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Giuliana Miglierini

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Comments to the SOTEU 2023 from EFPIA

Health was a marginal topic of the State of the Union address the President of the European Commission Ursula von der Leyen gave to the EU Parliament on 13 September 2023. Her speech was focused on the strategical goal to build a geopolitical Union and on currently open challenges, including the green and digital transition and climate changes. President von der Leyen mentioned the starting of the Health Union and the goal of a greater independence in crucial sectors like energy, chips and raw materials among achieved results. Among the ongoing legislative priorities in the remaining time are a series of Clean Transition Dialogues with industry. The Commission also appointed Mr Mario Draghi to prepare a report of the future of European competitiveness.

The European Federation of Pharmaceutical Industry Associations (EFPIA) positively commented  the SOTEU speech. According to EFPIA, the future challenge is to reconcile the Commission’s commitment do whatever it takes to keep the EU’s competitive edge with the policy in practice. A goal that should include the ongoing revision of the pharmaceutical legislation, those current form might further damage the competitiveness of the pharma sector, according to EFPIA.

Source: European Commission, EFPIA

EMA and EUnetHTA21 to collaborate on a permanent basis

The three years collaboration between EMA and the European Network for Health Technology Assessment consortium (EUnetHTA 21) closed on 16 September 2023. The date marks also the start of the transition period that will lead to the full implementation of the HTA Regulation on 1 January 2025. During the next 15 months, the new framework for Parallel EMA/HTA Scientific Advice will be in place to support developers requesting the involvement of HTA bodies when applying for EMA scientific advice. This temporary procedure will lead to the issuing of a scientific advice letter by EMA and individual written recommendations from participating HTA bodies. Other priorities identified by EMA to prepare to the HTA regulation include defining a single evidence plan to facilitate development programmes, harmonising views on the strength of the evidence, and involving patients, clinical experts and other relevant experts in decision-making

“We are very proud to see that our cooperation has now been enshrined into European law. The experience gained provided essential technical input to shape the new legislation. In fact, we continue our joint work and will do this on a new footing, with more participants, additional responsibilities and high expectations from stakeholders”, said Niklas Hedberg, Chair of the EUnetHTA 21 Consortium Executive Board.

Source: EMA

EP’s ENVI Committee voted for a more efficient treatment and reuse of urban wastewater

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The report of the Environment Committee (ENVI) of the European Parliament on the new rules for the collection, treatment and discharge of urban wastewater was approved on 20 September 2023 (60 votes in favour, 10 against and 6 abstentions).

Among the main concepts highlighted by the report is the importance of reusing treated wastewater from all urban wastewater treatment plants, especially in water-stressed areas, as well as in industrial processes and district and cooling systems. MEPs voted in favour of a improved monitoring of various elements at the inlets and outlets of urban wastewater treatment plants, as well as that of various public health parameters (i.e. viruses, bacteria, antimicrobial resistance, etc).

The ENVI Committee supports a system of extended producer responsibility (EPR) targeting medicinal products for human use and cosmetic products, deemed to be the main sources of micro-pollutants in urban wastewater. According to the report, EPR schemes may be complemented by up to 20% national financing for the upgrade of urban wastewater treatment plants in order to avoid unintended consequences on the availability, affordability and accessibility of vital products, in particular medicines.

Source: European Parliament

EFPIA, white paper on the use of relevant endpoints in oncology in HTA

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Relevant endpoints in oncology are used in clinical trials to assess the most meaningful treatment outcomes for patients, including patient-reported or disease-free survival in certain metastatic forms, pathological complete response, etc.
A white paper published by EFPIA takes stock of the value of these types of endpoints and the challenges for their implementation, from the perspective of health technology assessment (HTA) bodies and payers. The white paper is based on a literature review and a dozen qualitative interviews conducted with various types of stakeholders.

