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EuropaBio<br />

& <strong>Biosimilar</strong><br />

<strong>Medicines</strong>


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

Contents<br />

• Welcome letter from the Secretary General<br />

of EuropaBio<br />

• Healthcare biotechnology and biosimilars<br />

• Glossary of key terms<br />

• References<br />

• Further information<br />

Healthcare biotechnology and biosimilars<br />

I - The Science<br />

1. Healthcare biotechnology – introduction<br />

2. Why do biological medicines differ from chemical medicines?<br />

3. How are biological medicines manufactured?<br />

4. Intellectual property for biotech medicines<br />

II - <strong>Biosimilar</strong> <strong>Medicines</strong> – Current Issues<br />

1. Naming<br />

2. Health Economics & Pricing<br />

3. Immunogenicity<br />

4. Interchangeability<br />

5. Substitution<br />

III – The Regulation of <strong>Biosimilar</strong>s<br />

1. In Europe<br />

2. Outside of Europe<br />

IV - The market for biosimilars<br />

1. Which biosimilars are currently available in Europe?<br />

2. When are the next biosimilars coming on to the market?<br />

3. What does the market entry of biosimilars mean for the original innovator products?<br />

V - The impact of biosimilars<br />

1. What do patients need to know?<br />

2. What do healthcare professionals need to know?<br />

3. What do payers need to know?


Welcome letter by EuropaBio<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

Biotechnology has enabled the discovery of<br />

treatments for some of the most serious diseases<br />

known to man – worldwide, the lives of over 325<br />

million people have been transformed by the<br />

availability of a growing number of biotechnology<br />

medicines. Today patients have access to more<br />

than 155 biotechnology drugs and vaccines, and<br />

medical science is working to increase that number<br />

every day. There are more than 418 biotechnology<br />

medicines in development, covering more than 100<br />

diseases i . These include 210 medicines for cancer, 50<br />

for infectious diseases, 44 for autoimmune diseases,<br />

and 22 for AIDS/HIV and related conditions.<br />

As the exclusive rights (patents and other data<br />

protection) for certain biological medicines expire,<br />

similar biological medicines or “biosimilars” are<br />

being developed. Some of these are already on<br />

the market in Europe. This document is intended<br />

to explain the complexities of biotech medicines,<br />

including biosimilar medicines, and to give an<br />

insight into what patients, healthcare professionals<br />

and other interested individuals should know<br />

<strong>about</strong> biotech and biosimilar medicines.<br />

Willy DeGreef<br />

Secretary General, <strong>Europabio</strong><br />

03


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

...patients<br />

have access<br />

to more<br />

than 155<br />

biotechnology<br />

medicines and<br />

vaccines...


I - The Science<br />

1. Healthcare biotechnology – introduction<br />

What are biotechnology medicines*<br />

and how do they work?<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

Biotechnology uses biological systems and living<br />

organisms to make or modify products or processes<br />

for specific use ii . Biotechnology medicines are just<br />

one of the many applications of biotechnology in<br />

healthcare. There are several prominent categories<br />

of biotechnological medicines:<br />

• Recombinant proteins can replace insufficient<br />

or malfunctioning proteins in the human body.<br />

One example of a recombinant protein is insulin,<br />

which is commonly used in the treatment of<br />

diabetes. Other recombinant proteins like<br />

antibodies or vaccines are used in the treatment<br />

or prevention of serious diseases such as cancer.<br />

• Nucleic acids like DNA or RNA are used in<br />

gene-therapy treatments to restore or modulate<br />

specific disease-related genes.<br />

• Tissues and cells are used for tissue repair after<br />

severe injuries e.g., skin transplants.<br />

• Inactivated forms of micro-organisms are used as<br />

vaccines to prevent diseases provoked by these<br />

micro-organisms (mostly viruses). Vaccines work<br />

by stimulating an immune response against a<br />

disease-causing micro-organism.<br />

• Complex chemical molecules like antibiotics,<br />

which are used for the treatment of bacterial<br />

infections, can be either directly obtained from<br />

micro-organisms (e.g. penicillin is produced<br />

by a certain type of fungus), or can be further<br />

modified by chemical processes (e.g. half-synthetic<br />

antibiotics like ampicillin).<br />

Furthermore, many biotechnological healthcare<br />

products are used widely for diagnostic purposes.<br />

*For the purpose of this document, we use the term “biotech medicine” or<br />

“biological medicine” or “biopharmaceutical” for recombinant protein products.<br />

05


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

The history of healthcare biotechnology<br />

06<br />

Although the modern healthcare biotechnology<br />

industry is only 30 years old, the science of<br />

biotechnology has been explored since the 19th<br />

century when eminent scientists such as Louis<br />

Pasteur and Robert Koch first developed the<br />

science of microbiology, the forerunner of today’s<br />

biotechnology. In 1953, James Watson and Francis<br />

Crick discovered DNA and in 1955, Fred Sanger<br />

determined the amino acid sequence of insulin.<br />

In 1972, Paul Berg created the first recombinant<br />

DNA molecule. DNA engineering has become the<br />

basis of modern biotechnology as it allows the<br />

re-arrangement (“recombination”) of so far<br />

unrelated genetic sequences and the use of those<br />

molecules for the production of recombinant<br />

proteins for medical purposes.<br />

The first biotech companies were founded in the<br />

1970s and many more in the early 1980s. Most of<br />

today’s healthcare biotech companies began life<br />

as small start-ups established by a handful of<br />

enthusiastic visionary scientists on a shoe-string<br />

budget. The hard work of the early pioneers has<br />

now come to fruition: today, over 325 million<br />

people have had their lives transformed by<br />

healthcare biotechnology treatments and it is<br />

estimated that by 2010, around 50 percent of<br />

new medicines will be of biological origin iii .


