Latest Regulatory Updates

March 2025

Hello and welcome back to the Boyds Regulatory Intelligence Digest. In this edition, we are sharing the latest guidance, insights and key developments from the regulatory agencies - FDA, EMA, MHRA, and EC.

To discuss any of these updates, please contact a member of the Boyds Regulatory team who will be happy to help.
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Food and Drug Administration (FDA)

Bioanalytical Method Validation for Biomarkers Guidance

This guidance helps sponsors and applicants in the development and validation of bioanalytical methods used to evaluate in vivo biomarker concentrations. The purpose of this guidance is to provide information on biomarkers, which is absent from the current guidance for industry M10 Bioanalytical Method Validation and Study Sample Analysis (November 2022). Upon the publication of this FDA guidance, the previous guidance for industry Bioanalytical Method Validation (May 2018) will be withdrawn.

Considerations for Including Tissue Biopsies in Clinical Trials; Draft Guidance for Industry, Investigators, Institutions, and Institutional Review Boards

This draft guidance provides recommendations regarding considerations for tissue biopsies that may be conducted in adults and in children as part of clinical trials that evaluate investigational medical products and/or that are conducted or supported by the Department of Health and Human Services (HHS).

Considerations for Complying With 21 CFR 211.110

This draft guide discusses the 21 CFR 211.110 to ensure batch uniformity and drug product integrity in human and veterinary drug products (not applicable to active ingredients only). In addition, quality considerations for drug products that are manufactured using advanced manufacturing (including techniques such as 3D printing) are also discussed, including how manufacturers can incorporate process models 20 into commercial manufacturing control strategies.

Study of Sex Differences in the Clinical Evaluation of Medical Products

This draft guide seeks to support developers in generating clinical trial data in female participants to ensure that representative data is available for females regarding the benefits and risks of medicinal products, particularly in underrepresented therapeutic areas. The guidance also applies to males, who may also be underrepresented in specific therapeutic areas.

European Medicines Agency (EMA) and the European Union (EU)

Guideline on quality, non-clinical and clinical requirements for investigational advanced therapy medicinal products (ATMPs) in clinical trials

Recognising that ATMPs have distinctive properties and complexities, which make traditional approaches to clinical development challenging, EMA has issued a dedicated guideline that aims to support ATMP developers on the structure and data requirements for a clinical trial application (CTA) for exploratory and confirmatory trials. The guidance is focussed on clinical development but includes a perspective towards Marketing Authorisation Applications (MAA). The guide comes into effect 01 July 2025.

Changing the labelling and package leaflet (Article 61(3) notifications)

Updates have been presented on the EMA dedicated page for Changes to labelling and package leaflets. These cover requirements for marketing authorization holders (MAHs) to use the IRIS platform when managing the labeling and package leaflet after the original submission. 

Data protection notice regarding personal data processing in the Clinical Trials Information System (CTIS) 

EMA have issued a data protection notice to explain the processing of personal data in CTIS including CTAs and trial lifecycle and submission and evaluation of annual safety reports (ASRs).

Conversations on cancer - cervical cancer treatment innovation: a collaborative discussion Webinar Recording

EMA have released the video recording of the Conversations on Cancer program webinar held in January 2025. This event outlined the historical path that has led to the current treatment landscape, the impact of new therapies on individuals with cervical cancer and their families, areas of ongoing high-impact research, and what the future might bring.

Simultaneous National Scientific Advice (SNSA) - Continuation and further development during 2025

Following a positive evaluation of the results of the SNSA pilot project at the 119th HMA (Heads of Medicines Agencies) meeting in January 2025, the HMA has supported the continuation of the SNSA concept. During 2025, the SNSA Working Group will continue to work on an optimised SNSA procedure, taking into account the learnings from the pilot. In the meantime, applicants can continue submitting new SNSA requests via snsa@fagg-afmps.be according to the currently available SNSA scope, procedure and timelines. Further details on the optimised SNSA procedure, including associated guidance, will be published later in 2025.

EMA establishes regular procedure for scientific advice on certain high-risk medical devices

A standard procedure has been established for manufacturers of certain high-risk medical devices to request scientific advice on their intended clinical development strategy and proposals for clinical investigation. More information on the submission process is available on EMA’s website.

There are currently no fees associated with these requests.

However, manufacturers of high-risk medical devices intended for the treatment of a rare condition should apply for advice via the ongoing pilot program to support orphan medical devices.

Medicines and Healthcare products Regulatory Agency (MHRA), HRA & GOV.UK

Digital mental health technologies guidance launched to help manufacturers and safeguard users

This new guidance helps manufacturers navigate medical device regulations and protect users of digital mental health technologies to ensure they are effective, reliable and acceptably safe.

MHRA asks for views on proposed guidance to support the safe regulation of new personalized cancer therapies  

MHRA has launched a consultation on regulatory guidance for individualized mRNA cancer immunotherapies, running until 31 March 2025. The guidance aims to streamline pathways for bringing these therapies through to patients without compromising on robust safety principles.


MHRA Real-World Evidence Scientific Dialogue Program

The MHRA is launching a pilot RWE Scientific Dialogue Program in 2025, designed to support developers in their evidence generation strategies and promote early access to innovative products through RWE that facilitates robust decision-making across the lifecycle. Selected applicants will benefit from a confidential virtual meeting with the MHRA and a joint workshop with MHRA and National Institute for Health and Care Excellence (NICE) to promote open discussions relating to RWE in a confidential and pre-competitive setting. The MHRA will not charge fees for the pilot phase of the RWE Scientific Dialogue Program.


