Regulation of innovative medicinal products including advanced therapies (ATMP)
Medicinal products for advanced therapies are regulated according to the ATMP Regulation 2007/1394/EC
This page informs about the ATMP regulation in the EU and provides an overview over relevant contact points for additional information regarding the development of innovative medicinal products, including ATMP.
Definitions
Definitions from REGULATION (EC) No 1394/2007 on advanced therapy medicinal products
ATMP (Advanced Therapy Medicinal Products) are biological medicinal products based on cells, tissue and genes. They are divided in gene therapy medicinal products, somatic cell therapy medicinal products, tissue engineered products and combined advanced therapy medicinal products.
Gene therapy medicinal products
as defined in Part IV of Annex I to Directive 2001/83/EC, chapter. 2.1
Gene therapy medicinal product means a biological medicinal product which has the following characteristics:
(a) it contains an active substance which contains or consists of a recombinant nucleic acid used in or administered to human beings with a view to regulating, repairing, replacing, adding or deleting a genetic sequence;
(b) its therapeutic, prophylactic or diagnostic effect relates directly to the recombinant nucleic acid sequence it contains, or to the product of genetic expression of this sequence.
Gene therapy medicinal products shall not include vaccines against infectious diseases
Somatic cell therapy medicinal product
as defined in Part IV of Annex I to Directive 2001/83/EC, chapter 2.2
Somatic cell therapy medicinal product means a biological medicinal product which has the following characteristics:
(a) contains or consists of cells or tissues that have been subject to substantial manipulation so that biological characteristics, physio[1]logical functions or structural properties relevant for the intended clinical use have been altered, or of cells or tissues that are not intended to be used for the same essential function(s) in the recipient and the donor; (b) is presented as having properties for, or is used in or administered to human beings with a view to treating, preventing or diagnosing a disease through the pharmacological, immunological or metabolic action of its cells or tissues. For the purposes of point (a), the manipulations listed in Annex I to Regulation (EC) No 1394/2007, in particular, shall not be considered as substantial manipulations.
Tissue engineered product
as defined in the ATMP REGULATION (EC) No 1394/2007, point (b):
Tissue engineered product means a product that:
— contains or consists of engineered cells or tissues, and
— is presented as having properties for, or is used in or administered to human beings with a view to regenerating, repairing or replacing a human tissue.
A tissue engineered product may contain cells or tissues of human or animal origin, or both. The cells or tissues may be viable or non-viable. It may also contain additional substances, such as cellular products, bio-molecules, biomaterials, chemical substances, scaffolds or matrices.
Combined advanced therapy medicinal product
as defined in the ATMP REGULATION (EC) No 1394/2007, point (d):
‘Combined advanced therapy medicinal product’ means an advanced therapy medicinal product that fulfils the following conditions:
— it must incorporate, as an integral part of the product, one or more medical devices within the meaning of Article 1(2)(a) of Directive 93/42/EEC or one or more active implantable medical devices within the meaning of Article 1(2)(c) of Directive 90/385/EEC, and
— its cellular or tissue part must contain viable cells or tis[1]sues, or
— its cellular or tissue part containing non-viable cells or tissues must be liable to act upon the human body with action that can be considered as primary to that of the devices referred to.
Please contact for further advice; Medical devices (laegemiddelstyrelsen.dk)
Is it a medicinal product? Ask DKMA
Definition of medicines and other products
Is it an ATMP? Ask EMA
Advanced therapy classification | European Medicines Agency (europa.eu)
Regulatory advice
Regulatory advice from DKMA: National scientific advice:
National Scientific Advice (laegemiddelstyrelsen.dk)
Regulatory advice from EMA:
Innovation in medicines | European Medicines Agency (europa.eu)
Support to SMEs | European Medicines Agency
Scientific advice and protocol assistance | European Medicines Agency
Good Manufacturing Practice (GMP)
Legislation on GMP and GDP:
Legislation on GMP and GDP (laegemiddelstyrelsen.dk)
GMP for ATMP:
Clinical trials
Clinical trials of medicines in Denmark
Clinical trials of medicines (laegemiddelstyrelsen.dk)
Particular demands for first-in-human clinical trials:
EMA guideline on documentation requirements regarding ATMP in clinical trials:
EMA guidelines regarding ATMP:
Guidelines relevant for advanced therapy medicinal products | European Medicines Agency
EDQM guide to the quality and safety of tissues and cells for human application:
Contact point for the clinical trial department:
Telephone: 4488 9123 / mail: clinical trials
Recommendation on the format of the submitted documentation for clinical trial applications:
As described in EU Regulation No 536/2014, the applicant is recommended to provide documentation prepared in accordance with international guidance such as that of the ICH Common Technical Document (CTD) format as also followed in the EMA scientific guidelines.
In addition to the guidance found for clinical trials under Eudralex – Volume 10 as listed below, reference is also given to the Notice to Applicants and the marketing authorization application templates.
Here detailed guidance for the description of the CTD for medicinal products for human use can be found.
Even though it is for marketing authorization applications, it provides a helpful description of the format and content of the regulatory documentation, which can be accommodated to the stage of development of the investigational medicinal product.
Notice to Applicants on the Common Technical Document
Template for marketing authorization with detailed guidance for non-clinic
Template for marketing authorization with detailed guidance for quality/CMC
Clinical Trial Guidelines
EudraLex - Volume 10 - European Commission (europa.eu)
Chapter III - Quality
- Guideline on the requirements to the chemical and pharmaceutical quality documentation concerning investigational medicinal products in clinical trials (revision 2 – January 2022)
- Guideline on the requirements for quality documentation concerning biological investigational medicinal products in clinical trials (Revision 2 - January 2022)
And chapter V - Additional Documents
- Guideline for good clinical practice - ICH E6(R2) - EMA/CHMP/ICH/135/1995 (2016) Describing the structure for the Protocol and Investigator´s Brochure
Compasionate use permits
Compasionate use permits for medicinal products that is not marketed in Denmark:
Pharmacovigilance
Legislation
Medicinal Product Act:
ATMP Regulation:
Requirements for the donation, procurement and testing of human tissues and cells
Other regulatory authorities responsibility
The Danish Patient Safety Authority: Regulation of tissue and cell procurement
Blood, Tissues/Cells and Organs | The Danish Patient Safety Authority (stps.dk)
The Danish Environmental Protection Agency: Regulation of GMO
Work environment in Denmark
Report work with genetic engineering - Arbejdstilsynet (at.dk)
Contact
For general requests regarding ATMP and other innovative medicinal products you can contact the Danish Medicines Agency´s innovation coordinator here: Send an e-mail