2. Why do biological medicines differ from<br />

chemical medicines?<br />

What are the differentiating factors?<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

Biological medicines are far more complex<br />

and usually much bigger in size than chemical<br />

medicines, which are produced by chemical<br />

synthesis. This means that their manufacturing and<br />

precise characterisation tends to be more difficult<br />

than for chemical medicines, the ingredients of<br />

which are more easily identifiable and can be<br />

exactly reproduced.<br />

1. Biological medicines show a higher variability.<br />

As biological medicines are produced by living<br />

systems, such as cell lines, they show a higher<br />

variability than traditional (chemical)<br />

pharmaceuticals. As a consequence, each<br />

biological medicine is unique. This could be<br />

likened to the signature of a person; each time<br />

a person (biological) signs something, their<br />

signature will be slightly different, whereas a<br />

printed (chemical) signature remains exactly<br />

the same.<br />

2. Biological medicines are more complex.<br />

Proteins consist of one or more chains of<br />

potentially several hundred amino acids with a<br />

complex three-dimensional structure. Their<br />

molecular size is, therefore, bigger than that of<br />

chemical medicines. These large molecules are<br />

diverse and difficult to characterize. In contrast,<br />

the molecular structure of chemical medicines<br />

is relatively simple, which can allow them to be<br />

exactly reproduced.<br />

3. Biological medicines have the potential to<br />

provoke immune reactions.<br />

Biological medicines, because of their<br />

composition and large molecular size, have<br />

the ability to stimulate the body to mount an<br />

immune response, i.e. produce antibodies against<br />

a protein that the human body recognizes as<br />

“foreign”. “Small molecule” chemical medicines,<br />

07


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

on the other hand, are too small to be recognized<br />

on their own by the immune system. Chemical<br />

medicines can sometimes provoke rare negative<br />

immune reactions like allergy or hypersensitivity<br />

when they bind to naturally occurring proteins in<br />

the body. However, these reactions are generally<br />

short-lived; once levels of the chemical medicine<br />

have decreased in the body, the negative immune<br />

response will, in most cases, disappear and no<br />

longer harm the patient as long as no further<br />

exposure to the medicine occurs.<br />

The potential to provoke an immune response in<br />

the body (immunogenicity) is a double-edged sword<br />

for all biological medicines. Vaccines specifically<br />

exploit this immunogenic potential by provoking an<br />

immune response that recognizes and “fights off” an<br />

“invader” substance. However, for most medicines<br />

based on recombinant proteins, stimulating an<br />

immune response is regarded as undesirable.<br />

Immune responses are complex reactions of the<br />

body and can differ from patient to patient (due to<br />

genetic factors), as well as from disease to disease<br />

(depending on the immune status of the patient).<br />

The likelihood of an immune response can also<br />

be influenced by characteristics of the biological<br />

product itself, such as its formulation, stability and<br />

manufacturing process. The individual manufacturing<br />

process has influence, for example, on the active<br />

substance and the quality and quantity of impurities.<br />

Most of the immune responses that occur are mild<br />

and do have negative effects on the patient, e.g.<br />

in the majority of cases where transient antibodies<br />

to a therapeutic protein are found in the blood. In<br />

rare cases, however, unwanted immune reactions<br />

can have severe, detrimental effects on the health<br />

of a patient, e.g. when so-called “neutralizing”<br />

antibodies appear and make the therapeutic protein<br />

in the biotech medicine ineffective.<br />

08<br />

With biological medicines that resemble the<br />

patient’s own proteins and are intended to replace<br />

insufficient levels of that substance in the patient,<br />

such neutralizing antibodies can even trigger the<br />

body to fight off what remains of the protein<br />

produced by the patient’s body. This immunogenic<br />

reaction can persist for years after the biological<br />

medicine has stopped being administered to the<br />

patient. This potential to elicit a sustained immune<br />

response to a patient’s own protein and block<br />

important biochemical pathways for long periods<br />

of time makes immunogenicity of biological<br />

medicines a particular safety concern.<br />

4. Biological medicines are often administered<br />

via injections.<br />

When taken orally, the digestive system breaks<br />

down proteins (of which biotech medecines<br />

are composed), into their building blocks called<br />

amino acids. This progess would prevent the<br />

protein from reaching the part of the body it<br />

should treat and exerting its therapeutic<br />

function. Therefore biotech medicines must<br />

generally be administered by injection and<br />

cannot be taken orally in the shape of a pill or<br />

capsule like chemical medicines. Antibiotics,<br />

which are complex structures, but not proteins,<br />

can be taken orally or via injections, depending<br />

on the specific need.<br />

5. Biological medicines need special transport and<br />

storage conditions.<br />

Biological material is generally subject to fast<br />

degradation when handled inappropriately.<br />

Therefore, biological medicines usually need<br />

to be stored in a refrigerator and should be<br />

handled under specific conditions.


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

...biotech<br />

medicines<br />

must generally<br />

be administered<br />

by injection...


