2018 Pharmaceutical Administration and REgulation JApan

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2018

INFORMATION ON JAPANESE REGULATORY AFFAIRS

Regulatory Information Task Force


Japan Pharmaceutical Manufacturers Association

Pharmaceutical
Administration and
Regulations in Japan

Japan Pharmaceutical Manufacturers Association


Pharmaceutical Regulations in Japan:

2018

http://www.jpma.or.jp/about/issue/gratis/index2.html (Japanese)

http://www.jpma.or.jp/english/parj/whole.html (English)

Pharmaceutical Administration and


Regulations in Japan

This file contains information concerning pharmaceutical administration,


regulations, and new drug development in Japan updated annually by the
English RA Information Task Force, International Affairs Committee, Japan
Pharmaceutical Manufacturers Association (JPMA). The contents are not
abstracts of governmental rules or regulations but concise descriptions of most
current practices by regulatory agencies and the industry that the working group
complies. The file does not contain anything related to forecasts. The file is
available also at the homepage of National Institute of Health Sciences
(http://www.nihs.go.jp/kanren/iyaku.html).

Japan Pharmaceutical Manufacturers Association


http://www.jpma.or.jp/english/
Pharmaceutical Regulations in Japan:

4.25 Kansai Branch ............................ 8


4.26 Hokuriku Branch ......................... 9
Table of Contents 5. NATIONAL INSTITUTE OF
BIOMEDICAL INNOVATION, HEALTH
AND NUTRITION (NIBIOHN) ................. 9
6. JAPAN AGENCY FOR MEDICAL
RESEARCH AND DEVELOPMENT
CHAPTER 1 ........................................................... 1 (AMED) ............................................ 9
ORGANIZATION AND FUNCTION OF THE 7. PHARMACEUTICAL AFFAIRS AND
MINISTRY OF HEALTH, LABOUR AND FOOD SANITATION COUNCIL (PAFSC) ... 9
WELFARE .............................................. 1 8. NATIONAL INSTITUTE OF
INFECTIOUS DISEASES .................... 10
1. PHARMACEUTICAL SAFETY AND
ENVIRONMENTAL HEALTH BUREAU
(PSEHB) ........................................... 2 CHAPTER 2 ..........................................................15
1.1 General Affairs Division ................. 2
1.2 Pharmaceutical Evaluation Division .. 2 PHARMACEUTICAL LAWS AND
1.3 Medical Device Evaluation Division .. 2 REGULATIONS ..................................... 15
1.4 Pharmaceutical Safety Division ....... 3
1. PHARMACEUTICAL LAWS ................. 15
1.5 Compliance and Narcotics Division... 3
2. PHARMACEUTICAL AND MEDICAL
1.6 Blood and Blood Products Division ... 4
DEVICE ACT .................................... 15
2. HEALTH POLICY BUREAU .................... 4
3. OUTLINE OF PHARMACEUTICAL
2.1 Economic Affairs Division ............... 4
REGULATIONS ................................ 17
2.2 Research and Development
3.1 Definition of Drugs ..................... 17
Division ..................................... 4
3.2 Classification of Drugs ................ 17
3. NATIONAL INSTITUTE OF HEALTH
3.3 License for
SCIENCES ........................................ 5
Manufacturing/Marketing
4. PHARMACEUTICALS AND MEDICAL
Businesses .............................. 19
DEVICES AGENCY, AN INDEPENDENT
3.4 License for Manufacturing Business
ADMINISTRATIVE ORGANIZATION ......... 5
and Accreditation of Overseas
4.1 Office of Review Administration ....... 6
Manufacturers .......................... 20
4.2 Office of Review Management......... 6
3.5 Manufacturing/Marketing Approvals 22
4.3 Office of Standards and Guidelines
3.6 Good Manufacturing Practice
Development .............................. 6
(GMP) .................................... 22
4.4 Office of New Drug I ..................... 6
3.7 Drug Master File (MF) ................ 23
4.5 Office of New Drug II .................... 6
3.8 Drug Retail Seller Licensing ......... 23
4.6 Office of New Drug III.................... 6
3.9 Labeling and Package Inserts ....... 24
4.7 Office of New Drug IV ................... 7
3.10 Proper Advertisement ................. 25
4.8 Office of New Drug V .................... 7
3.11 Good Laboratory Practice (GLP) ... 25
4.9 Office of Cellular and Tissue-based
3.12 Good Clinical Practice (GCP) ....... 26
Products .................................... 7
3.13 Trial Conducted from a
4.10 Office of Vaccines and Blood
Compassionate Viewpoint
Products .................................... 7
(expanded trial) ......................... 27
4.11 Office of OTC/Quasi-drugs ............. 7
3.14 Patient-requested Therapy System 27
4.12 Office of Generic Drugs ................. 7
3.15 Good Post-marketing Study
4.13 Office of Medical Devices I ............. 7
Practice (GPSP) ....................... 28
4.14 Office of Medical Devices II ............ 7
3.16 Reexamination ......................... 28
4.15 Office of Medical Devices III ........... 7
3.17 Reevaluation ............................ 28
4.16 Office of in Vitro Diagnostics ........... 7
3.18 Adverse Drug Reaction (ADR) and
4.17 Office of Compliance and
Infection Reporting .................... 29
Standards .................................. 8
3.19 Risk Management Plan ............... 29
4.18 Office of Safety I .......................... 8
3.20 Dissemination of Information ........ 29
4.19 Office of Safety II ......................... 8
3.21 Measures related to the Law
4.20 Office of Medical Informatics and
Concerning Access to Information
Epidemiology .............................. 8
Held by Administrative
4.21 Office of Manufacturing/Quality and
Organizations ........................... 30
Compliance ................................ 8
3.22 Patent System .......................... 30
4.22 Office of International Programs ...... 8
3.23 Drug Abuse Control ................... 31
4.23 Office of International Cooperation ... 8
4. MARKETING APPROVALS .................. 32
4.24 Advanced Review with Electronic
4.1 Drug Marketing Approvals ........... 32
Data Promotion Group .................. 8
4.2 Marketing Approval Reviews ........ 32