Decision tree for navigating nanotechnology-based products for medical application

MHRA provides a decision tree to help researchers and developers of nanomedicines understand how different guidelines from the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) and European regulatory agencies can be applied to support their development programs.


UK patients enabled access to transformative new medicines in the shortest time possible via new, integrated Innovative Licensing and Access Pathway

MHRA have refreshed the UK-wide ILAP, which will offer a clearer, more streamlined and integrated process for developers to help get transformative new medicines to patients in the National Health Service (NHS) in the shortest time possible. 

The new ILAP has been launched by the MHRA, the Health Technology Appraisal Bodies (the All Wales Therapeutics and Toxicology Centre (AWTTC), the National Institute for Health and Care Excellence (NICE), the Scottish Medicines Consortium (SMC) and the NHS.

European Commission (EC)

Commission launches a public consultation and a call for evidence for EU Medical Devices evaluation

The Commission has launched a public consultation and a call for evidence on the EU’s legislation on medical devices and in vitro diagnostic medical devices, as part of the targeted evaluation of these rules. The consultation provides stakeholders with the opportunity to express their views on how the current rules are performing and to highlight possible shortcomings. The consultation and call for evidence will be open until 21 March 2025 and are accessible here.

MDCG 2023-3 rev.2 - Questions and Answers on vigilance terms and concepts

MDCG has issued an update to MDCG 2023-3 rev.2 - Questions and Answers on Vigilance Terms and Concepts under Regulations (EU) 2017/745 (MDR) and 2017/746 (IVDR), dated January 2025. This document clarifies key terms and concepts from Section 2 of Chapter VII of the MDR and IVDR, incorporating relevant updates from the Guidelines on a Medical Devices Vigilance System with modifications for alignment.

Key updates are to Q1 has been amended to align with Regulation (EU) 2024/1860 amending Regulations (EU) 2017/745 and (EU) 2017/746 as regards a gradual roll-out of Eudamed, the obligation to inform in case of interruption or discontinuation of supply, and transitional provisions for certain in vitro diagnostic medical devices. Question 2 Reference to ‘Eudamed vigilance (VGL) module’ is amended to ‘Eudamed Postmarket surveillance and Vigilance module (VGL module)’.  Footnote 34   ’48 working hours’ replaced with ‘allow 48 hours (equivalent to two weekdays)’.

The guide is available here.

Combined studies and COMBINE strategy
December 16th, 2024 EU National authorities in Member States have endorsed a new strategy for the COMBINE program, (a cross-sector initiative to streamline combined studies of medicines and medical devices, including diagnostics).

The strategy can be found on the Commission’s webpage: Combined studies and COMBINE strategy

The COMBINE program will be rolled out over the coming years through seven cross-sector projects. Among the goals of this program are to:

  • Pilot a single assessment process for multi-country combined studies across device and medicinal product regulations
  • Harmonise serious adverse event reporting processes
  • Clarify questions on the interface between clinical trials and medical device regulations
  • Explore new opportunities for advising sponsors and facilitating knowledge exchange among national authorities

Pilot coordinated assessment for CI/PS

Member States, supported by the European Commission, have launched a pilot coordinated assessment of clinical investigations and performance studies across multiple Member States as per Article 78 of the EU MDR and Article 74 of the IVDR.

This pilot will allow sponsors to submit a single application for pilot-coordinated assessments, assuring more harmonized interaction with the Member States approving the clinical investigation or performance studies.

It is hoped this pilot will help put in place a fast and fit-for-purpose EU system for coordinated assessment once its mandatory operation starts. The aim is to implement a harmonized, predictable process across Member States, reducing administrative burden for sponsors and ensuring high transparency and consistency in the coordinated assessment.

Advice on SARS-CoV-2 on request from the Medical Device Coordination Group

The IVD expert panel has provided new scientific advice on SARS-CoV-2. This information may affect how SARS-CoV-2 tests are classified under the EU IVR. Manufacturers are encouraged to assess how this advice impacts their devices and consult with their notified body as to the conformity assessment steps to be taken in case of a change in risk class.

The MDCG guidance on IVD classification (MDCG 2020-16) is being updated to reflect this advice.

Revised versions and new guidance are available in the EMDN section

There are a number of updates to guidance in the European Medical Device Nomenclature (EMDN) as follows:

MDCG 2025-3: EMDN Version History 

MDCG 2025-2: Summary of EMDN 2024 Submissions and outcome of annual revision

MDCG 2025-1: EMDN Ad hoc procedure  

MDCG 2024-2 rev.1: Procedures for the updates of the EMDN

MDCG 2021-12 rev.1: FAQ on the European Medical Device Nomenclature (EMDN)

Podcast: Conversations in Drug Development

How to Effectively De-Risk your IND

In this episode, Dr. Nick Meyers and Dr. Eric Hardter, discuss effective strategies for de-risking Investigational New Drug (IND) applications.

Discover key insights on how to navigate the complexities of IND submissions, including the importance of pre-IND meetings, optimizing your non-clinical and CMC packages, and understanding FDA expectations. Gain valuable tips on engaging with regulatory agencies, addressing potential issues, and ensuring your IND is well-prepared to avoid clinical holds. Whether you're a seasoned professional or new to the field, this episode offers practical advice to help streamline your drug development process.

Visit, Podcast | Conversations in Drug Development | Boyds (boydconsultants.com) or listen on Spotify, Amazon Music or Apple Podcasts by searching for "Conversations in Drug Development".

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