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

3. How are biological medicines manufactured? Manufacturing biological medicines is generally<br />

10<br />

more complex than the production of traditional<br />

(chemical) pharmaceuticals. Biological medicines<br />

show a higher batch-to-batch variability than<br />

chemical medicines. There are a number of reasons<br />

for this, including the nature of the starting<br />

material and the very high level of precision<br />

required in the manufacturing process.<br />

The starting material for most biological medicines<br />

is a genetically modified cell line. Each biotech<br />

company uses unique cell lines and develops its<br />

own proprietary (unique) manufacturing processes<br />

to produce biological medicines.<br />

The production of biological medicines involves<br />

processes such as fermentation and purification.<br />

Even very small changes to these manufacturing<br />

processes such as minor variations during production<br />

e.g. temperature variations, can result in significant<br />

changes in the clinical properties of the biological<br />

medicine produced. It is therefore vital to precisely<br />

control the manufacturing processes and the<br />

environment inside a production facility, in order to<br />

obtain consistent results and to guarantee the safety<br />

and efficacy of the end product.<br />

The production of biotechnology medicines<br />

requires a high level of monitoring and quality<br />

testing: typically around 250 in-process tests are<br />

conducted for a biological, compared with around<br />

50 tests for a traditional (chemical) medicine.<br />

The unique starting material and the complex<br />

manufacturing processes mean that it is not<br />

possible to exactly reproduce a biological in the<br />

same way a pharmaceutical (chemical) generic can<br />

be produced.


