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Review ArticleOpen Access

A Comparative Study on the Dossier Submission for Pharmaceutical Products: Global Review Volume 48- Issue 1

Swathi J1, Muthu Pranesh K1, Pavithran T1, Nivetha D1, D Nagasamy Venkatesh2*, N Arun2 and SD Shanmugakumar3

  • 1Department of Pharmaceutical Regulatory Affairs, JSS College of Pharmacy, JSS Academy of Higher Education & Research, Ooty – 643001, The Nilgiris, Tamil Nadu, India
  • 2Department of Pharmaceutics, JSS College of Pharmacy, JSS Academy of Higher Education & Research, Ooty – 643 001, The Nilgiris, Tamil Nadu, India
  • 3Jyothishmathi Institute of Pharmaceutical Sciences, Karim Nagar -505 001, Telangana, India

Received: December 12, 2022;   Published: January 11, 2023

*Corresponding author: D Nagasamy Venkatesh, Department of Pharmaceutics, JSS College of Pharmacy, JSS Academy of Higher Education & Research, Ooty – 643 001, The Nilgiris, Tamil Nadu, India

DOI: 10.26717/BJSTR.2023.48.007589

Abstract PDF

ABSTRACT

The Dossier is a series of papers on various topics. The process of reviewing and analyzing the pharmaceutical product dossier, which has administrative, quality, non-clinical and clinical data. The Drug Regulatory Authority in a specific country regulates and authorizes this process and the process is known as New Drug Application in the United States of America, Marketing Authorization Application in the European Union and other countries simply as the Registration Dossier. For dossier preparation, there are essentially two formats, i.e., Asean Common Technical Dossier and International Conference on Harmonization- Common Technical Dossier. International Conference on Harmonization- Common Technical Dossier is followed by International Conference on Harmonization countries and low economic or developing countries where Asian countries follow the Asian Common Technical Dossier. Asian Common Technical Dossier serves as the bridge between developed and emerging countries’ regulatory requirements. To harmonize both Common Technical Dossier and Asian Common Technical Dossier guidelines, discrepancies and variations in both guidelines can be reduced. As a result, the clear regulatory strategy should be carefully understood and established through an examination of the target regions, the various terms and conditions of the patent and its extension, the various implementation options, the data needs, and the potential schedule for marketing launches in the various regions.

As a result, less testing is required, drug approvals are launched more quickly, and the overall cost of manufacture is reduced. A high-quality dossier is required for any export market and can be created through the methodical production of formulas. A consistent dossier and responses to regulatory authorities’ questions could benefit from careful planning and formulation production. It is challenging for pharmaceutical companies to design therapeutic formulations that can be concurrently submitted for approval in many countries because the regulatory standards of various nations differ from one another. Therefore, there are ongoing procedures of harmonization around the world.

Keywords: ICH- CTD; ACTD; eCTD; Dossier Submission

Introduction

Dossier submission is a set of records and data summarizing the entire history of product production and evolution. The marketing approval of a product depends upon the dossier, and it is the vehicle to the regulatory agency for the product approval. The dossier submission is done after the successful completion of the phase III clinical trial. The information presented in the dossier includes product chemistry, formulation, manufacture, toxicology, pharmacology, pharmacokinetics, and clinical studies. Another part of the dossier contains the companies dedicated work in phase IV. For example, in US and Europe, companies must include the pediatric study plan [1]. The steps involved during and after the dossier submission is given in (Figures 1 & 2).

Figure 1 Steps involved during the dossier submission.

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Figure 2 Steps involved after the dossier submission.

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Planning

1) Plan the submission according to the given timeline.

2) Gain complete knowledge about the respective agencies and their submission requirements and format

3) Listing down all the requirements to be submitted to the agency and distributing it to the respective department.

Formatting and Compilation

Formatting the dossier according to the country specific requirements and compile all the documents.

Review

The documents are again re-checked, and cross verified before submitting to the agency. The delay in the following and the meeting can jeopardies the time to market the drug, which is a great loss for the company [2].

Dossier Submission Types

The dossier submission may vary from one country to another. The types of dossier submission include: CTD, eCTD, ACTD, NeeS, paper submission.

Common Technical Document (CTD)

The CTD is a well-structured, globally accepted common format maintained by the ICH with regard to technical criteria for the registration of human pharmaceuticals. The ICH-CTD is a collaborative project of three regulatory agencies, Europe, the USA and Japan. The CTD is one of the cross-cutting themes that does not fall into one of the categories of efficiency, protection and effectiveness, and is part of the multidisciplinary guideline [3].

CTD Modules:

Module 1: Regional and Administrative Information: It is not considered to be a section of CTD. It includes regional information. It includes administrative documents such as application forms, legal documents, proposed label etc [4].

Module 2: CTD Overview and Summaries: This module consists of the common technical document summary containing information from module 3 to 5 which consists of seven sections.

