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Biosimilars

Development, Approval & Interchangeability — biosimilar vs generic, the comparability exercise, CDSCO-DBT / EMA / US FDA 351(k) pathways, immunogenicity & pharmacovigilance (an RGUHS Paper IV LAQ)

Past RGUHS · 1 RGUHSMay '22

Biosimilars: Development, Approval & Interchangeability

1. Definition & terminology

  • A biosimilar ("similar biologic" in Indian regulatory parlance) is a biological/biotechnology-derived product that is highly similar to an already-licensed reference biologic (innovator product), with no clinically meaningful differences in terms of safety, purity, potency and efficacy, despite minor differences in clinically inactive components (Shargel 8e Ch.29, pp.26–27).
  • The Indian term of art is "Similar Biologic", defined as a product "similar in terms of quality, safety and efficacy to an already authorized Reference Biologic" (CDSCO–DBT Similar Biologics 2016, §3 [CDSCO]).
  • A biosimilar is, by definition, similar and NOT identical to its reference biologic — even two batches/lots of the same reference biologic are not identical to each other (Shargel 8e Ch.29, p.28).
  • Regulators coined "biosimilar" to denote a follow-on biologic "as close as possible to a reference biologic, in an almost analogous way that a generic drug is versus a reference drug" — but the analogy is deliberately loose because the active substance cannot be proven identical (Shargel 8e Ch.29, p.26).
  • Distinguish related "follow-on" terms (Shargel 8e Ch.29, pp.9–11):
    • Generic — follow-on of a small-molecule (chemically synthesised) drug; API is identical to the reference; demonstrates bioequivalence (BE).
    • Biosimilar / Similar Biologic — follow-on of a biologic; API is highly similar but not identical; demonstrates biosimilarity via a comparability exercise.
    • "Biobetter" (not a formal regulatory term) — an intentionally engineered improvement over the reference biologic (e.g. modified glycosylation, longer half-life); regulated as a new biologic / stand-alone product, NOT as a biosimilar.
    • A "supergeneric" is the small-molecule analogue of a biobetter — an improvement (less frequent dosing, combination) filed as a new drug application/submission, not a generic (Shargel 8e Ch.29, p.9).
  • Reference biologic (CDSCO term) = the innovator's product approved after evaluation of a complete (full safety, efficacy, quality) dossier. Another similar biologic can NEVER serve as the reference (CDSCO 2016 §6.1 [CDSCO]).
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Biosimilars

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