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Clinical Regulatory

Global regulatory solutions for your clinical study

Global regulatory support, ensuring seamless IND and CTA submissions, ongoing maintenance, and expedited study start-up timelines.

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KEY FIGURES

20+

New US INDs filed per year

20+

Initial & transition CTA under the EU CTR

100+

Currently maintained INDs/CTAs globally

Secure the path for the authorization of your clinical trial

We accompany you from early training of your stakeholders, through the definition of your Clinical Trial filing strategy and planning, identification and controls of regulatory requirements, and execution of your submission and interactions with evaluating bodies.

Your global regulatory partner to achieve your operational objectives

Integrated to deliver clinical research services or partner with third-party CROs, we coordinate global trial submissions with local regulatory and in-house expertise to accelerate your applications.

Compliance and excellence as a key driver for your development

Our unwavering commitment to precision, efficiency, and quality ensures your submissions meet global standards, paving the way for streamlined approvals and accelerated development timelines.

FAQs

Can I convert my IND into the EMA’s CTR?

Not literally. The FDA’s US IND and the EU CTR support the same purpose: authorizing clinical trials with medicinal products.

 

Their technical format is significantly different. While the IND is published to the FDA under eCTD format, a clinical trial application (CTA) in the EU under the CTR must be processed through the online platform called Clinical Trials Information System (CTIS). This format mostly relies on data/information entered into the system’s forms, as well as a number of documents, generally in PDF format.

 

However, their content can be similar to some extent. For example: the study protocol, compliant with ICH standards and designed with international purpose, can be the same. Also, Quality data (Module 3) of the IND can be converted into the European Investigational Medicinal Product Dossier (IMPD).

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Does the EMA review CTA under the CTR?

No. The authorization and oversight of clinical trials is the responsibility of EU/EEA Member States while the European Medicines Agency (EMA) is responsible for maintaining CTIS. The European Commission (EC) oversees the implementation of the Clinical Trials Regulation.

 

The European Commission (EC) oversees the implementation of the Clinical Trials Regulation.

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Which countries are concerned by the EU CTR?

With CTIS, sponsors can now apply for authorizations in up to 30 EU/EEA countries at the same time and with the same documentation.

 

All EU member states (to date 27 countries), as well as the EEA member states, adding up Norway, Iceland, and Lichtenstein, to a total of 30 countries concerned.

 

The United Kingdom (UK) and Switzerland (CH) are not concerned by the EU CTR and operate clinical trial applications under their own national disposals.

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What is the deadline for transitioning ongoing trials to the CTR?

CTR transitional application must be approved before 30 January 2025 EOB CET. An expedited transition procedure will remain open until 16 October 2024 focusing on the validation of minimum application dossiers restricted to documents already authorised under the CTD.

 

After this date and depending on the MS workload, an expedited procedure may not be available.

 

VCLS invites sponsors with eligible trials to make CTR transition their priority early in 2024 as steps may be required before being able to submit the transitional application.

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Is it exact that no Request for Information (RFI) can be received during CTR transition procedure?

The regulation anticipates in applicable timelines that member states concerned can issue queries (called Request For Information, RFI) during the evaluation of CTR transitional applications.

 

However, considering that these procedures involve the submission of a set of documents previously evaluated and approved by the member states concerned, the EMA expects the occurrence of RFI during transitional applications to be unusual.

 

VCLS’ experience so far has proven this effectively occurred, more than sporadically, and we invite sponsors to not bet only on the best-case scenario (and timeline) when planning their CTR transition.

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Do CTR transparency provisions apply to CTR transition?

Yes, documents submitted by the sponsor as part of the transitional application do fall under the transparency requirements of the CTR and have to be made publicly available.

 

Compliance with CTR transparency provisions (management of public disclosure and protection of private personal data, PPD, and commercially confidential information, CCI) generally implies the submission of redacted and sanitized versions (for public disclosure) in addition to full versions of CTA documents (reserved to evaluators, hence not for publication).

 

These mechanisms shall be considered as of the transitional application considering that all eligible data and documents in the CTIS will be concerned by the public disclosure policy applied by the CTR.

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Is the CTR applicable to my medical device study?

The CTR (European Clinical Trials Regulation, EU 536/2014) is applicable to all clinical trials with medicinal products (drugs).

 

To some extent, the provisions of the CTR may be applicable to non-approved or off-label authorized medicinal products used in clinical investigations for medical devices, or some drug-device combination products.

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Related Glossary

Clinical Trial Application (CTA)
Investigational New Drug (IND)
Common Technical Document (CTD)

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