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

4. Intellectual property for biotech medicines Innovative medicines generally benefit from a<br />

certain period of intellectual property protection<br />

via patents and other exclusive rights such as data<br />

protection and market exclusivity. Patent rights<br />

give the patent holder (often, but not always, the<br />

manufacturer), the right to prevent others from<br />

manufacturing, selling, using and importing a<br />

product, or using a process or selling a product<br />

made by that process during a limited period of<br />

time, e.g. 20 years from the date of application.<br />

Data and market exclusivity mean that there is a<br />

period of time after approval before a competitor<br />

can enter the market with a follow-on product that<br />

relies wholly or partly on the originator’s data on<br />

safety and efficacy for its regulatory approval. The<br />

follow-on product can often use an abbreviated<br />

regulatory approval procedure.<br />

Such forms of intellectual property protection<br />

are important for companies that develop and<br />

manufacture new medicines, as it enables them to<br />

recoup their investments and further invest in the<br />

research and development of new medicines.<br />

Follow-on versions of chemical medicines that enter<br />

the market after expiry of IP protection are<br />

called “generics”. Follow-on versions of biological<br />

medicines are called “similar biological medicinal<br />

products” or “biosimilars”. In both cases, the<br />

originator product is called the “reference product”.<br />

Due to certain special features that characterise a<br />

biological medicine, the European Union decided<br />

that the name of follow-on biological medicines<br />

(“biosimilars”) and their regulatory approval pathway<br />

had to be different from chemical “generics”.<br />

11


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

II - <strong>Biosimilar</strong> medicines - current issues<br />

1. Naming<br />

12<br />

All medicines have an International Non-proprietary<br />

Name (INN) and most have a brand name, too.<br />

Chemical pharmaceuticals have the same INN as<br />

the originator product as they are exact copies of<br />

the originator. Due to the complexity of biological<br />

medicinal products, EuropaBio advocates a<br />

revision of the INN nomenclature system so that<br />

each biotechnology-derived medicine is assigned<br />

a distinct INN. Another alternative would be to<br />

ensure that biologicals are always commercialised<br />

with a brand name or the INN plus the<br />

manufacturer’s name.<br />

In some countries, physicians are obliged or<br />

enc<strong>our</strong>aged to prescribe by INN. In such situations<br />

if two biologicals have the same INN, this could<br />

result in products being considered identical<br />

and thus “switched”, when there might be no<br />

scientific evidence to support that switch. Such a<br />

switch could have negative clinical consequences<br />

for the patient, as typically the two products<br />

are similar but not identical, and the differences<br />

between them may have a therapeutic impact.<br />

The European Commission’s proposal for improving<br />

the EU pharmacovigilance iv system stresses the<br />

importance of being able to precisely trace a<br />

biological product. Specifically, the Commission<br />

suggests that marketing authorisation holders<br />

should advise those completing adverse event<br />

reports to provide “the (invented) name and the<br />

batch number”. Also, in order to improve the<br />

pharmacovigilance of biological products including<br />

biosimilars, the Commission has proposed that<br />

Member States ensure that biological medicinal<br />

products that are the subject of adverse reaction<br />

reports be identifiable i.e. traceable. v<br />

2. Health Economics and Pricing<br />

<strong>Biosimilar</strong>s are unlikely to result in the same<br />

price competition as has occurred with the<br />

introduction of generic medicines for a number<br />

of reasons. Firstly, biological medicines including<br />

biosimilars are generally more complex and<br />

costly to produce, e.g. unlike generic medicines,<br />

biosimilars require independent clinical trials to<br />

be undertaken.<br />

Furthermore, the pre-approval regulatory<br />

requirements and post-marketing surveillance<br />

for biosimilars are more rigorous than for<br />

generic medicines, thus adding a further layer to<br />

the cost of producing a biosimilar.<br />

The exact price level of a biosimilar will depend<br />

on the pricing and reimbursement environment<br />

of each country, the competitiveness of the<br />

market and the desire to enc<strong>our</strong>age the future<br />

development of new products.<br />

3. Immunogenicity –<br />

what is it and why does it matter?<br />

Biologicals have the inherent potential to<br />

provoke (unwanted) immune reactions (see<br />

chapter I part 2 above). This potential is one of<br />

the major reasons why biologicals are generally<br />

treated differently to chemical medicines by<br />

regulatory authorities.<br />

While a lot is known today <strong>about</strong> certain<br />

features of biological products that make them<br />

more likely to provoke immune reactions e.g.<br />

high content of host cell proteins and certain<br />

routes of administration, it is currently not<br />

possible to accurately predict immunogenicity in<br />

humans only through non-clinical assessment in


animals. Therefore, immunogenicity assessment<br />

through clinical studies plays a major role in the<br />

development of biological medicines.<br />

At the time a biosimilar receives market approval, a<br />

lot is already known <strong>about</strong> the safety and efficacy of<br />

the product class and the reference product, which<br />

at this point has usually been on the market for<br />

years (or even decades). However, the potential to<br />

provoke immune reactions can differ from product<br />

to product and rare effects can only be detected and<br />

assessed when large numbers of patients have been<br />

treated with a product. At the time of approval,<br />

information on the safety of a medicinal product<br />

is relatively limited for several reasons, such as a<br />

limited number of patients in clinical trials, a limited<br />

time of exposure to the medication and, generally, a<br />

rather strictly defined patient population.<br />

Unlike chemical generics, biosimilars need to have a<br />

“Risk Management Plan” in place. This acknowledges<br />

the special characteristics of biologicals. As with<br />

other new medicines, this Risk Management Plan<br />

defines a set of “pharmacovigilance activities and<br />

interventions designed to identify, characterise,<br />

prevent or minimise risks relating to medicinal<br />

products, and the assessment of the effectiveness of<br />

these interventions”. vi<br />

The potential of biologicals to provoke immune<br />

reactions has been the major reason for treating<br />

biosimilars in the same way as new (biological)<br />

products with regard to post-marketing surveillance.<br />

4. Interchangeability<br />

Interchangeability of medicinal products refers to<br />

the situation where one product is “switched” for<br />

another equivalent product in a clinical setting,<br />

without a risk of an adverse health outcome.<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

