30 Churchill Place ● Canary Wharf ● London E14 5EU ● United Kingdom An agency of the European Union Telephone +44 (0)20 3660 6000 Facsimile +44 (0)20 3660 5520 Send a question via our website www.ema.europa.eu/contact 23 April 2015 EMA/CHMP/90102/2015 Committee for Medicinal Products for Human Use (CHMP) Assessment report Pregabalin Mylan Pharma International non-proprietary name: pregabalin Procedure No. EMEA/H/C/003962/0000 Note Assessment report as adopted by the CHMP with all information of a commercially confidential nature deleted.
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30 Churchill Place ● Canary Wharf ● London E14 5EU ● United Kingdom
Send a question via our website www.ema.europa.eu/contact
23 April 2015
EMA/CHMP/90102/2015
Committee for Medicinal Products for Human Use (CHMP)
Assessment report
Pregabalin Mylan Pharma
International non-proprietary name: pregabalin
Procedure No. EMEA/H/C/003962/0000
Note
Assessment report as adopted by the CHMP with all information of a commercially confidential nature deleted.
Assessment Report
EMA/CHMP/90102/2015 Page 2/29
Administrative information
Name of the medicinal product:
Pregabalin Mylan Pharma
Applicant:
Generics UK Limited
Station Close
Potters Bar
Hertfordshire
EN6 1TL
UNITED KINGDOM
Active substance:
pregabalin
International Nonproprietary
Name/Common Name:
pregabalin
Pharmaco-therapeutic group
(ATC Code):
Pregabalin
(N03AX16)
Therapeutic indications:
Neuropathic pain
Pregabalin Mylan Pharma is indicated for the treatment of peripheral and central neuropathic pain in adults.
Epilepsy Pregabalin Mylan Pharma is indicated as adjunctive therapy in adults with partial seizures with or without secondary generalisation. Generalised Anxiety Disorder
Pregabalin Mylan Pharma is indicated for the treatment of Generalised Anxiety Disorder (GAD) in adults.
Pharmaceutical form:
Capsule, hard
Strengths:
25 mg, 50 mg, 75 mg, 100 mg, 150 mg, 200
mg, 225 mg and 300 mg
Route of administration:
Oral use
Packaging:
blister (PVC/PVDC/alu) and bottle (HDPE)
Package sizes:
100 capsules, 100 x 1 capsules (unit dose), 14
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EMA/CHMP/90102/2015 Page 3/29
capsules, 14 x 1 capsules (unit dose), 21
capsules, 56 capsules, 56 x 1 capsules (unit
dose), 84 capsules, 84 x 1 capsules (unit
dose), and 200 capsules
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Table of contents
1. Background information on the procedure .............................................. 7
1.1. Submission of the dossier ..................................................................................... 7
ASMF Active Substance Master File = Drug Master File
AUC Area Under the plasma Concentration
AUC0-inf Area Under the plasma Concentration-time curve from time zero to infinity
AUC0-t Area Under the plasma Concentration-time curve from time zero to t hours
BE Bioequivalence
Cmax maximum plasma concentration
CoA Certificate of Analysis
CRO Certified Research Organisation
DMF Drug Master File = Active Substance Master File
DP Decentralised (Application) Procedure
DSC Differential Scanning Calorimetry
EC European Commission
ECG Electrocardiogram
EMA European Madicines Agency
EU European Union
FPM Finish Product Manufacturer
GABA Gamma-aminobutyric acid
GAD Generalised Anxiety Disorder
GCP Good Clinical Practice
GLP Good Laboratory Practice
GMP Good Manufacturing Practice
HCP Health Care Professional
HDPE High Density Polyethylene
HPLC High Pressure Liquid Chromatography
CHMP Committee for Human Medicine Products
ICD Informed Consent Document
ICSR Individual Case Safety Report
IEC Independent Ethics Committee
ICH International Conference of Hamrnization
INN International Non-proprietary Name
IPC In-process control test
IR Incidence Rate
IR Infrared
ISR Incurred Sample Reanalysis
LLOQ Lower Limit of Quantification
LOA Letter of Access
LOD Limit of Detection
LOQ Limit of Quantification
MA Marketing Authorisation
MAH Marketing Authorisation holder
MHRA British National Competent Authority
MR Medical Representative
MRI Magnetic resonance imaging
MS Mass Spectrometry
ND Not detected
