This guidance provides further information on comparator products used in studies supporting abridged marketing authorisation applications
New rules for January 2021
The UK has left the EU, and the transition period after Brexit comes to an end this year.
This page tells you what you’ll need to do from 1 January 2021. It will be updated if anything changes.
You can also read about the transition period.
The guidance is limited to applications intended for the Great Britain (England, Wales and Scotland) market only. Applications intended for Northern Ireland will be required to comply with EU requirements for comparator products to be used in studies.
Reference Medicinal Product
From 1 January 2021, reference medicinal products (RMP) for new generic medicines or other abridged marketing authorisation applications submitted from this date will be required to comply with the relevant legislation.
Comparator products used in bioequivalence and therapeutic equivalence studies
Comparator products (CPs) used in bioequivalence (BE), pharmacokinetic (PK) and therapeutic equivalence (TE) studies supporting abridged applications should be representative of the RMP supporting the application.
Generally, the CP should be sourced from Great Britain (England, Wales and Scotland). However, if the CP is not sourced from the Great Britain hmarket, the applicant should provide evidence that it is representative of the RMP. This guidance document provides further information on the data required to demonstrate this.
With the aim of facilitating the global development of medicinal products and to avoid unnecessary repetition of clinical BE/TE studies, it may be possible for an applicant to compare the proposed medicinal product with a non-Great Britain sourced CP. The application for the new medicinal product would still be required to refer to an eligible RMP.
The purpose of demonstrating pharmaceutical equivalence and BE against the CP is to provide evidence that the safety and efficacy profiles of the proposed product will be equivalent to that of the RMP and for which safety and efficacy has been demonstrated clinically.
In order to determine the acceptability of this evidence, the licensing authority must be satisfied that a non-Great Britain CP is representative of the RMP and that any differences between these two products would not be therapeutically significant.
The following types of abridged applications are commonly supported by BE or TE studies and are within the scope of this guidance:
- Applications relating to generic medicinal products (regulation 51 HMRs), equivalent to Article 10(1) of EU Directive 2001/83
- Applications relating to certain medicinal products that do not qualify as generics etc (regulation 52 HMRs), equivalent to Article 10(3) of EU Directive 2001/83
This guidance applies to BE, PK and TE studies provided in support of applications made under any of the above legal bases. In case of complex products, it is recommended that we are consulted for specific advice.
The principles may also be applicable to BE, PK or TE studies conducted in support of other applications that are out of the scope of this guidance such as:
- Applications relating to products in well-established medicinal use (regulation 54 HMRs), equivalent to Article 10a of EU Directive 2001/83
- Applications relating to new combinations of active substances (regulation 55 HMRs), equivalent to Article 10b of EU Directive 2001/83
- Variations requiring demonstration of BE to the RMP (e.g. for modified release solid oral dosage forms) (regulation 65C HMRs)
- Extension applications (regulation 65C HMRs)
These principles may be applicable to certain non-clinical studies, for example those provided in support of “hybrid” applications (regulation 52 HMRs).
If the use of a non-Great Britain CP is proposed for applications that are out of the scope of this guidance, early discussion with us is recommended to obtain the relevant regulatory and/or scientific advice.
Applications relating to similar biological medical products (regulation 53 HMRs) are out of scope of this guidance.
This guidance should always be read in conjunction with relevant scientific guidelines and legislative provisions in force in the UK.
The general principles that are applicable are described below. For more specific guidance, especially for more complex dosage forms, it is recommended that the applicant seeks scientific advice from us.
It will be the applicant’s responsibility to demonstrate that any CP authorised and sourced from outside the UK is representative of the RMP.
Source country of non-Great Britain CP
The non-Great Britain CP should be authorised in and sourced from a country with similar scientific and regulatory standards as the UK. Examples would be:
The non-Great Britain CP would normally be expected to be:
- part of the same global marketing authorisation (GMA) as the RMP, or
- marketed in the country of origin through a licensing arrangement with the innovator company or corporate entity that currently markets the medicine in the Great Britain.
The GMA contains the initial authorisation and all variations and extensions. It includes any additional strengths, pharmaceutical form, administration routes or presentations authorised through separate procedures and under a different name, granted to the Marketing Authorisation Holder (MAH) of the initial authorisation.
Identicality vs. representativeness
The non-Great Britain CP used is required to be representative of the RMP, but it is not required to be identical to it. This means that certain minor differences between both products may be accepted if justified, provided this is supported by bridging data (see below).
