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Giuliana Miglierini

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Reactions to the Critical Medicines Act

The European Commission’s proposal for the Critical Medicines Act aims to improve EU manufacturing capacity for critical medicines through strategic projects. Public procurement is the tool chosen to encourage reliable supply chains, also through collaborative procurement among EU countries. International partnerships may help reduce dependence on a single or limited number of suppliers.

EFPIA reacted to the proposal asking for more clarity on identifying circumstances where collaborative procurement options would improve access beyond existing national pricing and reimbursement pathways. The Act would also need to respond effectively to fragmented national contingency stock requirements. Systematic impact assessments evaluating the extent of the legislation on food, chemicals, and the environment would also be useful to assess how they affect the security of supply of critical medicines.

EuropaBio welcomed the recognition of biomanufacturing as a solution to strengthen the EU’s autonomy and supply security, highlighting also the lack of a proper impact assessment. Medicines for Europe asked for a real procurement reform, including MEAT criteria and multi-winner tendering, an investment partnership between the EU, Member States and the industry, and more EU solidarity on strategic EU reserves and national stockpiling mandates.

EMA’s recap of the activities performed in 2024

The European Medicines Agency released its first data on the activities performed in 2024. Recommendations for marketing authorisation refer to 114 medicines, 46 based on new active substances never authorised before in the EU. Six products received the PRIME designation, and 15 were designed as orphan medicines. EMA also issued five negative opinions, and recommended the approval of one ATMP. Four products were approved under exceptional circumstances; EMA performed three accelerated assessments and eight conditional marketing approvals. The year closed with 8 withdrawn applications.

Among the more innovative products are the first medicine to treat early Alzheimer’s disease (Leqembi – lecanemab), the first needle-free, nasal spray form of adrenaline to treat allergic reactions (Eurneffy – epinephrine), the first treatment for tumours associated with von Hippel-Lindau disease (Welireg – belzutifan), and two new antibiotic medicines (Emblaveo – aztreonam/avibactam). As for new vaccines, 2024 saw the recommendation for approval of the one against Chikungunya disease and a new mRNA vaccine against infections by respiratory syncytial virus (RSV). Oncology represented again the therapeutic area with more recommendations for approval (28), together with the biosimilar products (28).

Source: EMA

Towards the implementation of the electronic product information

A new step forward towards the implementation of electronic product information (ePI) was made with the publication in December 2024 of the ePI pilot report on the experience gained from the creation of ePI during regulatory procedures for EU human medicines.

The pilot was run from July 2023 to August 2024 by EMA together with the NCAs of Spain (AEMPS), Denmark (DKMA), the Netherlands (MEB) and Sweden (MPA), envisaging the ePI’s creation and publication in live regulatory procedures. 

According to the results, the EU regulatory system proved to be generally prepared for the introduction of ePI. A phased implementation in regulatory procedure could thus be planned, even if additional functionalities and integration with current IT systems would be needed. According to EMA, this task will be carried out in 2025. 

The phased approach to implementation should begin with voluntary adoption for centrally authorised products, to then progressively expand to nationally authorised products based on Member States’ readiness and available resources.

Source: EMA

EMA/HMA revision of the guidance on commercially confidential information

A complete revision guidance on the identification of commercially confidential information (CCI) and personal data in marketing authorisation applications for human medicines was published in December 2024 by EMA and HMA (Heads of Medicines Agencies). The initial guidance was released in 2012. Extensive transparency when disclosing information, both in response to access-to-documents requests and in the proactive publication of data once a medicine is The revision is based on the experience EMA and the national competent authorities have gained over the years.

The new guidance on CCI aligns with current practices, ensures a harmonised approach across all authorities, and reflects the principles applied in the context of EMA’s proactive clinical data publication. As a general rule, the great majority of MAA’s data is not considered CCI. Exceptions may refer to information about manufacturing, facilities or equipment and some contractual arrangements between companies. According to the updated guideline, general information related to quality is now mostly considered releasable. It also provides an indication of how personal data will be protected if it can lead to the identification of a person, as for the GDPR and EUDPR.

EU consultation on medical device legislation

The repeated calls in recent months from many quarters for work to be carried out as soon as possible on the revision of the two regulations on Medical Devices (MDR) and In Vitro Diagnostics (IVDR) have been answered by the European Commission. In fact, a Call for Input for an Evaluation, addressed to the public and stakeholders, has been published on the Commission’s website.

There is until 21 March 2025 to send in your comments and observations. The outcomes of the targeted evaluation should support the Commission in better understanding the adequacy, efficiency and effectiveness of current regulations and whether they effectively meet current and emerging needs. Other objectives of the initiative include assessing whether the two regulations have European added value and are in line with other actions of the legislator.

The decision to launch a public consultation phase follows the numerous difficulties encountered in the transition between the old directives and the new regulations. In its invitation, the European Commission also points out that the timeframe for the re-evaluation of the two regulations under Art. 121 MDR and Art. 111 IVDR actually provided for a deadline of May 2027. The results of the consultation are expected to be announced by the fourth quarter of 2025. According to the Invitation, a factual summary report of the responses submitted should be published after the close of the public consultation.