NMR Nuclear Magnetic Resonance
NMT Not more than
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NSAID Non-Steroidal Anti-Inflammatory Drug
OOS Out of Specifications
PDE Permitted Daily Exposure
PE Polyethylene
Ph.Eur. European Pharmacopoeia
PhV Pharmacovigilance
PIL Patient Information Leaflet
PK pharmacokinetic
PMS Post Marketing Surveillance
PP Polypropylene
PS Photo-Sensitivity
PSMF Pharmacovigilance System Master File
PSUR Periodic Safety Update Report
PT Preferred Term
PVC Poly vinyl chloride
PVDC Polyvinylidene chloride
QA Quality Assurance
QC Quality Control (samples)
QOS Quality Overall Summary
QP Qualified Person
Rf Retention factor
RH Relative Humidity
RMM Risk Minimization Measure
RMS Reference Member State
RR Reporting Rate
RRT Relative retention time
RSD Relative standard deviation
Rt Retention time
SAE Serious adverse event
SmPC Summary of Product Characteristics
SMQ Standardised MedDRA Querie
SOC System Organ Class
SOP Standard Operating Procedure
STD Standard Deviation
T/R Test/Reference
Tmax time for maximum concentration (* median, range)
TSE Transmissible spongiform encephalopathy
UV Ultraviolet
XRPD X-ray powder diffraction
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1. Background information on the procedure
1.1. Submission of the dossier
The applicant Generics UK Limited submitted on 9 July 2014 an application for Marketing Authorisation to the
European Medicines Agency (EMA) for Pregabalin Mylan Pharma, through the centralised procedure under
Article 3 (3) of Regulation (EC) No. 726/2004– ‘Generic of a Centrally authorised product’. The eligibility to the
centralised procedure was agreed upon by the EMA/CHMP on 20 February 2014.
The application concerns a generic medicinal product as defined in Article 10(2)(b) of Directive 2001/83/EC and
refers to a reference product for which a Marketing Authorisation is or has been granted in the Union on the
basis of a complete dossier in accordance with Article 8(3) of Directive 2001/83/EC.
The applicant applied for the following indication:
Treatment of - peripheral and central neuropathic pain in adults. - adjunctive therapy in adults with partial seizures with or without secondary generalisation. - the treatment of Generalised Anxiety Disorder (GAD) in adults.
The legal basis for this application refers to:
Generic application (Article 10(1) of Directive No 2001/83/EC).
The application submitted is composed of administrative information, complete quality data and a
bioequivalence study with the reference medicinal product Lyrica 50 mg hard capsules/Lyrica 300 mg hard
instead of non-clinical and clinical unless justified otherwise.
The chosen reference product is:
■ Medicinal product which is or has been authorised in accordance with Community provisions in force for not
25 mg hard capsules: EU/1/04/279/001-005; EU/1/04/279/026; EU/1/04/279/036
50 mg hard capsules: EU/1/04/279/006-010; EU/1/04/279/037
75 mg hard capsules: EU/1/04/279/011-013; EU/1/04/279/027; EU/1/04/279/030; EU/1/04/279/038
100 mg hard capsules: EU/1/04/279/014-016; EU/1/04/279/39
150 mg hard capsules: EU/1/04/279/017-019; EU/1/04/279/028; EU/1/04/279/031; EU/1/04/279/040
200 mg hard capsules: EU/1/04/279/020-022; EU/1/04/279/041
225 mg hard capsules: EU/1/04/279/033 – 035; EU/1/04/279/042
300 mg hard capsules: EU/1/04/279/023 – 025; EU/1/04/279/029; EU/1/04/279/032; EU/1/04/279/043
■ Medicinal product which is or has been authorised in accordance with Community provisions in force and to which bioequivalence has been demonstrated by appropriate bioavailability studies:
Product name, strength, pharmaceutical form:
a) Lyrica 50 mg hard capsules;
b) Lyrica 300 mg hard capsules
Marketing authorisation holder: Pfizer Limited
Date of authorisation: 06/07/2004
Marketing authorisation granted by:
Community
Community Marketing authorisation numbers:
a) EU/1/04/279/006-010; EU/1/04/279/037
b) EU/1/04/279/023 – 025; EU/1/04/279/029; EU/1/04/279/032; EU/1/04/279/043
Information on paediatric requirements
Not applicable
Scientific advice
The applicant did not seek scientific advice at the CHMP.
