PhRMA Wants ‘More Complete’ Interchangeability Guidance
Pharmaceutical Research and Manufacturers of America (PhRMA) says an FDA draft guidance, Biosimilarity and Interchangeability: Additional Draft Q&As on Biosimilar Development Under the BPCI Act, should be revised to provide more complete guidance related to interchangeable products, including on:
- consideration for developing presentations, container closure systems, and delivery device constituent parts for proposed interchangeable products;
- labeling for interchangeable products;
- promotional labeling and advertising considerations for interchangeable products;
- quality considerations and further guidance on post-approval manufacturing changes; and
- the agency’s approach to reviewing 351(k) applications seeking an interchangeability determination that are (1) in review at the time a first interchangeable product is approved or (2) submitted during the pendency of an interchangeability exclusivity period.
The PhRMA comment letter also asks that the final guidance revise the labeling statement on interchangeability to clarify that the product is interchangeable with the reference product and not with other biosimilar products.