Your clinical trial supply may be at risk – Brexit and the impact on IMP distribution
Brexit, the process of the UK leaving the European Union (EU), is creating uncertainties across many industries. Early indications from the European Medicines Agency (EMA) are that it will have a significant impact on the pharmaceutical and biopharmaceutical industry globally.
One area at risk of disruption is the supply chain for investigational medicinal products (IMPs).
It’s not only an UK / EU problem
The EU requires the ‘gateway’ for a Qualified Person (QP) release and distribution of investigational product to be sited in a member country. If a clinical trial sponsor or their contract manufacturing / logistics provider is using the UK as that gateway, then that currently approved supply route is at risk. This applies to all global pharmaceutical companies executing studies with sites in EU countries.
But the negotiations aren’t yet concluded – what’s known today?
While many details are still unresolved at this point, the EMA has provided guidance to give marketing authorization holders of centrally authorized medicinal products some initial direction. According to guidelines issued jointly by the EMA and the European Commission, the UK will become a “third country” beginning March 30, 2019. Although this guidance for commercial drug releases, it is a strong indicator of what will be applied to IMPs. The implication of the guidance is that if your QP release and clinical trial distribution to sites in EU countries is currently located in the UK, you are likely to have to relocate it to a remaining EU member country.
So what does it mean right now – what action should I take?
Although there are uncertainties, we do know enough to assess potential risks to the clinical trial supply chain and take actions to mitigate them. My advice is don’t wait, the clock is counting down fast towards March 2019, and the risks are compounded by many QPs being located in UK based facilities today, which could lead to competition for those scarce resources.
You can start by using the simple flowchart below to determine the likely impact on your studies.
My current / future studies will likely be impacted – who can help?
PAREXEL’s Clinical Trial Supplies and Logistics team have over 10 years’ experience of managing global distribution of IMP. We are available to further advise on your Brexit risk mitigation strategy and to provide IMP release from our European Distribution Center in Berlin. Please contact me at Tony.Street@PAREXEL.com to discuss your situation and how we can help.