FDA Issues Promotional Guide for Biosimilars/Reference Biologics
FDA has released a final guidance entitled “Promotional Labeling and Advertising Considerations for Prescription Biological Reference Products, Biosimilar Products, and Interchangeable Biosimilar Products: Questions and Answers,” which is aimed at clarifying how pharmaceutical companies should promote prescription biologics, including biosimilars and interchangeable biosimilars, in advertising and labeling. The guidance, presented in a question-and-answer format, outlines the agency’s current thinking on ensuring that promotional communications are truthful, accurate, and non-misleading.
The guidance addresses firms’ questions about promoting reference biologics — original products licensed under section 351(a) of the Public Health Service Act — and biosimilar products licensed under section 351(k), including interchangeable biosimilars that can be substituted for the reference product without a healthcare provider’s intervention.
Key points from the guidance include:
- Truthful and balanced communications: Companies must ensure promotional materials accurately reflect the safety and effectiveness of both reference products and biosimilars. Claims must be balanced, clearly present risks, and avoid creating misleading impressions of superiority or inferiority.
- Correct product identification: Firms are advised to identify reference products, biosimilars, and interchangeable biosimilars clearly in all promotional communications. Proper naming—including proprietary, proper, and core names—is critical to avoid confusion.
- Use of clinical data: Promotional materials can reference studies from the original reference product if such data are included in the FDA-approved labeling for the biosimilar. Firms must ensure that only relevant data for the licensed indications of the biosimilar are presented.
- Avoiding misleading comparisons: FDA cautions against implying that minor differences in study outcomes or licensure pathways indicate clinically meaningful differences between reference products and biosimilars. Presentations suggesting that biosimilars are less safe or effective than reference products—or vice versa—could be considered misleading.
- Interchangeability considerations: Promotional materials should not suggest that a biosimilar’s safety or efficacy is inferior because it is not licensed as interchangeable with a reference product. Likewise, communications should not imply that patients should avoid switching from a reference product to a biosimilar.