i
Pharmaceutical Regulations in Japan:

4.3Manufacturing/Marketing Approval Study ..................................... 59


Application with Electronic Data ..... 34 1.4 Interview advice meetings ........... 60
4.4 Priority Review System and 1.5 Approval review ........................ 63
Designation of Drug Products for 1.6 Compliance review .................... 64
Priority Reviews ........................ 35 1.7 GMP compliance inspection ......... 66
4.5 Restrictive Approval System ......... 36 2. DATA REQUIRED FOR APPROVAL
4.6 Orphan Drugs ........................... 36 APPLICATIONS ................................ 68
4.7 Drugs for Pediatric Use ............... 36 2.1 Data to be Attached to Approval
4.8 Unapproved Drugs and Drugs of Application of Drugs ................... 71
Off-label Use ............................ 37 3. GUIDELINES CONCERNING DRUG
4.9 Packaging Strategy for World-first APPROVAL APPLICATIONS ................ 72
Products .................................. 38 3.1 Nonclinical Studies .................... 73
4.10 Regulatory Science Strategy 3.2 Clinical Studies ......................... 78
Consultations for Regenerative 4. OTHER ........................................... 85
Medicine Products (former 4.1 Biotechnological Products .......... 85
Regulatory Strategy Consultations) 39 4.2 Drugs Using Materials of Human or
4.11 Approval System Implemented to Animal Origin as Ingredients
Promote the Application of (Biological Products) .................. 86
Regenerative Medicine Including 4.3 Biosimilar Products .................... 87
Cellular and Tissue-Based Products 4.4 Public Disclosure of Information on
for Commercialization (Approval New Drug Development .............. 88
with Conditions and Time Limit) ..... 40 4.5 ICH (International Conference on
4.12 Conditional Accelerated Approval Harmonization of Technical
System for Pharmaceuticals ......... 40 Requirements for Registration of
4.13 Guidelines for Promoting Optimal Pharmaceuticals for Human Use) .. 88
Use ........................................ 40
4.14 Biosimilar Products .................... 41
4.15 Combination Products ................. 41 CHAPTER 4 ........................................................ 111
4.16 Codevelopment ......................... 42
4.17 Transfer of Marketing Approvals .... 42 POST-MARKETING SURVEILLANCE OF
4.18 Approval Applications for Drugs DRUGS ............................................. 111
Manufactured Overseas .............. 42 1. GVP .............................................. 114
4.19 Issuing of Certificates for Exported 2. GPSP ............................................ 120
Drugs by MHLW ........................ 43 3. PAPER COMPLIANCE REVIEW AND
5. JAPANESE PHARMACOPOEIA AND ON-SITE GPSP SURVEYS OF DATA
OTHER STANDARDS ......................... 43 FOR REEXAMINATION AND
5.1 Japanese Pharmacopoeia (JP)...... 43 REEVALUATION .............................. 124
5.2 Standards Based on Article 42 of 4. ADVERSE DRUG REACTIONS AND
the Pharmaceutical Affairs Law...... 45 INFECTIONS REPORTING SYSTEM .... 124
5.3 Standards for Biological Materials .. 45 4.1 Adverse Drug Reaction and
5.4 Quality Standards Based on Infectious Disease Reporting
Notifications ............................. 46 System by Pharmaceutical
5.5 Government Batch Test ............... 46 Companies ............................. 125
6. PHARMACEUTICAL SUPERVISION ...... 47 4.2 Drug and Medical Device Safety
6.1 Pharmaceutical Supervision ......... 47 Information Reporting System by
6.2 Product Recalls ......................... 47 Medical Personnel .................... 128
6.3 Prevention of Medical Accidents 4.3 WHO International Drug Monitoring
Caused by Drugs, etc.................. 47 Program................................. 128
6.4 Safety Measures against Bovine 5. PERIODIC INFECTION REPORTS FOR
Spongiform Encephalitis (BSE)...... 48 BIOLOGICAL PRODUCTS (ARTICLE
68-14 AND 68-24 IN THE LAW) ........... 128
6. REEXAMINATION SYSTEM (ARTICLE
CHAPTER 3 ......................................................... 56 14-4 AND 23-29 OF THE
PHARMACEUTICAL AFFAIRS LAW) ..... 129
DRUG DEVELOPMENT ........................... 56
6.1 Designation for Reexamination of
1. PROCESS FROM DEVELOPMENT TO Drugs .................................... 129
APPROVAL ...................................... 56 6.2 Periodic Safety Reports (Article 63
1.1 Development of New Drugs .......... 56 of the Enforcement Regulations of
1.2 Procedures for Clinical Trials ........ 57 the Law)................................. 130
1.3 Safety information on Adverse 6.3 Data Required for Reexamination
Reactions and Infections during the Applications and Reexamination

ii
Pharmaceutical Regulations in Japan:

