Requirement | Regulatory authority | ||||
WHOa-c | EMA (EU)d,e | FDA (US)f-i | |||
Approval pathway/ development | • Reference product (RP) must be licensed in region/ country where biosimilar approval is sought • Biosimilar authorization is based on a stepwise comparability exercise o Quality studies: head-to-head comparisons of quality and heterogeneity (e.g., physicochemical, biological, immunochemical properties); documented manufacturing process; stability studies o Non-clinical studies: Pharmacokinetic (PK), Pharmacodynamic (PD), and toxicological o Clinical studies: clinical comparability exercise (i.e., PK/PD studies followed by pivotal clinical studies to show comparable safety/effectiveness/ immunogenicity) • Varying amounts of data may be requested by individual national regulatory authorities • Post-marketing surveillance is required |
• Abbreviated approval pathway o EU-wide marketing authorization granted via centralized EMA procedures o Requires manufacturer submission of a Marketing Authorization Application (MAA) o MAA evaluated by EMA’s Committee for Medicinal Products for Human Use, Pharmacovigilance and Risk Assessment Committee, and Biologics/Biosimilar Working Parties • Data required from stepwise comprehensive comparability studies o Pharmaceutical and comparative quality studies o Comparative non-clinical studies o Comparative clinical studies of safety/efficacy, PK/PD, and immunogenicity • If biosimilarity is shown, safety/efficacy findings from clinical trials of the RP may be used to support MAA o Allows for shorter and less costly drug development program • Post-marketing surveillance is required |
• Abbreviated approval pathway o Created by the Biologics Price Competition and Innovation Act under the Affordable Care Act in 2010 (§351[k], Public Health Service Act)j o Requires manufacturer submission of a Biologics License Application (BLA) o BLA evaluated by the FDA’s Centers for Drug/Biologics Evaluation and Research • Data required from 3 study types o Analytical studies (e.g., physicochemical, functional properties) o Non-clinical studies (e.g., toxicology) o Clinical studies (e.g., PK, PD, immunogenicity) • If biosimilarity is shown, safety/efficacy findings from clinical trials of the RP may be used to support BLA o Allows for shorter and less costly drug development program • Post-marketing surveillance is required |
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Extrapolation | • If biosimilarity is shown, the biosimilar may obtain approval for other clinical indications of the RP, even if not directly assessed in clinical trials • Scientific justification required |
• If biosimilarity is shown, the biosimilar may obtain approval for other clinical indications of the RP, even if not directly assessed in clinical trials • Scientific justification required |
• If biosimilarity is shown, the biosimilar may obtain approval for other clinical indications of the RP, even if not directly assessed in clinical trials • Scientific justification required |
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Interchangeability/ switching/ substitution |
• No guidance • Practices to be defined by national authorities |
• No guidance • Practices to be regulated by legislation in individual EU countries |
• Interchangeability requires data from 3 transitions from reference to biosimilar product • Switching requires data from 1 transition from RP to biosimilar |
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Nomenclature | • Reference and related biosimilar products share same nonproprietary name (i.e., the International Nonproprietary Name [INN]) • Reference and related biosimilar products will have unique “biological qualifier” (BQ) added to the INN (2015 proposal) o BQ = 4 random lower-case consonants • Example (fictitious) o SBP = replicamab-jnzt o RBP = replicamab-kngx |
• Reference and related biosimilar products have distinct proprietary names • Reference and related biosimilar products share same nonproprietary name (i.e., INN) • Example (actual) o Biosimilar = Remsima® (infliximab) o RP = Remicade® (infliximab) • Proprietary names and batch numbers should appear on product packaging |
• Reference and related biosimilar products have distinct proprietary names • Reference and related biosimilar products have a non-proprietary proper name that combines a shared core name plus a unique suffix o Core name = the name selected by the US Pharmacopeial Convention for the active substance (same for biosimilar and RP) o Suffix = 4 random lower-case letters attached to the core name by a hyphen (distinct for biosimilar and RP) • Example (fictitious) o Biosimilar = replicamab-jnzt o RP = replicamab-kngx |