tribulations of going global for a mid-sized company · case study 13 japan - local testing local...
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ן Helping thousands of patients across
87 countries
ן FY 2013 revenue: €3.4 billion
ן More than 8 500 employees globally
ן R&D Spend: 25% of revenue
ן Listed on Euronext
UCB: A patient-centric biopharma leader
2
Focusing on severe diseases in
Immunology and the Central Nervous System
Stephanie, living with rheumatoid arthritis
Biotech Product Development
Vial
PFS
Device
4
MARKET ENTRY -
COMPETE
FOR PATIENTS WHO
CANNOT SELF-INJECT
AND/OR REQUIRE
CLOSE MONITORING
DIFFERENTIATE
PATIENTS WHO
WANT CONTROL
BECOME ICONIC
PATIENTS WHO
WANT TO GET ON
WITH IT
Product
Portfolio Life Cycle
Management
D
e
v
e
l
o
p
m
e
n
t
Biotech Product Development
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Evolution over Time
Drug Substance Drug Product
Increased
number of
Markets
Increased
Demand
Increased
complexity
Final form
I I
I
I I
I I I
LCM
Biotech Product Development
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Increasing complexity during development of product
Regulatory restrictions
■ Some countries don’t accept more than one Drug Substance site (or only recently changed)
■ Some countries have different Drug Product sites associated with different applications
■ Long approval timelines and big differences in assessments
■ Limited guidance from local Health Authorities available, compliance requirements and point of
focus perceived differently in different area’s
Mid sized company restrictions
■ Only affiliates in main countries, need to use partners for most ROW countries
■ Partners work for multiple companies
■ Difficult to retrieve feedback, at least one extra layer in the communication (sometimes more)
Case study
8
China - Regulatory Framework
Regulatory process in China is lengthy process
■ Only accepts one Drug Substance and one Drug Product manufacturer
• Change in regulation has been discussed for a long time
■ Need to perform clinical trial first, clinical trial approval can take up to 3 years
■ Between submission and approval, many changes applied:
• Drug Substance process changes
• Analytical method changes
• Specification changes
■ No formal process for submitting changes during clinical trial approval or when clinical trial is
ongoing
■ Need to keep supply in line with the initial submission (over 3 years ago)
Case Study
9
China - Supply Constraints
“Dinosaur” Process to be maintained @ the manufacturing site
Need to plan production campaign per process
Reduced Batch Output
Specific testing methods may still be required
“Dinosaur” Process to be maintained in inventory
Batch scale may not be adequate anymore leading to potential discard
Although Demand is low, no possibility to phase out
Expected to manufacture locally
Case study
10
Japan - Regulatory Framework
Implementation restrictions
■ Change needs to be submitted as a prior approval change (PCA)
• Requirements for documentation different from other countries
■ Once approved the change needs to be implemented in the product released to Japan immediately
• Approval can take anywhere between 6-12 months
• Need to have product available with and without “change” to be able to supply Japanese market
■ Implementation can be defined in many ways
■ AQL doesn’t exist in Japanese regulations 100%inspection - no defect
Case Study
11
Japan - Development Strategy
Global vs Local Product
A subset of a
ROW process
2 different
Products
1 Product taking
JP requirements
into account from
the start
Case Study
13
Japan - Local Testing
Local Testing to be performed on BioPharma Final Presentation
BEST CASE: Incoming ID test must be performed in JP, provided MOU country will support release
testing
FULL TESTING required should any activity such as packaging and/or distribution
are made out of a non-MOU country
Even if the company can demonstrate that the operations performed in the non-MOU country do
not impact the product quality manufactured and tested in the MOU country, the testing will be re-
performed in Japan.
How to deal with local testing results?