The paper discusses the current standard of assessment, overall survival (OS) from the time of patient assignment to the clinical trial to death, and its limitations, and then goes on to analyse the possible types of endpoints relevant in oncology. The latter measure effects of oncology treatment that go beyond survival alone, and are thus proposed to support better evaluation of new products by HTAs and payers for the purpose of pricing and reimbursement. Oncology-relevant endpoints can also, in some cases, support an assessment of treatment efficacy, for example with reference to time without disease progression. In contrast to overall survival, they can also capture data on the patient’s quality of life, or on particular events such as disease relapse or the occurrence of metastases. Another difference from the traditional approach emphasised by EFPIA’s paper is the fact that relevant endpoints in oncology usually refer to a single line of therapy (e.g. first-line surgery), in contrast to overall survival which takes into account all subsequent lines with which the patient has been treated. This could, according to EFPIA, facilitate a clearer measurement of therapeutic benefit and patient relevance, as many confounding factors could be avoided.

The white paper also indicates that relevant endpoints in oncology should always be considered by tumour type and stage, both from the point of view of the patient and the treating physicians. The difficulties identified in the adoption of this type of measurement refer to uncertainties due to a lack of evidence and a mismatch between physicians/patients and regulatory and HTA bodies regarding the relative value to be attributed to specific outcomes for each treatment setting.
The white paper also outlines some actions that EFPIA believes could help resolve these uncertainties, starting with the creation of a portfolio of fit-for-purpose endpoints by tumour type and stage. Evidence should also be gathered to support the value of these endpoints – both standalone and surrogate – and key outcomes by treatment setting and the methodologies used to collect them should be standardised.

EMA’s survey on communication

EMA published the results of its fourth communication perception survey, run in September 2022. The overall appreciation was very high, as 93% of respondents find EMA’s communication important or indispensable. Suggested improvements include the means used, the availability of translations and accessibility. Among the less known EMA’s communications tools are the Agency’s YouTube channel, Twitter and the AskEMA service. EMA’s communication materials are disseminated mainly internally within respondents’ organisations (82%), or externally through social media (36%) or the organisations’ websites (34%).

More than a half of respondents (56%) read EMA communications at least once a week. Perception of the quality of EMA’s communication is positive for the majority (72%) of respondents. As for transparency, 35% indicated EMA was more transparent that other regulatory authorities, 27% indicated the same level of transparency and 6% a lower level; a further 32% of respondents did not express an opinion.

The engagement with stakeholders was deemed sufficient by 57% of respondents and better compared to other regulators by a further 25%. A positive opinion was also expressed as for EMA’s efficiency in coordinating important public information within the EU regulatory network through the early notification system (ENS) and distribution of lines-to-take (LTT) on key issues.

Source: EMA

UK, international life sciences investment are dropping

The ninth annual Life Sciences Competitiveness Indicators (LSCIs) published by UK’s government shows a substantial decline in the estimated value of inward life sciences foreign direct investment in UK in 2022 compared to 2021 (£1 billion vs £1.9 billion, -47%). The country also dropped to the ninth place in the ranking of comparators, from the second in 2021. On the over hand, India, Switzerland and Ireland are among the countries that saw a substantial increases over the same period.

The overall value of equity finance raised in 2022 also decreased to £3.3 billion (£7.2 billion in 2021). The same dynamic characterised the number of initial public offerings (IPOs) and associated amount raised. In 2022, the UK had £7.1 million raised through 3 IPOs compared to £751.5 million over 11 IPOs in 2021. In this case, similar patters have been observed also for comparator countries due to the impact of the pandemic and broader economic factors.

Source: UK government, Life sciences competitiveness indicators 2023

EMA’s position paper on AI in the pharmaceutical life cycle

The increasing relevance of artificial intelligence (AI) in the regulatory field has been acknowledged by the publication of a draft reflection paper describing EMA’s current views on the use of AI and machine learning (ML). The draft reflection paper is open to public consultation up to 31 December 2023; it is part of the joint HMA-EMA Big Data Steering Group (BDSG) initiatives to develop the European Medicines Regulatory Network’s capability in data-driven regulation. The document discusses possible uses of AI and ML along the entire life cycle of medicinal products.

