FDA Complete Response Letter on Teva Generic EpiPen
FDA has issued Teva a complete response letter on its epinephrine ANDA, a generic copy of Mylan’s EpiPen, indicated for emergency treatment of allergic reactions, including potentially fatal anaphylaxis. Teva says the agency cited “certain major deficiencies,” and it intends to submit a response. The company says it expects that its epinephrine product will be significantly delayed and that any launch will not take place before 2017.
The delay is a boost to Mylan and EpiPen’s $1 billion in annual sales. Last year, Mylan lost a bid to delay Teva’s ANDA when FDA denied a petition that questioned the sameness of the Teva product. Mylan’s petition had argued that patients, caregivers, and other relevant user groups trained in the use of the EpiPen auto-injector who face an emergency situation would not be able to safely and effectively use Teva’s proposed product in accordance with the EpiPen instructions for use, without additional physician interaction or training. FDA’s denial letter said it has made no final determination on whether to approve or not approve any ANDA relying on the EpiPen as a reference-listed drug. Therefore, FDA said, it does not interpret its regulations as requiring it to provide a final agency decision on the “approvability of a specific aspect of an application when a final decision on the approvability of any such application has not yet been made.”