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Advanced Therapy Medicinal Products

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Background

Advanced therapy medicinal products (ATMPs) such as gene and cell-based therapies are highly innovative medicines that provide new opportunities to treat conditions with high unmet medical need. It is often described that the characteristics of advanced therapies are considerably different from more conventional medicines such as small molecules or biologicals. Differences lay in their mechanism of action, live raw materials, intended function and manufacturing. In addition, ATMPs consist mostly of live cell and tissue materials.

The number of ATMPs stranded during (clinical) development is unknown but perceived as considerable given the contrast between high clinical activity and low number of products reaching advanced (regulatory) development milestones. Research has highlighted that ATMPs experience several clinical, regulatory, and economical challenges, more so than more conventional medicinal products. It is also observed that most ATMP-developers are not companies but hospitals, academic facilities, and so-called small and medium enterprises (SMEs); higher compared to the small-molecule and biotechnology industry.

RSNN has previously brought together stakeholders that are involved in ATMP development and discussed hurdles in bringing advanced therapies to patients, emphasizing the role of the national hospital exemption (HE) procedures. However, substantial regulatory questions remain unanswered, in and outside of HE. Examples are safety and quality concerns due to loss of centralized overview of ATMP development (in part due to HE), implications of acceptance of less complete evidence packages for marketing authorization (e.g., for conditional marketing authorization) for downstream assessment, constructive interactions between stakeholders, organizational learning. These questions require additional, tailored investments in terms of research and discussions to answer them.

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