Advanced Therapy Medicinal Products (ATMPs) represent a significant breakthrough in modern medicine, offering new hope for conditions once considered untreatable - from rare diseases to cancer and more prevalent disorders. These innovative therapies form a diverse and rapidly evolving class of medicines, driven by continuous scientific advancements. While each ATMP holds the potential to transform patient care, they also present unique opportunities and challenges.
The development of ATMPs in Europe is governed by a highly complex and multilayered regulatory framework that ensures product safety, efficacy, and quality while balancing scientific innovation and patient access. ATMPs - including gene therapies, somatic-cell therapies, and tissue-engineered products - are primarily regulated under Regulation (EC) No 1394/2007 [1], which supplements the broader Directive 2001/83/EC governing medicinal products. The European Medicines Agency (EMA) and its Committee for Advanced Therapies (CAT) play a central role in scientific evaluation and marketing authorization.
However, ATMP development often intersects with additional regulatory regimes. For cell- and tissue-based products, the Substances of Human Origin (SoHO) framework - including Directive 2004/23/EC [2] - sets requirements for donation, procurement, and testing, ensuring traceability and donor protection. This adds an additional compliance layer, especially during early manufacturing stages. For ATMPs administered via or in combination with medical devices (e.g., cell-seeded scaffolds or gene delivery systems), the Medical Device Regulation (MDR, 2017/745) [3] and the In Vitro Diagnostic Regulation (IVDR, 2017/746) [4] introduce further obligations, including conformity assessments and clinical evaluation requirements. Determining the primary mode of action becomes critical for classification and regulatory pathway selection. Additionally, ATMPs involving genetically modified organisms (GMOs) - such as CAR-T cells or gene-edited stem cells - must adhere to Directive 2001/18/EC (deliberate release of GMOs) [5] and Directive 2009/41/EC (contained use of GMOs) [6]. This dual oversight can complicate clinical trial applications, as GMO-specific environmental risk assessments are required alongside clinical safety data, with national-level variations adding complexity.
Navigating these interconnected regulatory layers demands a holistic approach, early regulatory engagement, and strategic planning. Understanding the interplay of medicinal product, SoHO, device, and GMO frameworks is essential for successful ATMP development, ensuring both regulatory compliance and patient-centric innovation.
References
[1] Regulation (EC) No 1394/2007 of the European Parliament and of the Council of 13 November 2007 on advanced therapy medicinal products and amending Directive 2001/83/EC and Regulation (EC) No 726/2004.
[2] Directive 2004/23/EC of the European Parliament and of the Council of 31 March 2004 on setting standards of quality and safety for the donation, procurement, testing, processing, preservation, storage and distribution of human tissues and cells.
[3] Medical Device Regulation (MDR, 2017/745) of the European Parliament and of the Council of 5 April 2017 on medical devices.
[4] In Vitro Diagnostic Regulation (IVDR, 2017/746) f the European Parliament and of the Council of 5 April 2017 on in vitro diagnostic medical.
[5] Directive 2001/18/EC of the European Parliament and of the Council of 12 March 2001 on the deliberate release into the environment of genetically modified organisms.
[6] Directive 2009/41/EC of the European Parliament and of the Council of 6 May 2009 on the contained use of genetically modified micro-organisms