Section 1 – Table of contents

Section 2 – Introduction

Section 3 – Quality overall summary

Section 4 – Non-clinical overview

Section 5 – Clinical overview

Section 6 – Non-clinical written and tabulated summaries

Section 7 – Clinical summary

Module 3: Quality

Module 3 contains information about Drug Substance, Drug Product, Literature References [5].

Module 4: Non-clinical

Module 4 contains information about reports on pharmacologic, pharmacokinetic, and toxicological studies [6].

Module 5: Clinical

Module 5 contains information about safety and efficacy reports of clinical studies.

eCTD – Electronic Common Technical Document

It is the electronic form of a common technical document which is submitted by the applicant to the regulator in order to obtain approval for marketing the product. It is made up of individual PDF documents that are structured in accordance with the CTD structure. The information is provided by cross linking the document using XML backbone. The electronic submission is very useful for the reviewer of the regulatory authority [6]. It is superior technology and is a single application format for all applications [7].

eCTD Structure

1) Modules: 1 to 5

2) Documents: PDF linked via XML backbone

3) The submissions are highly transparent, easy to navigate and review.

Significance of eCTD

1) It is a common format which is being accepted in all countries

2) Helps in reviewing the application and in order to avoid the omission of the data

3) The review or communication of the regulatory facilities are done in time

4) Since it is an electronic submission, the patient population receives the medicines at appropriate time [8] (Table 1).

Table 1: Comparison of Dossier Submission Requirements in US, EU and INDIA [9].

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Conclusion

For the governing agencies to approve the drug for sale, a dossier including comprehensive details on the drug and the results of the studies conducted during its development phase is required. CTD is crucial for dossier submissions. A high-quality dossier is required for any export market and can be created through the methodical production of formulas. A consistent dossier and responses to regulatory authorities’ questions could benefit from careful planning and formulation production. It is challenging for pharmaceutical companies to design therapeutic formulations that can be concurrently submitted for approval in many countries because the regulatory standards of various nations differ from one another. Therefore, there are ongoing procedures of harmonization around the world. As a result, the clear regulatory strategy should be carefully understood and established through an examination of the target regions, the various terms and conditions of the patent and its extension, the various implementation options, the data needs, and the potential schedule for marketing launches in the various regions. As a result, less testing is required, drug approvals are launched more quickly, and the overall cost of manufacture is reduced.

Funding Statement

The research did not receive any specific grant from funding agencies in the public, commercial, or non-profit sectors.

Conflict of Interest

The author(s) declared no potential conflict of interest concerning this article’s research, authorship, and/ or publication.

Acknowledgement

The authors would like to thank the department of science and technology- fund for the improvement of science and technology infrastructure in universities and higher educational institutions (DST- FIST), New Delhi, for the infrastructure support to our department.

References

  1. Swapna G, Akhilesh Chandra (2014) Comparative study of dossier submission process for drug product in USA, EU & Indian regulatory. World Journal of Pharmaceutical Research 3(6): 406-411.
  2. Shrikant Godiyal (2019) Regulatory requirements for preparation of dossier for registration of pharmaceutical products in ACTD and CTD format. International Journal of Drug Regulatory Affairs 7(2): 51-61.
  3. Nisar Ahammad, Nagarjuna Reddy, MV Nagabhushanam, Brahmaiah Ramakrishna (2019) Challenges Faced During eCTD and CTD Filling Procedures for USFDA and Canada. Journal of Drug Delivery & Therapeutics 9(4): 673-679.
  4. Debbie Jordan (2014) An overview of the common technical document (CTD) regulatory dossier. The European Medical Writers Association 23(2): 101-105.
  5. Varun Garg, Sachin Kumar Singh, Monica Gulati, Bimlesh Kumar, Neeraj Mittal Garg, et al. (2017) A comparative study of common technical documents in different regulated markets. Journal of Pharmacy Research 11(8): 1015-1024.
  6. Randeria Juhi (2018) Regulatory Requirements for dossier submission in African countries (Kenya, Uganda and Tanzania) – A Review. International Journal of Drug Regulatory Affairs 6(2): 14-21.
  7. Veerendar Kr Gautam, Mohamad Irfan (2017) A study of procedures for dossier preparation and their marketing authorization in different countries of selected drugs. PharmaTutor 5(10): 8-22.
  8. Badjatya Jitendra Kumar, Ramesh Bodla (2013) Drug product registration in semi-regulated market. International Journal of Drug Regulatory Affairs 1(2): 1-6.
  9. Shweta Handoo, Vandana Arora, Deepak Khera, Prafulla Kumar Nandi, Susanta Kumar Sahu (2012) A comprehensive study on regulatory requirements for development and filing of generic drugs globally. International Journal of Pharmaceutical Investigation 2(3): 99-105.