Generic medicines, which are considered<br />

bioequivalent, are regarded as “therapeutically<br />

equivalent and therefore, interchangeable” vii .<br />

The current state of scientific knowledge means<br />

that, in general, (chemical) generic medicines<br />

can be deemed interchangeable with their<br />

reference product. Regulatory agencies such as<br />

the European <strong>Medicines</strong> Agency (EMEA) do not<br />

assess the interchangeability or substitutability of<br />

a biosimilar when granting a positive opinion for<br />

a marketing authorisation application. In other<br />

words, the granting of approval does not mean<br />

that the biosimilar product can be interchanged or<br />

substituted with the reference product.<br />

Currently, no clinical studies have been designed<br />

or undertaken to assess the clinical outcome<br />

of repeated switches (changes) of a biological<br />

medicine, whether using two original biological<br />

medicines or an original and a biosimilar.<br />

5. Substitution<br />

Automatic substitution (or generic substitution) is<br />

where the pharmacist substitutes a brand name<br />

(chemical) medicine for a generic version of the<br />

same drug. Some countries make generic substitution<br />

mandatory under certain conditions, for example<br />

where the doctor prescribes by INN. Generic<br />

substitution is often linked to reimbursement; for<br />

example, some health insurance schemes will only<br />

reimburse the patient for the cost of the generic<br />

version of a product. The result of this is that a<br />

patient refusing the generic version and insisting on<br />

the original product must pay the difference in cost.<br />

Generic versions of chemical pharmaceuticals which<br />

have demonstrated their bioequivalence may be<br />

substituted with no risk to patient safety.<br />

13


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

The EMEA has specifically stated that “since<br />

biosimilars and biological reference products are<br />

not identical, the decision to treat a patient with a<br />

reference product or biosimilar medicine should be<br />

taken following the opinion of a qualified health<br />

professional”*. In addition, there is currently no<br />

convincing scientific data to prove that repeated<br />

product switching of biological medicines<br />

(whether biosimilar versions or not) does not<br />

lead to negative clinical consequences. Moreover,<br />

regulators need to remain prudent in matters<br />

relating to the protection of public health.<br />

A number of countries such as France, Italy, Spain,<br />

UK, Netherlands, Germany, Sweden, have either<br />

established legislative measures to prohibit the<br />

automatic substitution of biotech medicines or<br />

have given regulatory advice on the use of biologics<br />

(including prescription by brand). The justification<br />

for such measures is that of patient safety.<br />

EuropaBio firmly believes that other countries that<br />

allow automatic substitution of generic medicines<br />

should take the necessary measures to prevent<br />

automatic substitution of biologics.<br />

*http://www.emea.europa.eu/pdfs/human/pcwp/7456206en.pdf<br />

14


III - The Regulation of <strong>Biosimilar</strong>s<br />

1. In Europe<br />

Chemical medicines can be approved by the national<br />

medicines authorities of individual EU member states.<br />

In contrast, biological products, including biosimilars,<br />

have to follow the “centralized procedure” for<br />

approval carried out by the European <strong>Medicines</strong><br />

Agency (EMEA). Applications submitted to the EMEA<br />

are assessed by its Committee for Human Medicinal<br />

Products (CHMP), which can give a positive or negative<br />

opinion. Upon receipt of a positive opinion from the<br />

EMEA, the European Commission issues a marketing<br />

authorisation which is valid for all EU countries.<br />

Since 2003, the European Union has created<br />

a legal and regulatory pathway to enable the<br />

development and marketing of biosimilar<br />

medicines. Directives 2003/63/EC viii and 2004/27/<br />

EC ix , created a legislative route and the EMEA has<br />

subsequently developed a number of regulatory<br />

guidelines concerning the required data needed for<br />

approval of a biosimilar. Besides the “overarching”,<br />

general guideline on biosimilars, the EMEA has<br />

developed guidelines on quality, on non-clinical<br />

and clinical issues, and product-specific annexes<br />

to those on e.g., insulin, epoetin, somatropin and<br />

granulocyte-stimulating growth factor. At the time<br />

of <strong>publication</strong> of this document, further guidelines<br />

were close to being finalised, including guidelines<br />

on interferon-alfa and low-molecular heparin x .<br />

EMEA’s “overarching” guideline on biosimilars xi<br />

specifically states that biosimilar products are<br />

“by definition” not generics, and that the<br />

generic approach to approval “is scientifically not<br />

appropriate” for biosimilars.<br />

In its document “Questions and Answers on<br />

biosimilar medicines”, the EMEA defines biosimilars<br />

as follows xii :<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

“A biosimilar medicine is a medicine which is<br />

similar to a biological medicine that has already<br />

been authorized (the ‘biological reference<br />

medicine’). The active substance of a biosimilar<br />

medicine is similar to the one of the biological<br />

reference medicine. <strong>Biosimilar</strong> and biological<br />

reference medicines are used in general at<br />

the same dose to treat the same disease. Since<br />

biosimilar and biological reference medicines<br />

are similar but not identical, the decision to<br />

treat a patient with a reference or a biosimilar<br />

medicine should be taken following the<br />

opinion of a qualified healthcare professional.<br />

The name, appearance and packaging of a<br />

biosimilar medicine differ to those of the<br />

biological reference medicine.”<br />

The EMEA Q&A document further states that<br />

the “legislation defines the studies that need<br />

to be carried out to show that the biosimilar<br />

medicine is similar and as safe and effective as the<br />

biological reference medicine”. To this end, the<br />

biosimilar approval pathway requires a biosimilar<br />

manufacturer to demonstrate similarity with the<br />

reference product for quality, safety and efficacy.<br />

Specifically, the biosimilar must demonstrate,<br />

through clinical studies, that it has no significant<br />

clinical differences with the reference product.<br />

<strong>Biosimilar</strong> manufacturers must provide all of<br />

the pre-clinical and clinical data required to<br />

demonstrate the similarity of their product with<br />

the reference product, without the need to repeat<br />

unnecessary tests and trials.<br />

The EMEA assesses the level of data required for a<br />

biosimilar marketing authorisation application on a<br />

case-by-case basis, but the level of data required is<br />

still less than for an original biological.<br />

15


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

A biosimilar manufacturer must undertake<br />

pre-clinical and clinical studies in order to submit<br />

relevant data that establishes the quality, safety and<br />

efficacy of the product, as well as its similarity with the<br />

reference product. The biosimilar must demonstrate<br />

the similarity of its active substance in molecular<br />

and biological terms, to the active substance in<br />

the reference product. In addition, the biosimilar’s<br />

similarity with the reference product should extend<br />

to the pharmaceutical form, strength and route<br />

of administration. The data required can include<br />

pre-clinical data from in-vitro and in-vivo (animal)<br />

testing and data generated by clinical trials in healthy<br />

individuals and the target patient population.<br />

When the reference product has more than one<br />

therapeutic indication, i.e. treats more than one<br />

disease,“the efficacy and safety of the biosimilar<br />

medicine may also have to be assessed using<br />

specific tests or studies for each disease”. xiii<br />

Under certain circumstances, the EMEA allows<br />

extrapolation of indication, i.e. a biosimilar that<br />

has demonstrated comparable safety and efficacy<br />

in the “most sensitive” indication can be assumed<br />

to be able to extrapolate that safety and efficacy<br />

to other indications of the reference product.<br />

However, this extrapolation is only allowed if the<br />

indications share the same mode of action and if<br />

it is “appropriately justified by current scientific<br />

knowledge” xiv , without conducting specific clinical<br />

studies for each of those indications.<br />

As with all biopharmaceuticals, the EMEA requires<br />

biosimilar manufacturers to prepare a risk<br />

management programme (RMP), which comprises<br />

a safety specification, a pharmacovigilance plan,<br />

an evaluation of the need for risk minimisation<br />

activities and (if deemed necessary), a plan for risk<br />

minimisation activities. The pre-clinical and clinical<br />

testing required as part of the abridged biosimilar<br />

16<br />

approval procedure may not reveal all possible<br />

immunogenicity.<br />

This means that preparing a marketing<br />

authorisation application for a biosimilar is more<br />

costly and complex than for a generic medicine.<br />

Generic manufacturers do not usually have to carry<br />

out non-clinical (i.e., animal) studies or clinical<br />

trials when requesting authorisation. Instead, they<br />

need only demonstrate the bioequivalence of their<br />

product with the reference product. For (chemical)<br />

generic pharmaceuticals, this is normally done by<br />

showing that the blood levels of the two products<br />

are the same when given to a small number of<br />

healthy volunteers.<br />

2. Outside of Europe<br />

At the time of <strong>publication</strong>, the European Union<br />

is the only region that has established a specific<br />

approval pathway for biosimilar medicines. The<br />

US congress is still in the process of developing<br />

legislation that would lead to an approval pathway.<br />

The World Health Organisation and numerous<br />

countries around the world such as Argentina,<br />

Canada, Malaysia, Turkey and Saudi Arabia have<br />

produced draft guidelines on biosimilar medicines.<br />

Regulators in Japan and Korea, amongst other<br />

countries, are currently examining the issue of<br />

biosimiliars.