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Licensing status
Pregabalin Mylan Pharma has been given a Marketing Authorisation in Canada on 15 February 2013.
An application was filed in the following countries: New Zealand and United States.
The 90% confidence intervals for test/reference ratios observed for Cmax and AUCs are within the pre-specified
acceptance limits for bioequivalence, 80.00-125.00%. Therefore, the bioequivalence between test and
reference products can be considered as demonstrated.
Safety data
Study 005-14
Four subjects experienced a total of four adverse events (vomiting) which led to the withdrawal of these subjects
from the study. The adverse events were mild in severity.
No serious adverse events were reported. All subjects were found to be in normal health status at the time of
post study medical examination.
Study 006-14
Two subjects experienced a total of two adverse events (vomiting) which led to the withdrawal of these subjects
from the study. The adverse events were mild in severity.
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No serious adverse events were reported. All subjects were found to be in normal health status at the time of
post study medical examination. However, post study safety evaluation was not performed for 2 subjects who
were absent for period-II and were considered as lost to follow-up.
Conclusions
Based on the presented bioequivalence study 005-14 Pregabalin Mylan Pharma 300 mg is considered
bioequivalent with Lyrica 300mg. The results can be extrapolated to other strengths: 75 mg, 100 mg, 150 mg,
200 mg and 225 mg, according to conditions in the Guideline on the Investigation of Bioequivalence
CPMP/EWP/QWP/1401/98.
Based on the presented bioequivalence study 006-014 Pregabalin Mylan Pharma 50 mg is considered
bioequivalent with Lyrica 50 mg. The results can be extrapolated to other strengths 25 mg strength, according
to conditions in the Guideline on the Investigation of Bioequivalence CPMP/EWP/QWP/1401/98.
2.4.3. Pharmacodynamics
No new pharmacodynamic studies were presented and no such studies are required for this application.
2.4.4. Post marketing experience
No post-marketing data are available. The medicinal product has not been marketed in any country.
2.4.5. Discussion on clinical aspects
The chosen pharmacokinetic parameters of the BE studies were adequate according to the current guidelines.
The statistics have been adequately described and the standard acceptance criteria were acceptable. The
threshold of a 10% significance level sequence effect (vs. the 5% threshold for period and treatment effects)
was unusual. However, the CHMP was of the opinion that it did not have consequences on the interpretation of
the data.
The number of sample points around Cmax was considered adequate for the estimation of Cmax, calculation of the
terminal elimination life was considered acceptable, and the analytical method has been validated in a suitable
range. In study 006-14, the upper range of calibration was lower than the upper range of calibration in the
method validation. This was acceptable since lower pregabalin plasma concentrations were expected following
administration of a 50 mg dose.
A single dose bioequivalence studies were considered sufficient since the application concerns an immediate
release formulation. Steady state studies are not indicated as no accumulation of pregabalin is expected, and
bioavailability is not affected by repeated doses.
There were no deaths or serious adverse events reported during the conduct of the studies. All adverse events,
were mild in nature and resolved. The safety of pregabalin is well documented and both test and reference
products are expected to have a comparable safety profile.
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2.4.6. Conclusions on clinical aspects
Based on the results of the pivotal bioequivalence studies submitted, Pregabalin Mylan Pharma hard capsules
are considered bioequivalent to Lyrica hard capsules.
2.5. Pharmacovigilance
Detailed description of the pharmacovigilance system
The CHMP considered that the Pharmacovigilance system as described by the applicant fulfils the legislative
requirements.
2.6. Risk management plan
The CHMP received the following PRAC Advice on the submitted Risk Management Plan:
The PRAC considered that the risk management plan version 3 is acceptable. The PRAC endorsed PRAC
Rapporteur assessment report is attached.