Procedures ............................ 131 1. HISTORY OF HEALTH INSURANCE


7. REEVALUATION SYSTEM (ARTICLES PROGRAMS ................................... 160
14-6 AND 23-31 OF THE LAW) ........... 132 2. MEDICAL BENEFITS OFFERED
UNDER HEALTH INSURANCE
PROGRAMS ................................... 161
CHAPTER 5 ....................................................... 139 3. REIMBURSEMENT OF MEDICAL FEES 161
4. NATIONAL HEALTH INSURANCE
SUPPLY AND DISSEMINATION OF DRUG PRICE LIST .................................... 162
SAFETY MANAGEMENT INFORMATION .. 139 5. PRICING FORMULA FOR
1. PACKAGE INSERTS ........................ 139 REIMBURSEMENT PRICE REVISIONS
1.1 Guidance on the Style and Format OF DRUGS LISTED IN THE NHI PRICE
of Package Inserts ................... 141 LIST .............................................. 162
1.2 Headings and Their Sequence in 6. RECENT REVISIONS OF THE NHI
Package Inserts ...................... 142 PRICE LIST .................................... 164
1.3 Precautions ............................ 143 7. DETERMINATION OF
1.4 Labeling of Excipients ............... 144 REIMBURSEMENT PRICES FOR NEW
1.5 Entries for Biological Products ..... 144 DRUGS ......................................... 165
1.6 Brand Names of Prescriptions 8. ENTRY OF GENERIC DRUGS IN THE
Drugs ................................... 145 NHI PRICE LIST .............................. 166
1.7 Information on Package Inserts in 9. ISSUES RELATED TO THE USE OF
English.................................. 146 DETERMINATION OF UNAPPROVED
2. INFORMATION TO SUPPLEMENT DRUGS AND OFF-LABEL USE............ 166
PACKAGE INSERTS ........................ 146
2.1 Outline of Prescription
Pharmaceutical Product
Information ............................. 146
2.2 Pharmaceutical Interview Forms Fig. 1 Organization of Ministry of Health,
(IF) ...................................... 147 Labour, and Welfare (Health-related
3. SUPPLY AND DISSEMINATION OF organizations only) ................................... 11
SAFETY MANAGEMENT Fig. 2 Organization of Pharmaceutical Safety
INFORMATION ............................... 147 and Environmental Health Bureau
3.1 Distribution of Emergency Safety (PSEHB) and Pharmaceuticals and
Information (Yellow Letters) ........ 149 Medical Devices Agency (PMDA) ............12
3.2 Safety Flash Report (Blue Letters) 150 Fig. 3 Organization of the Pharmaceutical
3.3 Distribution of Information by Affairs and Food Sanitation Council
'Notices of Revision of Precautions'151 (PAFSC) ...................................................14
3.4 Dissemination of Information for Fig. 4 Flowchart of Patent-Life Extension...........50
Drugs That Have Completed Fig. 5 Flowchart of Approval Review ..................51
Reexamination or Reevaluation ... 151 Fig. 6 Procedure for manufacturing and
3.5 Dissemination of ADR Information marketing approval of drugs for
by the Pharmaceuticals and overseas manufacturers in Japan ...........52
Medical Devices Safety Information Fig. 7 Flowchart of Drug Listing in Japanese
(Information on Adverse Reactions Pharmacopoeia ........................................53
to Drugs) ............................... 151 Table 1 List of Main Controlled Substances .......54
3.6 Dissemination of Information by Table 2 Divisions of the Pharmaceutical and
Drug Safety Update .................. 152 Food Safety Bureau in Charge of
3.7 Commentaries on "Precautions" in Certification Work.....................................55