IV - The Market for <strong>Biosimilar</strong>s<br />

1. Which biosimilars are currently available in Europe?<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

The following table shows the biosimilar medicines that have been approved by the EMEA xv :<br />

TRADE NAME INN SPONSOR REFERENCE<br />

PRODUCT<br />

DECISION DATE<br />

Omnitrope ® somatropin Sandoz Genotropin Approve 12/04/2006<br />

Valtropin ® somatropin BioPartners Humatrope Approve 24/04/2006<br />

Alpheon ® Interferon alfa-2a BioPartners Roferon-A Reject 28/06/2006<br />

Abseamed ®1 epoetin alfa Medice Eprex Approve 28/082007<br />

Binocrit ®1 epoetin alfa Sandoz Eprex Approve 28/08/2007<br />

epoetin alfa Hexal ®1 epoetin alfa Hexal Eprex Approve 28/08/2007<br />

Retacrit ®2 epoetin alfa Hospira Eprex Approve 18/12/2007<br />

Silapo ®2 epoetin alfa STADA Eprex Approve 18/12/2007<br />

Insulin Rapid Marvel ® , Long Marvel<br />

30/70 Mix Marvel ®<br />

Insulin Marvel Humulin Withdraw 16/01/2008<br />

Ratiograstim ® Filgrastim Ratiopharm Neupogen Approve 16/09/2008<br />

Biograstim ® Filgrastim CT Arzneimittel Neupogen Approve 16/09/2008<br />

Tevagrastim ® Filgrastim Teva Neupogen Approve 16/09/2008<br />

Zarzio ® Filgrastim Sandoz Neupogen Positive opinion 20/11/2008 (MA<br />

expected 01/2009)<br />

Filgrastim Hexal4 ® Filgrastim Hexal Neupogen Positive opinion 20/11/2008 (MA<br />

2. When are the next biosimilars coming onto<br />

the market?<br />

The EMEA’s Committee for Human Medicinal<br />

Products (CHMP) is currently assessing several<br />

applications for biosimilars and it is expected that<br />

these products will be approved during the c<strong>our</strong>se<br />

of 2008. The CHMP gave a positive opinion on<br />

three biosimilar versions of filgrastim (reference<br />

product: Amgen’s Neupogen) in February 2008<br />

and a revised opinion in July 2008. These three<br />

biosimilars then received a marketing authorisation<br />

from the European Commission in September 2008.<br />

expected 01/2009)<br />

3. What does the market entry of biosimilars mean<br />

for the original innovator products?<br />

<strong>Biosimilar</strong> products will compete with originator<br />

biologicals, many of which already compete with<br />

other originator products made by different biotech<br />

companies. However, in many cases, biosimilars<br />

are copies of older biological medicines, for which<br />

second-generation biological medicines are already<br />

available. This means that the biosimilar products will<br />

mainly compete with the older biological medicines,<br />

rather than with the most recent treatments<br />

developed by originator companies, which can offer<br />

increased therapeutic benefit to patients.<br />

1 The EMEA approved three licenses for the same EPO made by Sandoz, with two additional licenses being granted to marketing partners Hexal and Medice Arzneimittel.<br />

2 The EMEA approved two licenses for the same EPO made by Hosp /STADA<br />

3 The EMEA approved three licenses for the same Filgrastim made by Ratiopharm/Teva/CT Artzneimittel<br />

4 The EMEA approved two licenses for the same Filgrastim made by Sandoz/Hexal


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

...physicians<br />

must be<br />

allowed<br />

to exercise<br />

appropriate<br />

clinical<br />

judgement...


V - The Impact of <strong>Biosimilar</strong>s<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