The CHMP endorsed the Risk Management Plan version 3 with the following content:
Safety concerns
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Pharmacovigilance plan
Not applicable
Risk minimisation measures
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2.7. PSUR submission
The marketing authorisation holder shall submit periodic safety update reports for this product in accordance
with the requirements set out in the list of Union reference dates (EURD list) ) provided for under Article 107c(7)
of Directive 2001/83/EC and published on the European medicines web-portal.
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2.8. Product information
2.8.1. User consultation
No full user consultation with target patient groups on the package leaflet has been performed on the basis of
a double bridging report making reference to Lyrica (for content) and Memantine Mylan 10 mg film-coated
tablets (for style and format). The bridging report submitted by the applicant has been found acceptable.
3. Benefit-risk balance
This application concerns a generic version of pregabalin hard capsules. The reference product Lyrica is
indicated for the treatment of peripheral and central neuropathic pain in adults, adjunctive therapy in adults
with partial seizures with or without secondary generalisation and treatment of Generalised Anxiety Disorder
(GAD) in adults. No nonclinical studies have been provided for this application but an adequate summary of the
available nonclinical information for the active substance was presented and considered sufficient. From a
clinical perspective, this application does not contain new data on the pharmacokinetics and pharmacodynamics
as well as the efficacy and safety of the active substance; the applicant’s clinical overview based on information
from published literature was considered sufficient.
The bioequivalence studies form the pivotal basis with an open-label, balanced, randomized, two-sequence,
two-period, cross-over, single dose design. The design was considered adequate to evaluate the bioequivalence
of this formulation and was in line with the respective European requirements. Choice of dose, sampling points,
overall sampling time as well as wash-out period were adequate. The analytical method was validated.
Pharmacokinetic and statistical methods applied were adequate.
Based on the presented bioequivalence studies 005-14 and 006-14, Pregabalin capsules 300 mg are considered
bioequivalent with Lyrica™ hard capsules 300 mg with respect to rate and extent of absorption of Pregabalin;
and Pregabalin capsules 50 mg are considered bioequivalent with Lyrica™ hard capsules 50 mg with respect to
rate and extent of absorption of Pregabalin.
The results of study 005-14 with 300 mg formulation can be extrapolated to other strengths: 75 mg, 100 mg,
150 mg, 200 mg and 225 mg, and the results of study 006-14 with 50 mg formulation can be extrapolated to the
other strength 25 mg, according to conditions in the relevant Guideline.
A benefit/risk ratio comparable to the reference product can therefore be concluded.
The CHMP, having considered the data submitted in the application and available on the chosen reference
medicinal product, is of the opinion that no additional risk minimisation activities are required beyond those
included in the product information.
4. Recommendation
Based on the CHMP review of data on quality, safety and efficacy, the CHMP considers by consensus that the
benefit-risk balance of Pregabalin Mylan Pharma in the treatment of - peripheral and central neuropathic pain in adults. - adjunctive therapy in adults with partial seizures with or without secondary generalisation.
- the treatment of Generalised Anxiety Disorder (GAD) in adults
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is favourable and therefore recommends the granting of the marketing authorisation subject to the following
conditions:
Conditions or restrictions regarding supply and use
Medicinal product subject to medical prescription (See Annex I: Summary of Product Characteristics, section
4.2).
Conditions and requirements of the Marketing Authorisation
Periodic Safety Update Reports
The marketing authorisation holder shall submit periodic safety update reports for this product in accordance
with the requirements set out in the list of Union reference dates (EURD list) ) provided for under Article 107c(7)
of Directive 2001/83/EC and published on the European medicines web-portal.
Conditions or restrictions with regard to the safe and effective use of the medicinal product
Risk Management Plan (RMP)
The MAH shall perform the required pharmacovigilance activities and interventions detailed in the agreed RMP
presented in Module 1.8.2 of the Marketing Authorisation and any agreeed subsequent updates of the RMP.
An updated RMP should be submitted:
At the request of the European Medicines Agency;
Whenever the risk management system is modified, especially as the result of new information being
received that may lead to a significant change to the benefit/risk profile or as the result of an important
(pharmacovigilance or risk minimisation) milestone being reached.
If the submission of a PSUR and the update of a RMP coincide, they can be submitted at the same time.