These differences could include but are not limited to:
- Colour of tablet coatings (assuming no difference in functionality of coat) or capsule shells
- Scorelines, embossings and imprintings on solid dosage forms
- Flavours in liquid dosage forms
- Container closures
Demonstration of identicality of the non-Great Britain CP to the RMP
In cases where the applicant provides written confirmation from the MAH of the non-Great Britain CP that the CP is identical to the RMP, no further analytical data are required.
This written confirmation should confirm the following are identical in both products:
- the route of synthesis of the drug substance(s)
- the drug substance specifications
- the finished product quantitative composition
- the manufacturing process including in-process controls
- the finished product specifications
- the stability data
In cases where identicality can be confirmed, the use of a non-UK CP is also acceptable for more complex formulations.
For the drug substance and finished products specifications, non-significant differences in specifications may be acceptable if fully justified.
Demonstration of representativeness of the non-Great Britain CP to the UK RMP
If a CP authorised and sourced from outside Great Britain is used, the applicant should provide adequate data or information to scientifically justify the relevance of these comparative data and establish an acceptable bridge to the RMP.
As a scientific matter, the type of bridging data needed should always include data from analytical studies that compare all 3 products:
- Between the RMP and the non-Great Britain CP to establish suitability of the latter as CP in BE/TE studies
- Between the proposed medicinal product and the RMP to demonstrate similarity to allow bridging of the RMP data
- Between the proposed medicinal product and the non-Great Britain CP to support the BE/TE studies
Any observed differences in the data have to be duly justified with regard to their potential impact on safety and efficacy.
Only data requirements between the RMP and the non-UK CP are discussed here; for other data requirements see current guidance.
The following information should be provided in Module 1.5.2 of the Common Technical Dossier structure for both the RMP and non-Great Britain CP:
- Name and address of the authorisation holder of the non-Great Britain CP used, the product name, the country of authorisation, country of origin, and authorisation number
- Proof of purchase (batch number, date and place of purchase, expiry date)
- Samples in their original container closure systems should be available upon request
- Product information (Summary of Product Characteristics or equivalent)
- Certificates of analysis (tested according to the proposed specification for the proposed medicinal product)
- The excipients in the formulation of the RMP, when compared to the non-UK CP, should be qualitatively the same. Any differences in excipients would need to be shown to have no effect on safety or efficacy
- If quantitative formulation information is available for these two products it should also show the non-Great Britain CP to be representative of the RMP
The experimental comparison should include the physico-chemical properties and all critical product attributes of the medicinal product; these should include device attributes where appropriate. Where provided, dissolution data should cover the physiological pH range. Reference is also made to existing current guidance.
Number of batches to be tested
For the comparison between the RMP and the non-Great Britain CP, data on at least 3 batches of each product would usually be expected.
In cases of products that exhibit a higher inherent batch-to-batch variability or that are complex, a larger number of batches might be required to establish representativeness.
The precision and accuracy of the analytical methods and the inter-batch variability are critical to deciding if the formulations of the RMP and non-Great Britain CP are representative of each other. The analytical methods and analytical method validation reports used to generate the physicochemical data should be provided to satisfy this requirement.
If the RMP is unavailable
Should the RMP not be marketed in Great Britain and not be available for the relevant comparison, the applicant should contact us for advice.
Acceptability of approach
The overall acceptability of such an approach and the type of bridging data needed will be a case-by-case/product-type decision and is recommended to be discussed upfront with us if one or more of the following applies to the product:
- does not exhibit immediate release of the drug substance
- is not for oral administration
- is made by complex methods of manufacture
- exhibits a narrow therapeutic range or safety margin (for example, careful dosage titration or patient monitoring)
- has a steep dose-response relationship
- a risk of serious undesired effects
- complicated or variable pharmacokinetics (such as nonlinear pharmacokinetics, variable or incomplete absorption)
- an absorption window (i.e. site-specific absorption)
- substantial (e.g. greater than 40%) first-pass metabolism
However, the final determination of the adequacy of the scientific justification and bridging will only be made during the assessment of the application. This will take the safety, efficacy and quality of the medicinal product into account.
If representativeness between the non-Great Britain CP and the RMP cannot be demonstrated, BE and TE studies should be performed against the RMP in Great Britain
For specific queries please contact RIS.NA@mhra.gov.uk