1. What do patients need to know? Patients need and deserve to be fully informed<br />

<strong>about</strong> any medical treatment they are receiving.<br />

If a physician chooses to prescribe a medicine<br />

to a patient, the patient should be involved in<br />

that decision, understand why that choice has<br />

been made, and what it will mean for his or her<br />

treatment.<br />

Patients may not be completely aware of the<br />

complexities of biologicals, including biosimilars,<br />

and the implications of using them. These<br />

implications include the potential of different<br />

products provoking different immunogenic<br />

reactions in individual patients. It is important<br />

that patients are not obliged to “switch” their<br />

treatment from an originator to a biosimilar purely<br />

on cost grounds, but that the specific therapeutic<br />

needs of the patient are always taken into account.<br />

According to a survey by the International Alliance<br />

of Patients’ Organizations (IAPO), the key concerns<br />

of patients with regard to biosimilars are xvi :<br />

• Cost and the potential to increase access to<br />

biological treatments<br />

• Safety and efficacy<br />

• Patient information and decision-making<br />

• Regulatory process<br />

• Interchangeability<br />

For these reasons it is very important that the label<br />

and other product information relating to the<br />

biosimilar reflect the specific characteristics (clinical<br />

data, reference product, switching advice etc) of<br />

the biosimilar in question.<br />

19


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

2. What do healthcare professionals need to know? Healthcare professionals need to understand the<br />

20<br />

EMEA approval process for biosimilars, in particular<br />

the abridged clinical data requirements, which can<br />

allow the extrapolation of indication for biosimilars<br />

in certain circumstances.<br />

Furthermore, in relation to interchangeability and<br />

substitution, healthcare professionals should be<br />

aware that the two different products may provoke<br />

different immune reactions in different patients.<br />

Physicians should not feel obliged to prescribe a<br />

certain medication purely on the grounds of cost,<br />

but should be allowed to exercise appropriate<br />

clinical judgement.<br />

For these reasons it is very important that the label<br />

and other product information of the biosimilar<br />

reflect the specific characteristics (clinical data,<br />

reference product, switching advice, etc.) of the<br />

biosimilar in question.


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

3. What do payers need to know? Payers, such as national health systems and health<br />

insurance funds, may be interested in cost-saving<br />

potential. Biological medicines tend to be more<br />

expensive than traditional pharmaceuticals for<br />

a number of reasons. These reasons include the<br />

high costs involved in researching, developing,<br />

producing and marketing biological medicines.<br />

It is important for payers to understand the<br />

cost structure of biological medicines, including<br />

biosimilars, with regard to complex manufacturing<br />

procedures and regulatory requirements, which can<br />

require enhanced post-marketing surveillance.<br />

Evidence so far shows that biosimilars will not<br />

result in the same cost savings that generic<br />

medicines have brought. Due to the fact that<br />

biosimilars have been on the market for a relatively<br />

short period of time, it is not possible to accurately<br />

estimate the average price discount compared to<br />

the originator products. In Germany, the biosimilars<br />

that have been launched so far are available at a<br />

price that is around 25% lower than the originator.<br />

However, it is also true that some biosimilars have<br />

the same price as the originator product.<br />

In addition, it is important that payers understand<br />

that, due to the need to remain prudent in matters<br />

of patient safety, automatic substitution for<br />

biologics should not occur and the choice to use<br />

any biological product should remain in the hands<br />

of the treating physician. The physician must be<br />

allowed to exercise appropriate clinical judgement<br />

to select the best available treatment for the<br />

individual patient. Treatment choice should not be<br />

mandated purely for reasons of cost.<br />

21


E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

Glossary of key terms<br />

Adverse event: The occurrence of an undesirable,<br />

unpleasant or life-threatening reaction to a<br />

medicinal product.<br />

Allergy: A disorder of the immune system that<br />

causes reactions such as itching, swollen or<br />

inflamed skin or eyes, runny nose. More extreme<br />

allergic reactions such as anaphylactic shock, which<br />

can be life threatening.<br />

Amino acid: One of several molecules that join<br />

together to form proteins. There are 20 common<br />

amino acids found in proteins.<br />

Antibody (pl: antibodies): Antibodies (also known as<br />

immunoglobulins, abbreviated to Ig) are proteins that<br />

are found in blood or other bodily fluids. Antibodies<br />

are used by the immune system to identify and<br />

neutralize foreign objects, such as bacteria and viruses.<br />

Biological/biotech medicine: A substance made from<br />

a living organism or its products. Biologicals/biotech<br />

medicines may be used to prevent, diagnose, treat<br />

or relieve the symptoms of a disease. For example,<br />

antibodies, interleukins, and vaccines are biologicals.<br />

<strong>Biosimilar</strong>: A similar but not identical version of an<br />

existing biological made following patent expiry by<br />

a different manufacturer than the producer of the<br />

original product.<br />

Biotechnology: Any technological application<br />

that uses biological systems, living organisms, or<br />

derivatives thereof, to make or modify products or<br />

processes for specific use.<br />

DNA: Deoxyribonucleic acid (DNA) is a nucleic acid<br />

that contains the genetic instructions used in the<br />

development and functioning of all known living<br />

organisms and some viruses.<br />

22<br />

Generic (medicine): A copy of an existing (chemical)<br />

medicine, which is bioequivalent to the original<br />

medicine, but is made by a different firm.<br />

Gene therapy: The practice inserting of genes into<br />

an individual’s cells and tissues in order to treat a<br />

disease or correct a generic deficiency.<br />

Genetics: The science of heredity and variation in<br />

living organisms.<br />

Hypersensitivity: The occurrence of undesirable<br />

(damaging, discomfort-producing and sometimes<br />

fatal) reactions produced by the immune system.<br />

Immune system: The collection of mechanisms<br />

within the body that protect against disease by<br />

identifying and killing pathogens and tum<strong>our</strong> cells.<br />

Immunogenic: The potential to cause immune<br />

reactions.<br />

Indication: A valid reason to use a certain test,<br />

medication, procedure, or surgery, which is often<br />

subject to official (regulatory) approval.<br />

Insulin: A hormone that affects metabolism and<br />

causes the body’s cells to take up glucose (sugar)<br />

from the blood and store it as glycogen in the liver<br />

and muscles.<br />

INN: International non-proprietary name.<br />

In-vitro: In the laboratory (outside the body).<br />

In-vivo: In the body (the opposite of in-vitro).