The focus of the consultation

The focus of the targeted evaluation is on the period between the adoption of the new MDR and IVDR legislation (5 April 2017) and 31 December 2024, limited to areas already in the implementation phase. The main focus of the initiative is to verify whether the objectives set for the regulations can actually be achieved by the end of the transition periods, as extended, also in view of the current regulatory framework and the way it is implemented.

A critical issue, highlighted by several parties, at the centre of the evaluations is theimpact of the legislation on the availability of devices, including ‘orphan’ devices and devices intended for smaller patient populations, along with the development of innovative devices in the EU.

The Commission also announces attention to the issue of costs and administrative burdens, in particular for small and medium-sized enterprises, and to that of the benefits to be gained from implementing the legislation. A geographical impact assessment on the implementation of regulations in all EU Member States and in other countries, both within and outside the European Economic Area, should also not be missing.

Highlights from the last EPSCO meeting

The Employment, Social Policy, Health and Consumer Affairs Council (EPSCO) which took place on 3 December 2024 addressed many healthcare-related topics. Among these, Health ministers discussed the European Health Union in light of the Draghi report of September 2024 on the future of European competitiveness. Among the main issues on the table was the potential impact of Draghi’s recommendations on national healthcare systems and the European Health Union’s, as well as how member states and the Commission might coordinate their implementation.

A report on progress achieved in the revision of the pharmaceutical package was also discussed. The document resumes the opinions the Commission received from different national governments and bodies on the initial proposal of the new directive and regulation of 26 April November 2023. The EU Parliament adopted on 10 April 2024 its position on the revision. A number of meetings of the Council’s Working Party (WP) on Pharmaceuticals and Medical Devices were also organised under the different presidencies. Main still open issues include incentives and length of data protection, regulatory flexibility and shortages.

The Council also approved its conclusions on the improvement of cardiovascular health in the European Union. Prevention, early detection, treatment and rehabilitation are the key actions identified in order to reduce the social and economic burden of cardiovascular diseases.Other topics raised during the discussions included the ongoing negotiations for an international agreement on pandemic prevention, preparedness and response, as well as complementary amendments to the International Health Regulations (2005), the needed reforms in the Medical Device and In vitro Diagnostic Medical Device Regulations and the voluntary cooperation for joint procurement of medicinal products.

HERA Stakeholders Hub, a new EU platform for collaboration in the pharma supply chain

The new HERA Stakeholders Hub, launched by the Health Emergency Preparedness and Response Authority (HERA), aims to enhance collaboration in the pharmaceutical sector. The HERA Stakeholders Hub will facilitate direct communication between businesses, national authorities, non-governmental organisations and other concerned stakeholders on medical countermeasures and pharmaceuticals, including critical medicines.

The matchmaking platform is one of the main features of the new Hub. It is expected to facilitate the connection between potential partners for supply chain collaboration and research projects. Dedicated collaboration spaces will be also available for members of the Critical Medicines Alliance and the Joint Industrial Cooperation Forum.

Members of the HERA Stakeholders Hub should also collaborate to address supply chain vulnerabilities and tackle medicine shortages, so to create a more stable and reliable supply of strategic resources in the EU.

Interim report of EMA’s proof-of-concept pilot on the use of data for clinical evaluation

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EMA published on its website the interim report of the still ongoing proof-of-concept (PoC) pilot on the analysis of raw clinical study data voluntarily submitted as part of the dossier to support marketing or post-marketing authorisation applications. The pilot started in September 2022 and counted five regulatory procedures activated until December 2023.

The higher benefit for participants is linked to the statistical analysis of clinical data for more complex dossiers and products. The survey highlighted in 83% of cases an added value of accessing clinical study data at the time of submission with reference to improved understanding of the set of information in a product dossier, a reduced list of questions to applicants/MAHs, the promotion of multi-disciplinary teamwork and a better consensus on methodological issues among regulators. The development of a knowledge base for the review of experience to guide the assessment of future studies has also been indicated.

Added value was also highly perceived (93%) for GCP site inspections, leading to a shorter time to plan and conduct inspections and optimisation of resources across the European regulatory network. The interim report addresses learnings gained during the first phase of the project and highlights consequent recommendations to be implemented in the second phase.

Review of the joint EU regulatory network strategy to 2028

The original five-year joint EU regulatory network strategy 2021-2025 (EMANS 2025) is undergoing a revision to update it according to the last regulatory and technological innovation. The draft EMANS 2028 strategy published by EMA and the Heads of Medicines Agencies (HMA) was open to public consultation until 30 November 2024. “The six focus areas have been carefully chosen to support the network’s core work of evaluating medicines as we take strides to promote the development of medicines and ensure that they reach those who need them.”, said Maria Lamas, Chair of the HMA Management Group.

EMANS 2028’s strategic focus areas aim to facilitate pathways for access to medicines through healthcare systems in the EU. Data, digitalisation and artificial intelligence would support decision-making processes and better efficiency. The creation of a regulatory and research environment aims improving innovation and competitiveness of the EU’s healthcare sector. Potential threats have also been considered, including antimicrobial resistance, as well as an improved availability of medicines to protect public and animal health. Last but not least, the EU regulatory network should benefit from enough resources to support its scientific and regulatory decision making. The final strategy should be adopted by March 2025.

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