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Microbiome Products

Forging a path for your microbiome product

Navigating the complexities of development, approval, and commercialization

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understanding microbiome regulations VCLS expertise

KEY FIGURES

50+

Microbiome programs supported​

20+

Live biotherapeutic products (LBP)​

30%

Advanced to clinical stage​

​​Pioneering Innovation in the Microbiome Field

  • Leading the advancement of the microbiome regulatory framework, working with regulators, associations and expert groups
  • Award-winning microbiome team (2023 TOPRA for communication)​

Comprehensive Product Expertise​​

Proven experience and a wide range of expertise to guide development of ingredients, of live/inactivated micro-organisms alone/in consortia, and of substances derived from microbiome as drugs (including LBPs, ATMPs), tissue- and cell-based products, medical devices, IVD/CDx, nutraceuticals, and cosmetics.​

FAQs

What regulatory framework should be followed during the international development of a microbiome product?

The relevant regulatory framework should be defined on a case-by-case basis, taking into account, in particular, the region(s) of interest and the characteristics of the microbiome product.

 

Regulations and, therefore, product positioning may vary from one region to another. Standards and/or guidelines specific to the type of microbiome product of interest may be used, as well as non-product specific, transversal references.

 

Their technical formats are significantly different. While the IND is published to the FDA in the eCTD format, a clinical trial application (CTA) in the EU under the CTR must be processed through the online platform called the 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.

 

For example, for live biotherapeutic products (LBPs), both the US and the EU have set requirements specific to this type of product. Principles established in local and international guidelines for biological products can be followed, such as the ones from the EMA guideline on quality documentation for biological investigational medicinal products in clinical trials and from the ICH guidelines on the quality of biotechnological products. Finally, transversal materials can also be (partially) applied, such as the FDA Guidance for Industry: INDs for Phase 2 and Phase 3 Studies: Chemistry, Manufacturing, and Controls Information and the ICH General Principles for Planning and Design of Multi-Regional Clinical Trials.

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Under what conditions can microorganisms be incorporated in medical devices (MD) ?

To qualify as an MD in the EU, the product should not include viable microorganisms that achieve or support the intended purpose. These must also be considered in determining the risk class of the MD.

 

It should be demonstrated that the microorganisms incorporated in the MD have no potential for metabolism or multiplication.

 

Appropriate validation should be put in place to demonstrate the absence of viable microorganisms in the final product.

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Are there microbiome-specific safety considerations ?

As with any innovative therapy, it is crucial to demonstrate both the safety and efficacy of a microbiome product before administration to humans.

 

Microbiome products must therefore be tested in toxicology studies to obtain a safety profile. Given the variety of microbiome products, the toxicological evaluation program must be defined on a case-by-case basis and tailored to the intrinsic characteristics of the microbiome product.

 

In the case of a live biotherapeutic product, the nonclinical studies must assess the potential effect(s) of the microorganisms themselves and of the molecules derived from them, on the recipient of the therapeutic product itself and on the host microbiota. Toxicology studies may include, but are not limited to, biodistribution, colonization, shedding, general toxicology, immunogenicity/immunotoxicity, genotoxicity, and reprotoxicity assessments. Given the case-by-case approach, it is strongly recommended to initiate interactions with agencies early on to discuss the safety package to support clinical trials and future registration.

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Are there specific requirements to consider for the EU clinical development of a microbiome-based medicinal product which has undergone genetic modifications?

On top of clinical trial requirements, the regulatory framework for genetically-modified organisms (GMOs) should be considered.

 

Clinical development of GMO investigational medicinal products may be pursued under deliberate release or contained use conditions. The authorities in charge of approval, the process for application, as well as the required supportive documentation will depend on the selection of the country or countries in which the clinical investigation will be conducted.

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Are there adequate nonclinical models available to develop a microbiome product?

The selection and generation of a nonclinical study model for microbiome research remains a challenge, given the variability and complexity of the human microbiome.

 

The main question is not “Are there any nonclinical models?” but rather, “What do we need to demonstrate using a nonclinical model?”.

 

To date, many nonclinical models have been and are being developed, such as the in vitro simulator of the human gut microbial ecosystem (SHIME), or germ-free or gnotobiotic (i.e., inoculated with a defined microbiota animal models). The panel of nonclinical models includes in silico, in vitro, ex vivo and in vivo models, which are selected on a case-by-case approach depending on the question to be addressed based, in particular, on the target clinical indication, the target population, and the route of administration. Thus, there are a large number of models that developers can choose and combine to demonstrate the safety and efficacy of their product.

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Related Glossary

Bacteriophages (phages)
Live Biotherapeutic Products (LBP)
Microbiome
Fecal Microbiota Transplant (FMT)
Micro-organism

Questions? Get the answers by our expert team ​

No two product development paths are the same. Talk to our experts about your development challenges and we will provide you actionable recommendations.​