Package Inserts of New Drugs .... 152 Fig. 8 Flowchart of New Drug Development
4. ELECTRONIC INFORMATION and Approval ............................................90
DISSEMINATION ............................. 152 Fig. 9 Timeline of the standard process of
5. PACKAGE INSERTS OF new drug approval ...................................91
NON-PRESCRIPTION DRUGS ........... 153 Fig. 10 Timeline of the standard process of
6. PACKAGE INSERTS OF new drug approval ...................................92
GUIDANCE-MANDATORY DRUGS ...... 154 Table 3 Data to be Submitted with an
Application for Approval to
Manufacture/Market: A New
CHAPTER 6 ....................................................... 160 Prescription Drug .....................................93
Table 4 Data to be Submitted with an
HEALTH INSURANCE PROGRAMS AND Application for a Non-prescription Drug ...95
DRUG PRICING IN JAPAN ..................... 160 Table 5 Classification of Clinical Studies
According to Objectives ...........................97

iii
Pharmaceutical Regulations in Japan:

Table 6 List of Major Guidelines, etc. on


Physicochemical Properties,
Specifications, and Tests Methods .......... 98
Table 7 List of Major Guidelines, etc. on
Toxicity Tests ........................................... 99
Table 8 List of Major Guidelines, etc. on
Pharmacological Studies ....................... 100
Table 9 List of Major Guidelines, etc. on
Pharmacokinetic Studies ....................... 100
Table 10 List of Major Guidelines, etc. on
Bioequivalence Studies ......................... 101
Table 11 List of Major Guidelines, etc. on
Clinical Evaluation ................................. 101
Table 12 List of Major Guidelines, etc.
Related to Biotechnology ...................... 104
Fig. 11 Organization of ICH Common
Technical Documents ............................ 105
Fig. 12 Correlation between Development
Phases and Types of Study................... 106
Table 13 ICH topics and guidelines - Progress
of harmonization .................................... 107
Fig. 13 Pharmaceutical Post-marketing
Surveillance System .............................. 134
Fig. 14 Post-marketing Collection and
Reporting of Pharmaceutical Safety
Information............................................. 135
Fig. 15 Collection and Reporting of
Pharmaceutical Safety Information ....... 136
Fig. 16 Reexamination System ........................ 137
Fig. 17 Reevaluation System ........................... 138
Fig. 18 Layout of a Package Insert for a
Prescription Drug (with “Warning”) ........ 155
Fig. 19 Layout of Package Insert Based on
Revised Guidelines for Preparation
(Image) .................................................. 156
Fig. 20 Standard Procedures for Revision of
Package Insert (1) ................................. 158
Fig. 21 Standard Procedures for Revision of
Package Insert (2) ................................. 159
Fig. 22 Reimbursement Pricing Flow-sheet
for New Drugs ....................................... 168
Fig. 23 Correlation between the Time of
Marketing Approval Based on
Pharmaceutical Affairs Law and the
Time of Entry in the NHI Price List ........ 169
Table 14 Methods of Previous
Reimbursement Price Revisions ........... 170
Table 15 Revision Rates of Reimbursement
Prices..................................................... 171
Table 16 Requirements for Applying
Premiums .............................................. 176

