eCTD Specification
17 July 2014
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ACTD
• ASEAN established the ASEAN Common Technical
Document (ACTD) to create harmonized
requirements and a common format for all
submissions of dossiers in the ASEAN countries.
• The ACTD is based on the European standard (CTD),
CTD format is required for the registration of all drug
products into EMEA regulated countries.
• Contents of Module 2 in CTD were separate in to
ACTD Part 2,3,4 as paper management during review
process is easier.
• TOCs aren’t required anymore in eCTD
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eCTD ACTD
ICH M4
Regional
Admin
Information
NOT Part of
the CTD
ACTD
Module
Part 1 1
Module 2
Nonclinical
Overview
Quality
Overall
Summary
ACTD
Part 2
Nonclinical
Summary
ACTD
Part 3
Clinical
Overview
The CTD
Clinical
Summary
ACTD
Part
4
Clinical
Quality
Nonclinical
Study Reports
Study Reports
Module 3
Module 4
Module 5
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Business Protocol
Prepare Submission
Application
eSubmission Identifier
from THAI FDA website
Prepare the cover letter
and validation report
Delivery of the eCTD
Application at FDA (CD)
FDA : Feedback on
Validation of Application
FDA : Start
review process
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Regional Content
•
Module 1 administrative and prescribing
information
-
•
The content and numbering of Module 1 for Thailand is
modelled after the EU Module 1 content as described in the
2008 version of the EU Notice to Applicants. Additional
documents specifically required by Thailand not covered by the
EU structure is describe in 1.A Additional Data of TH Module 1
and Regional Specification
Modules 2 to 5
-
No change from ICH eCTD Specification.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Reviewing
process
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Handling of Empty or Missing eCTD Sections
• For new applications, including generic applications, detailed
statements justifying the absence of data or specific CTD
sections should be provided in the relevant Quality Overall
Summary and/or Nonclinical/Clinical Overviews e.g. Module 2.3,
2.4, or 2.5.
• For a generic application, there is no need to provide a
justification for content that is typically absent.
• Note that placeholder documents highlighting no relevant
content should not be placed in the eCTD structure.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Reviewing
process
(6)
Bookmarks, TOCs, and Hyperlinks
•
•
•
•
Bookmarks and/or TOCs make the review more efficient.
The FDA recommends that documents with more than five pages and
with multiple sections should provide a Table of Contents, and/or if
appropriate, a Table of Tables, Table of Figures, etc. on the first page
of the document.
Hyperlinks are recommended when they would aid the evaluation in
ways not already possible through the use of the eCTD index.xml and
document navigation aids.
Applicants should consider when creating cross document hyperlinks
that they can cause confusion later in lifecycle and therefore be
distracting for an efficient review.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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process
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File Reuse
•
The FDA accepts and encourages applicants to make active use of file reuse.
•
Applicants should not submit the same document multiple times.
•
File reuse should be used when
•
-
a file is submitted multiple times within one sequence,
-
a file already submitted in an earlier sequence is being referenced again,
-
or if a file submitted in another application is being referenced in a new application.
Please note that the FDA is implementing a flat repository structure to make
cross application referencing possible.
-
Links to content provided in other applications simply need to be directed out of the current
application structure and into the structure of the corresponding application.
-
All application will be stored using the eSubmission Identifier to make cross referencing
easily predictable and possible.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Structure
• Naming conventions for the
content files are irrelevant for
electronic review
• All content must be
referenced
by the appropriate XML files
for efficient navigation.
• Applicants should concentrate
on providing precise but
informative leaf titles to
aid reviewers.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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eSubmission Identifier
• A request for an eSubmission identifier should made
via website (THAI FDA e-logistic data base). The
request will require the following information:
-
Licensee Number
Description of Application.
Dosage Form
INN or Generic Name
Strength
WHO ATC Code
Sequence Type
Application form (CPP)
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Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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eSubmission Identifier
• The eSubmission Identifier will be issued
within 10 days of application. The Applicant
must check on the THAI FDA online service
for a response informing them of their
eSubmission Identifier. After receiving the
identifier, the Applicant must then make an
appointment for submission within 30 days.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Validation Criteria
• No major new or unusual validation criteria
developed from EU eCTD V3.2
• Other regions were analysed, compared and adopted
if suitable
• Detail validation criteria can be found at TH Regional
Specification and Validation Criteria
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Items worth noting
Validation Criteria
•
Files and Folders
- There are no naming conventions being validated
•
ICH Backbone
- File Reuse - Information is collected about references outside the
application and sequence as well as multiple references to a file within a
sequence
•
TH Regional
- File Reuse
- Cover Letter must be New
- Information is collected when Application Form is not New
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Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Validation Tools
Most vendors offer free basic versions of their
validation tools
•
•
•
•
•
No excuses for submitting applications that do not pass technical validation
Make sure you validate on the media being submitted
Validation should be limited to criteria specified by the FDA
- Some vendors provide extended profiles, these should not be provided with the
application
List of validation tools will be provided on the eSubmission Website as
vendors provide evidence that they can sufficiently validate the FDA
requirements
Current free version of validation tool being used by the FDA can be found at:
- http://www.lorenz.cc/esolutions/eValidator/ (Link also provided on FDA
eSubmission webpage)
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Business Protocol for Submitting
eCTD
Expected Structure of Submitted Media and Media
Formats
•
•
Expected structure of submitted media
- Content should be submitted in an application folder named after the eSubmission identifier.
- The sequence folder and its contents should be placed in this application folder.
- Large applications must be split and submitted on multiple items e.g. DVDs
- The overall folder structure should be included on each media so that content can be easily
merged
Media formats
- The media formats acceptable when submitting an eCTD are:
o CD-R, DVD-RAM, DVD+R/-R,
- Ensure that you do not use:
o double-sided discs, rewritable discs or compressed or zipped files (except for validation
reports).
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Delivery of the eCTD Application
•
The Applicant will need to make an appointment
through drug_esubmissions@fda.moph.go.th and
deliver the application personally at the Division of
Policy System Development. The eCTD will be
validated and imported into the THAI FDA Review
System together with the applicant. Once accepted
and submitted, the applicant will be given back their
media to keep.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Application feedback
• THAI FDA will inform applicants if there are
problems experienced during the upload of
an eCTD sequence.
• Confirmation of validation document will be
issue during appointment.
Prepare
Application
eSubmission
Identifier
Validation
report
Delivery the
application
Application
feedback
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Start Review Process
Initial Content
Screening
Process
Prepare
Application
Evaluation
Process
eSubmission
Identifier
Validation
report
Administration
Process
(include LoQ)
Delivery the
application
Application
feedback
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Issue
Registration
Certificate
Reviewing
process
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Implementation of eCTD
*2002 Implementation Status of Submission System, Thomson Reuters
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Implementation of eSubmission
*2002 Implementation Status of Submission System, Thomson Reuters
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Thank you!
Teerapong Cheepchol
tch@factory-talk.com
T: +662-630-4525
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