAIN A KEY ELEMENT OF FUTURE PHARMA GROWTH, BUT WILL LOWER REGULATORY STANDARDS CREATE ISSUES?
33. EXTRAPOLATION OF INDICATIONS: WHILE BASED ON SOLID SCIENCE, CONCERNS AND QUESTIONS CONTINUE TO DIVIDE OPINION
34. INTERCHANGEABILITY IN THE US: FIVE KEY QUESTIONS 55 WILL AN INTERCHANGEABLE BIOSIMILAR EVER BE APPROVED IN THE US? 55 WHAT WILL BE THE BURDEN OF PROOF? 56 WILL THERE BE ANY COMMERCIAL BENEFIT FOR INTERCHANGEABLE BIOSIMILARS? 35. DO INTERCHANGEABLE BIOSIMILARS MAKE SENSE IN ALL INDICATIONS? 58 HOW CAN THE FDA ENSURE THAT INTERCHANGEABILITY STANDARDS ARE MAINTAINED AFTER THE APPROVAL OF AN INTERCHANGEABLE BIOSIMILAR?
36. NAMING: CONVENTIONS IN RELATION TO BIOSIMILAR NAMING ARE LIKELY TO DIVERGE, THEREBY CREATING CONFUSION
37. TERMINOLOGY: GUIDANCE ON THE USE OF THE WORD ‘BIOSIMILAR’ IS NEEDED TO ENSURE THE EFFORTS OF THE EMA AND FDA ARE NOT TAKEN FOR GRANTED
38. APPENDIX
39. CONTRIBUTORS
2. OBJECTIVES AND METHODOLOGY
3. HISTORICAL REVIEW OF BIOSIMILAR REGULATION
4. BIOSIMILAR REGULATORY OUTLOOK
5. EUROPE; BIOSIMILARS REGULATION IN THE EUROPEAN UNION HAS SHAPED GLOBAL THINKING, AND CONTINUES TO INFLUENCE REGULATORY POLICY AROUND THE WORLD
6. US: WHILE BEING LATE TO THE GAME, THE US HAS MADE SIGNIFICANT PROGRESS IN RECENT YEARS, BUT CHALLENGES REMAIN
7. JAPAN: UNDER THE JAPANESE BIOSIMILAR GUIDELINES, DEVELOPERS NEED TO MAKE HEAVIER INVESTMENT TO GET A BIOSIMILAR APPROVED COMPARED TO GENERIC DRUGS
8. THE IMPLEMENTATION OF BIOSIMILAR GUIDELINES ACROSS OTHER MARKETS HAS GENERALLY FOLLOWED THE
9. EMA’S MODEL, WITH SOME NOTABLE EXCEPTIONS
10. AUSTRALIA FOLLOWS EUROPE’S LEAD AND IMPLEMENTS THE EMA’S GUIDELINES EN BLOC
11. BRAZIL LEANS ON THE WORLD HEALTH ORGANIZATION’S SIMILAR BIOTHERAPEUTIC PRODUCT GUIDANCE FOR INSPIRATION
12. CANADA BORROWS ELEMENTS FROM THE EUROPEAN GUIDELINES AND PROVIDES INSPIRATION FOR THE
13. FDA’S GUIDELINES
14. CHINA BOWS TO INTERNATIONAL PRESSURE AND CREATES A NATIONAL BIOSIMILARS PATHWAY, BUT MAINTAINS ACCESS AS AN IMPORTANT ELEMENT
15. INDIA’S GUIDELINES GENERATE CONTROVERSY DUE TO TIMING AND CONTENT
16. KOREA’S EARLY FORAY INTO DEVELOPING GUIDELINES SEEN AS SUPPORTIVE OF LOCAL INDUSTRY
17. RUSSIA REMAINS WITHOUT A FORMAL BIOSIMILAR PATHWAY, BUT GUIDELINES EXPECTED IN THE NEAR TERM
19. CURRENT REGULATORY SITUATION AND KEY CONTROVERSIES