Marketing authorisation: The permission granted<br />

by a regulatory authority to a company to market<br />

a medicinal product following the company’s<br />

submission of required documentation and data<br />

relating to testing and clinical trials of the product.<br />

Medical biotechnology: The production of safe<br />

and effective versions of biological substances<br />

that occur naturally in the human body, in a<br />

scientifically controlled environment in order to<br />

make medicinal products.<br />

Microbiology: The science of studying micro<br />

organisms or microscopic organisms.<br />

Micro-organism: An organism that is so small it<br />

cannot be seen by the human eye.<br />

Molecule: The smallest particle of a substance that<br />

has all of the physical and chemical properties of<br />

that substance. Molecules are made up of one or<br />

more atoms. If they contain more than one atom,<br />

the atoms can be the same (an oxygen molecule<br />

has two oxygen atoms) or different (a water<br />

molecule has two hydrogen atoms and one oxygen<br />

atom). Biological molecules, such as proteins and<br />

DNA, can be made up of many thousands of atoms.<br />

Molecular: Of a molecule<br />

Nucleic acid: A macromolecule composed of chains<br />

of monomeric nucleotides. In biochemistry these<br />

molecules carry genetic information or form<br />

structures within cells.<br />

Patent: A patent is a set of exclusive rights granted<br />

by a state to an inventor or his assignee for a fixed<br />

period of time in exchange for a disclosure of an<br />

invention.<br />

E U R O P A B I O A N D B I O S I M I L A R M E D I C I N E S<br />

Pharmacovigilance: Safety control procedures<br />

which medicines are subject to both before, during<br />

and after their approval by regulatory authorities.<br />

Protein: Large organic compounds made of<br />

amino acids arranged in a linear chain and joined<br />

together by peptide bonds between the carboxyl<br />

and amino groups of adjacent amino acid residues.<br />

Recombinant: In genetics, recombinant means<br />

DNA, proteins, cells, or organisms that are made<br />

by combining genetic material from two different<br />

s<strong>our</strong>ces. Recombinant substances are made in the<br />

laboratory and are being studied in the treatment<br />

of cancer and for many other uses.<br />

Reference product: The original product on which a<br />

biosimilar or generic drug bases its application for<br />

marketing approval.<br />

RNA: Ribonucleic acid is a nucleic acid which is<br />

central to the synthesis of proteins.<br />

Vaccine: A biological preparation which is used<br />

to establish or improve immunity to a particular<br />

disease.<br />

23


Further information<br />

• EMEA working group on biosimilars:<br />

http://www.emea.europa.eu/htms/general/contacts/CHMP/CHMP_BMWP.html<br />

• EMEA guidelines on biosimilar medicines:<br />

http://www.emea.europa.eu/pdfs/human/biosimilar/043704en.pdf (overarching guideline on biosimilars)<br />

http://www.emea.europa.eu/pdfs/human/biosimilar/17073408en.pdf (Erythropoietin products)<br />

• IAPO view on biosimilars:<br />

http://www.patientsorganizations.org/showarticle.pl?id=767<br />

• Wikipedia entry on biosimilars:<br />

http://en.wikipedia.org/wiki/<strong>Biosimilar</strong>s<br />

References<br />

i PhRMA Report, 14 August 2006<br />

ii Adapted from Convention on Biological Diversity (1992)<br />

iii Add PhRMA reference.<br />

iv European Commission proposals to revise EudraLex Volume 9A. For more details please see:<br />

http://ec.europa.eu/enterprise/pharmaceuticals/pharmacos/docs/doc2008/2008_03/pc_vol9_03-2008.pdf<br />

v http://ec.europa.eu/enterprise/pharmaceuticals/pharmacovigilance/docs/public-consultation_12-2007.pdf<br />

vi EMEA “Guideline on Risk Management Systems for Medicinal Products for Human Use”<br />

vii US, Orange Book<br />

viii “In case the originally authorized medicinal product has more than one indication, the efficacy and safety of the medicinal<br />

product claimed to be similar has to be justified or, if necessary, demonstrated separately for each of the claimed indications”<br />

(part II, 4 of Directive 2003/63/EC).<br />

ix “Where a biological medicinal product which is similar to a reference medicinal product does not meet the condition in<br />

the definition of generic medicinal products, owing to, in particular, differences relating to raw materials or differences in<br />

manufacturing processes of the biological medicinal product and the reference biological medicinal product, the results of<br />

appropriate pre-clinical tests or clinical trials relating to these conditions must be provided” (article 10 of Directive 2004/27/EC).<br />

x For guidelines on biosimilars see: http://www.emea.europa.eu/htms/human/humanguidelines/multidiscipline.htm<br />

xi EMEA “Guideline on Similar Biological Medicinal Products” (CHMP/437/04)<br />

xii EMEA’s “Questions and Answers on biosimilars (similar biological medicinal products)”<br />

xiii EMEA’s “Questions and Answers on biosimilars (similar biological medicinal products)”<br />

xiv “Guidance on <strong>Biosimilar</strong> Medicinal Products Containing Erythropoietins”; EMEA/CHMP/94526/2005<br />

xvi See: http://www.patientsorganizations.org/<br />

Avenue de l’Armée 6, B-1040 Brussels - Belgium<br />

Tel : (+32.2) 735.03.13 • Fax : (+32.2) 735.49.60<br />

E-mail : info@europabio.org • www.europabio.org

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