Advanced Therapy Medicinal Products


Advanced Therapy Medicinal Products

April 18, 2012




• ATMP definition/ classification?

• What is my human cell based product?

• Exemptions and different routes?


Definitions 2001/83/EC/ ; 2004/24/EC; 93/42/EC


Advanced Therapy Medicinal Products




Status EU ATMP’s

• 1 registered ATMP in EU : Chondroselect (Tigenex)

• Only six applications have been submitted for MA (four ATMPs)

• In 2009-2011

• a product was intended for treatment of squamous cell carcinoma (head and neck) was withdrawn

• the CAT adopted a negative opinion on the MA application of a gene therapy product intended for treatment of cerebral cancer (high grade glioma); the manufacturer withdrew its application in March 2010.

• A negative CAT opinion was adopted for the MA application a gene therapy product intended for use in severe lipid metabolic disease.On re-examination of Glyberain

October2011, the CAT adopted a positive opinion but this was not endorsed by the


• 50 Summaries of scientific recommendations on classification of advanced-therapy medicinal products (4 not classified a ATMP)



or Medical Device or Human tissue

Or Blood product or Combo?

• Where does my product fit?

• Where do I want it to fit?

 Carefull consideration required to define best strategy

Ask for classification is that wise?

• CAT/ CBG/CA human tissues/ Notified Body?

• Where to go best?


1) Advanced Therapy Medicinal Products

• ATMPs are medical products for human use and include:

 Gene therapy products

 Somatic cell therapy products

 Tissue engineering products

• ATMPs are regulated under consolidated framework for advanced therapies (Regulation 1394/2007) as pharmaceutical products

• ATMP Regulation, Article 3

Where an ATMP contains human cells or tissues, the donation, procurement and testing of those tissues or cells shall be made in accordance with Directive 2004/23/EC


Cells or tissues shall be considered ‘engineered’

if they fulfill at least one of the following conditions:

•Industrial process

•the cells or tissues have been “engineered”; subject to substantial manipulation,

•are not intended to be used for the same essential function or functions in the recipient as in the donor .


This is still open for interpretation

What does this mean for

-Autologous processes?

-Small academic clinical case study?

-Culturing in the OR/ bioreactor within the same procedure?

-Harvesting tissue and place it in a different environment?


Exceptions to Substantial Manipulations

Annex I, ATMP Regulation

• cutting

• grinding

• shaping

• centrifugation

• soaking in antibiotic or antimicrobial solutions

• sterilization,irradiation

• cell separation, concentration or purification

• filtering

• lyophilization

• freezing

• cryopreservation,


What if my product is an exception or gray zone?

What are the other options?


2) European Union Tissue and Cells Directive


• Directive DG Sanco (2004/23/EC) (April 6, 2006)

Standards of quality and safety for donation, procurement, testing, processing, preservation, storage and distribution of human tissues and cells

Implementing Directives

• Directive DG Sanco (2006/17/EC) (Nov 1, 2006)

Technical requirements for the donation, procurement, testing of human tissues

• Directive DG Sanco (2006/86/EC) (Sept, 2007)

Traceability requirements, notification of serious adverse reactions and events and certain technical requirements for the coding, processing, preservation, storage and distribution


Tissue Directive (2004/23/EC)

• Storage and preservation

“autologous Cell and tissue graft used in the same graft procedure are exempt article 2(section 2a



Definitions discussion at different levels

Summary CA Tissue and Cells (Dec 2011)-EUTCD

•SANCO legal team and provide feedback to NCAs during the meeting in


•Unanimous consensus between the CAs to consider the use of amniotic membrane for cornea replacement as homologous, and therefore in the scope of Directive Tissue Directive

•And Apheresis of mononuclear cells for preparation of ATMPs; Donor

Lymphocyte infusion, mononuclear cells collected by apheresis are considered to be in the scope of the Tissue Directive


Medical Device Directive (93/42/EC)

• Article 1.5(f)

This Directive does not apply to:

(a) in vitro diagnostic devices;

(b) active implantable devices covered by Directive 90/385/EEC;

(c) medicinal products covered by Directive 65/65/EEC;

(d) cosmetic products covered by Directive 76/768/EEC (18);

(e) human blood, human blood products, human plasma or blood cells of human origin or to devices which incorporate at the time of placing on the market such blood products, plasma or cells;

(f) transplants or tissues or cells of human origin nor to products incorporating or derived from tissues or cells of human origin;

(g ) transplants or tissues or cells of animal origin, unless a device is manufactured utilizing animal tissue which is rendered non-viable or non-viable products derived from animal tissue.


CAT Classification of Stem cell-based ATMPs

Product ATMP classification/ Indication

Autologous corneal epithelium containing stem cells Tissue engineered product /

Corneal lesions

Allogeneic human placenta-derived, cultureexpanded, mesenchymal-like cell population

Somatic cell therapy product /

Chronic inflammatory diseases

Autologous bone marrow-derived progenitor cells Tissue engineered product

Cardiovascular diseases

Umbilical cord blood cells expanded ex vivo using allogeneicmesenchymal precursor cells

Autologous osteoprogenitor cells, isolated from bone marrow and expanded in vitro, incorporated, as an integral part, with 3D biodegradable scaffold

Allogeneic mesenchymal precursor cells

Tissue engineered product /

Heamatology-oncology diseases

Tissue engineered product – combined

Repair, regeneration bone defects

Tissue engineered product /

Cardiaovascular diseases


CAT Classification of other ATMPs


Human islets of Langerhans

ATMP classification/ Indication


Intended for:

Autologous: Post pancreatectomy for benign pancreatic pathologies

Allogeneic: Treatment of severe forms of type 1 diabetes

Product is derived from pancreatic tissue by a number of steps that do not constitute substantial manipulation. Moreover, information provided show that the manipulation of the tissue does not alter the biological characteristics and physiological functions relevant for the intended clinical use. The product is intended to be used for the same essential function in the recipient and the donor, i.e.pancreatic function.



