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Gilead Sciences, Inc. 333 Lakeside Drive Foster City, CA 94404 [email protected] Historical Timeline Regulatory Impact WHO Guidelines 1906 - No exportation restrictions from FDA 1938 - FDA implemented definition of drugs and ceased exports 1986 - Export regulations hindered from globalization 1996 - FDA executes Export Reform and Enhancement Act (EREA) to allow exportation 1998 - World Health Organization establishes guidelines CPPs are critical documentation for many global regulatory filings for drug products in countries without a rigorous drug regulatory authority infrastructure. Requirements Certifying (exporting) country - “USA” Requesting (importing) country - “Mongolia” Name, pharmaceutical form, and composition of product “Harvoni ® (ledipsavir 90 mg/sofosbuvir 400 mg) tablets” Information on registration and marketing status “Harvoni ® tablets are approved and are currently marketed in the United States” Include current product information “Approved shelf-life for Harvoni ® tablets is 24 months and should be stored below 30C” Gilead prepares a cover letter with NDA number and information about market approval and manufacturers to the FDA. Gilead also includes the original NDA approval letter with the documentation. Gilead provides two sets of attachments to the FDA, one for the country and one for FDA’s records. Attachments include: Formulation Composition, Bottle Label, and Package Insert. Gilead pays $175.00 for certificate application. Regulatory Affairs: Application Process of Certificate of Pharmaceutical Product (CPP) Jason Kerr Summer Intern Session August 2015 FDA receives certificate application. FDA can take up to 20 government working days to respond Returned due to missing information Rejected due to manufacturing facilities not to cGMP compliance Denied due to drug product not compliant with regulations Accepted FDA will then fill out a certificate with an official ribbon and send it back to Gilead with an expiration of 24 months. Acknowledgements Special thanks to the Regulatory Affairs - Chemistry, Manufacturing, and Controls (CMC): Erin Watson, Michael K. Lee, and Denise Aycox. Mongolia receives CPP and begins reviewing the drug application. Mongolia will send an approval letter to Gilead. Gilead will ship drug product and distribute prescription drugs throughout the country. With a globalizing economy, Ministry of Health (MoH) require a more efficient means of receiving essential information systematically regardless of country of origin. Countries lacking a strong regulatory infrastructure heavily rely on CPPs for their submission. CPP’s ensures that imported products are made at cGMP facilities. Whenever possible, the importing country will verify drug standards with their own national laboratories. Application Process Gilead decides to market product to Mongolia, which requires a CPP in their submission filings FDA produces official certificate and sends it back to Gilead Gilead prepares proper documentation for the FDA FDA processes and verifies applicant’s information Once submission is ready, Gilead submits CPP to Mongolia’s submission for approval Timeline If required, the certificate is sent to the Mongolian embassy for authentication

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Gilead Sciences, Inc.

333 Lakeside Drive

Foster City, CA 94404

[email protected]

Historical Timeline

Regulatory Impact WHO Guidelines

1906 - No exportation restrictions from FDA

1938 - FDA implemented definition of drugs and ceased

exports

1986 - Export regulations hindered from globalization

1996 - FDA executes Export Reform and Enhancement

Act (EREA) to allow exportation

1998 - World Health Organization establishes guidelines

CPPs are critical documentation for many global

regulatory filings for drug products in countries without a

rigorous drug regulatory authority infrastructure.

Requirements

Certifying (exporting) country - “USA”

Requesting (importing) country - “Mongolia”

Name, pharmaceutical form, and composition of product

“Harvoni® (ledipsavir 90 mg/sofosbuvir 400 mg)

tablets”

Information on registration and marketing status

“Harvoni® tablets are approved and are currently

marketed in the United States”

Include current product information

“Approved shelf-life for Harvoni® tablets is 24

months and should be stored below 30C”

Gilead prepares a cover letter with NDA number and information

about market approval and manufacturers to the FDA.

Gilead also includes the original NDA approval letter with the

documentation.

Gilead provides two sets of attachments to the FDA, one for the

country and one for FDA’s records.

Attachments include: Formulation Composition, Bottle Label, and

Package Insert.

Gilead pays $175.00 for certificate application.

Regulatory Affairs: Application Process of

Certificate of Pharmaceutical Product (CPP)

Jason Kerr Summer Intern Session

August 2015

FDA receives certificate application.

FDA can take up to 20 government working days to respond

Returned due to missing information

Rejected due to manufacturing facilities not to cGMP

compliance

Denied due to drug product not compliant with regulations

Accepted

FDA will then fill out a certificate with an official ribbon and send

it back to Gilead with an expiration of 24 months.

Acknowledgements Special thanks to the Regulatory Affairs - Chemistry, Manufacturing, and Controls (CMC): Erin Watson, Michael K. Lee, and Denise Aycox.

Mongolia receives CPP and begins reviewing the drug

application.

Mongolia will send an approval letter to Gilead.

Gilead will ship drug product and distribute prescription

drugs throughout the country.

With a globalizing economy, Ministry of Health (MoH)

require a more efficient means of receiving essential

information systematically regardless of country of

origin.

Countries lacking a strong regulatory infrastructure

heavily rely on CPPs for their submission.

CPP’s ensures that imported products are made at

cGMP facilities.

Whenever possible, the importing country will verify

drug standards with their own national laboratories.

Application Process

Gilead decides to

market product to

Mongolia, which

requires a CPP in their

submission filings

FDA produces official

certificate and sends it

back to Gilead

Gilead prepares proper

documentation for the

FDA

FDA processes and

verifies applicant’s

information

Once submission is

ready, Gilead submits

CPP to Mongolia’s

submission for approval

Tim

elin

e

If required, the

certificate is sent to the

Mongolian embassy for

authentication