20. BIOSIMILAR APPROVALS IN KEY DEVELOPED AND EMERGING MARKETS
21. EUROPE LEADS THE WAY WITH 21 BIOSIMILAR APPROVALS AND MORE EXPECTED WITHIN THE NEXT 6-12 MONTHS
22. HAVE THE ‘GREEN SHOOTS’ OF THE US BIOSIMILARS MARKET FINALLY BEEN SEEN? 28 JAPAN’S BIOSIMILARS MARKET GATHERS PACE WITH SEVERAL APPROVALS SINCE 2009
23. OTHER KEY DEVELOPED AND EMERGING MARKETS 31 REGULATORY CONTROVERSIES, CONCERNS AND CONFUSION
24. DESPITE THE EMA’S STATUS AS THE LEADING BIOSIMILAR REGULATOR, IMPROVEMENTS IN REVIEW TIMELINES ARE NEEDED
25. UNNECESSARY CLINICAL DATA IS BEING GENERATED BY SOME BIOSIMILAR DEVELOPERS, WITH POTENTIAL ETHICAL RAMIFICATIONS (LILLY/GLARGINE)
26. SOME CLASSES OF COMPLEX PRODUCT ARE BEING REGULATED AS BIOLOGICS IN SOME REGIONS, BUT NOT AS BIOLOGICS IN OTHER REGIONS
27. THE EXTRAPOLATION OF INDICATIONS IS BEING HANDLED DIFFERENTLY BY DIFFERENT REGULATORY AUTHORITIES, DESPITE THE SAME DATA SET BEING REVIEWED
28. DIFFERENCES OF OPINION BETWEEN REGIONAL AND NATIONAL REGULATORY AGENCIES ON THE SUBJECT OF SWITCHING PATIENTS FROM THE BRAND TO THE BIOSIMILAR CONTINUE TO EMERGE
29. TRANSITION PROVISIONS WITHIN THE BPCIA REMAIN A CAUSE OF CONFUSION AND CONCERN FOR THE INDUSTRY
30. FUTURE REGULATORY CHALLENGES IN THE BIOSIMILARS MARKET
31. ANALYTICS: ADVANCES IN NON-CLINICAL ANALYTICS COULD REDUCE THE AMOUNT OF CLINICAL DATA NEEDED, BUT WON’T REMOVE THE NEED FOR IT COMPLETELY
32. EMERGING MARKETS: THESE REMAIN A KEY ELEMENT OF FUTURE PHARMA GROWTH, BUT WILL LOWER REGULATORY STANDARDS CREATE ISSUES?
33. EXTRAPOLATION OF INDICATIONS: WHILE BASED ON SOLID SCIENCE, CONCERNS AND QUESTIONS CONTINUE TO DIVIDE OPINION
34. INTERCHANGEABILITY IN THE US: FIVE KEY QUESTIONS 55 WILL AN INTERCHANGEABLE BIOSIMILAR EVER BE APPROVED IN THE US? 55 WHAT WILL BE THE BURDEN OF PROOF? 56 WILL THERE BE ANY COMMERCIAL BENEFIT FOR INTERCHANGEABLE BIOSIMILARS? 35. DO INTERCHANGEABLE BIOSIMILARS MAKE SENSE IN ALL INDICATIONS? 58 HOW CAN THE FDA ENSURE THAT INTERCHANGEABILITY STANDARDS ARE MAINTAINED AFTER THE APPROVAL OF AN INTERCHANGEABLE BIOSIMILAR?
36. NAMING: CONVENTIONS IN RELATION TO BIOSIMILAR NAMING ARE LIKELY TO DIVERGE, THEREBY CREATING CONFUSION
37. TERMINOLOGY: GUIDANCE ON THE USE OF THE WORD ‘BIOSIMILAR’ IS NEEDED TO ENSURE THE EFFORTS OF THE EMA AND FDA ARE NOT TAKEN FOR GRANTED
38. APPENDIX
39. CONTRIBUTORS