Classification discussions?

• Why do I favor an ATMP classification:

• Recognition in Europe;

• Raise the bar for market entry BUT

• Difficult route to market;

• Complex regulatory landscape- requirements/ standards difficult to apply

• Why do I favor HTP classification:

• Quick market access in specific MS BUT

• No mans land (??) creates unclear /changing situation per Member


Faster routes in development than classical ATMP?


1) Advanced Therapy Medicinal Products

• Key aspects of the ATMP Regulation:

• Centralized Marketing Authorization procedure (EMA)

• Committee for Advanced Therapies (CAT)

• Hospital Exemption ruling

• Specific GMP regulations

• Incentives for small and medium sized enterprises (SME)

• Risk management and long term traceability

• Post authorization pharmacovigilance systems


3 options : treatment of patients using ATMPs

1. Treatment as registered Medicinal Product (via EMA, see


2. Products,which were legally on the Community market when the Regulation became applicable, should comply to the

Regulation by December30,2012.

3. Treatment as registered Medicinal Product in a clinical study


for information).

4. Treatment as a hospital exemption

• De IGZ has to authorize the hospital exemption including manufacturing (GMP)



CAT: Committee for Advanced Therapies

• Products covered subject to centralized authorization procedure involving a single scientific evaluation of the quality, safety and efficacy of the product by the EMEA

• CAT (Committee for Advanced Therapies) responsible for

 Draft opinions on the Quality, Safety and Efficacy of each ATMP for final approval by CHMP (Committee for medicinal Products for

Human Use)

 Advice on whether the product falls within the definition ATMP

 Contribute to scientific advice procedures

• Comprised of multidisciplinary scientific experts representing all EU member states, as well as and patient and medical associations


Hospital Exemption

(Article 28)

• ATMPs exempted from the centralized marketing authorization procedure

• Hospital Exemption requirements:

 Non-routine basis

 Manufactured and used in same member state

 Used in a hospital under exclusive professional responsibility of a medical practitioner

 Specific quality standards

 Individual medical prescription

 Custom-made product for an individual patient

• Same requirements apply as for ATMPs for which a centralized procedure is mandatory (GMP, QP release, pharmacovigilance)

• Not intended for clinical trials but rather case studies


Hospital exemption

• Member states are responsible for the implementation of the

Hospital Exemption

• Lack of clear guidance in most Member States

• Differences in interpretation of the Hospital Exemption are likely to occur

• Many member states are reluctant to grant hospital exemption for clinical Phase 1 trials

• Variation per country ( ie Netherlands difficult vs Spain easier)


Hospital exemption procedure

• A request for hospital exemption needs to be adressed to IGZ, digitally via a form and has to be sent to


• IGZ reviews requests monthly, the request should be sent at least 2 weeks before the date IGZ has an ATMP review meeting.

• IGZ sents the decision 2 weeks after the review meeting

• Hospital Exemptions are enclined for one year only and maximum 10 patients.

• Hospital exemptions from companies are most likely deferred


• Good Manufacturing Practices


GMP Manufacturing of ATMPs

• ATMPs need to be manufactured in accordance with the

GMP guidelines for human medicinal products for human use (Directive 2003/94/EC)

• Control of consistency, reproducibility and uniformity are key aspects

• Annex 2 of the EU Guidelines for GMP for medicinal products for human and veterinary use (Eudralex Vol4) has been updated to include GMP specific to ATMPs

• The Annex recognizes the inherent variability and increased risks for microbial contamination and transfer of pathogens associated with biological culturing processes and materials


GMP Human tissues

• Only as defined in the Directives (light GMP system)


Advanced Therapy Medicinal Products

Applicable regulatory framework for cell based

(medical) products for human use.

Product and intended use

HUMAN tissues and cells intended for human use

Medicinal Products manufactured from

HUMAN tissues and cells intended for human use

Medicinal Products manufactured from

ANIMAL tissues and cells intended for human use


2004/23/EC 1394/2007



ATMP and Stem Cells

• EMA closely monitors developments in the area of stem cell therapy

• Depending on the indication and process, stem-cell based medicinal products can be classified as ATMPs

• Stem cells preparations that are not substantially manipulated or intended to be used for the same essential function in the recipient as in the donor are outside the scope of the ATMP


• To date, no stem-cell product has received marketing authorization within the EU


ATMP and Stem Cells

• EMA expressed concerns about ‘stem-cell tourism’: use of unauthorized stem-cell based treatment in the absence of rigorous scientific and ethical requirements

(Lancet 2010;Vol376:514)

• CAT has classified various medicinal products containing stem cells as ATMPs

• Committee of Orhpan Medicinal Products (COMP) has granted orphan designation to a number of medicines containing stemcells for the treatment of rare diseases