For example, AI/ML modelling approaches might be of help in reducing the need of animal studies in preclinical development, or the selection of patients to be recruited for clinical trials. AI/ML may also support the analysis of data to be included in regulatory dossiers. In the post-marketing phase, they may prove useful to support adverse event report management and signal detection. According to the reflection paper, a human-centric approach should guide all development and deployment of AI and ML. The use of AI in the medicinal product lifecycle should always occur in compliance with the existing legal requirements, consider ethics and ensure due respect of fundamental rights.

European Council, new trade agreement signed with New Zealand

On 27 June, the Council adopted a decision on the signature of the free trade agreement (FTA) with New Zealand. The EU and New Zealand are expected to sign the agreement later on. The FTA will liberalise and facilitate trade and investment, as well as promote a closer economic relationship, which will open significant economic opportunities for companies and consumers on both sides. The EU is New Zealand’s third-biggest trade partner. Bilateral trade in goods between the two partners has risen steadily in recent years, reaching almost €9,1bn in 2022. Once the agreement enters into force, bilateral trade is expected to grow by up to 30% thanks to this deal, with EU annual exports potentially growing by up to €4.5 billion. EU investment into New Zealand has a potential to grow by up to 80%. The deal can cut some €140 million a year in duties for EU companies from the first year of application.

Source: https://www.consilium.europa.eu/en/press/press-releases/2023/06/27/eu-new-zealand-council-adopts-the-decision-to-sign-free-trade-agreement

Bulgaria and Saudi Arabia authorities joined PIC/S

The PIC/S Committee has invited Bulgaria’s Bulgarian Drug Agency (BDA) and Saudi Arabia’s Saudi Food and Drug Authority (SFDA) to join the PIC Scheme. Bulgaria / BDA will become PIC/S’ 55th Participating Authority and Saudi Arabia / SFDA PIC/S 56th Participating Authority as from 1 July 2023.

BDA submitted a complete membership application in August 2018. The PIC/S assessment was combined with a Canadian MRA assessment and EMA JAP audit. A paper assessment was carried out followed by a joint tripartite PIC/S – EMA – Canada MRA on-site assessment visit which took place in February 2023, after establishment of the new system for the GMP Inspectorate of BDA [following a JAP audit in 2018]. The assessment report was finalised in April 2023. The Audit team recommended to the Committee to accept the PIC/S membership application of BDA, which was endorsed by the PIC/S Sub-Committee on Compliance (SCC). At its meeting in Geneva on 11-12 May 2023, the PIC/S Committee then unanimously accepted the membership of BDA in PIC/S as from 1 July 2023.

Source: https://picscheme.org/en/news

New mutual recognition agreements: EU-US for veterinary medicines and the MHRA international initiative

In today’s EU-US Trade and Technology Council, the US and the EU reached an agreement to mutually recognise the results of pharmaceutical Good Manufacturing Practices (GMP) inspections for veterinary products. This means that veterinary products manufactured in the EU can now be exported to and marketed in the US without a prior US inspection of the EU manufacturers, and vice versa. This follows an earlier, similar decision for human medicines. The US Food and Drug Administration (FDA) has already recognised the capacity of 16 EU Member States to carry out pharmaceutical GMP inspections of veterinary products. At the same time, the EU has recognised the US FDA as an equivalent authority to carry out these inspections. The US assessment of the remaining competent authorities of the Member States continues according to a schedule agreed with the US. The target date for completion of the assessment of all EU authorities has been set for July 2024.

New regulatory recognition routes for medicines will be established using approvals from Australia, Canada, the European Union, Japan, Switzerland, Singapore and the United States, the Medicines and Healthcare products Regulatory Agency has announced today. This means that patients will have access to safe and effective medicines that have been approved by trusted regulatory partners in other countries. The new international recognition routes will sit alongside the MHRA’s own unique innovation pathway for medicines which integrates early regulatory advice with health technology assessment advice. These recognition routes, which have been facilitated by existing international partnerships such as those developed through the Access Consortium and Project Orbis, mark the start of a new international recognition framework for medicines that will be in place by the first quarter of 2024.

Source:
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_2986
https://www.gov.uk/government/news/mhra-announces-new-recognition-routes-to-facilitate-safeaccess-to-new-medicines-with-seven-international-partners

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