iv
Pharmaceutical Regulations in Japan:

Environmental Health Bureau (PSEHB) undertakes


CHAPTER 1
main duties and functions of the Ministry; it handles
clinical studies, approval reviews and post-marketing
ORGANIZATION AND
safety measures, i.e., approvals and licensing. The
FUNCTION OF THE MINISTRY Health Policy Bureau handles promotion of R&D,
production, distribution policies, and drug pricing, i.e.,
OF HEALTH, LABOUR AND functions related to pharmaceutical companies. The
WELFARE Pharmaceuticals and Medical Devices Evaluation
Center (Evaluation Center) in the National Institute of
Health Sciences was established to strengthen
approval reviews and to introduce a specific system
The Ministry of Health, Labour, and Welfare
for reviewing tasks for drugs, etc. on July 1, 1997. To
(MHLW) (Koseirodosho in Japanese) was
confirm the reliability of reviews and application data,
established by a merger of the Ministry of Health and
the Organization for Pharmaceutical Safety and
Welfare (MHW) and the Ministry of Labour, on
Research (OPSR) conducted compliance reviews on
January 6, 2001 as part of the government program
application data. The OPSR also began offering
for reorganizing government ministries. The MHLW,
consultation services on protocols at the clinical trial
which was originally established in 1938, has been in
stage.
charge of the improvement and promotion of social
welfare, social security and public health, and the new This was followed by the integration of the
organization has the same tasks. aforementioned Evaluation Center, OPSR, and part
of the Medical Devices Center on April 1, 2004 to
It consists of the ministry proper, affiliated
form a new independent administrative organization,
institutions, councils, local branches, and external
the Pharmaceutical and Medical Devices Agency
organizations. The ministry proper includes the
(PMDA). The role of the PMDA is to provide
Minister's Secretariat, 11 bureaus, and the
consultations concerning the clinical trials of new
Director-General for Policy Planning and Evaluation.
drugs and medical devices, and to conduct approval
Councils include the Social Insurance Council,
reviews and surveys of the reliability of application
Pharmaceutical Affairs and Food Sanitation Council
data.
(PAFSC), and other organizations. Affiliated
Following this reorganization, the PSEHB and
institutions include the National Institute of Health
PMDA handle a wide range of activities from clinical
Sciences and the National Institute of Infectious
studies to approval reviews, reviews throughout
Diseases. Local branches are regional bureaus of
post-marketing stage, and pharmaceutical safety
health and welfare and prefectural labor bureaus.
measures. (Fig. 2 Organization of Pharmaceutical
The external organization is the Central Labor
Safety and Environmental Health Bureau (PSEHB)
Relations Commission (Fig. 1 Organization of Ministry
and Pharmaceuticals and Medical Devices Agency
of Health, Labour, and Welfare (Health-related
(PMDA)).
organizations only)).
The MHLW is in charge of pharmaceutical
regulatory affairs in Japan (veterinary drugs are under
the jurisdiction of the Ministry of Agriculture, Forestry
and Fisheries), and the Pharmaceutical Safety and

2018 -1-
Pharmaceutical Regulations in Japan:

1. PHARMACEUTICAL SAFETY AND drugs, quasi-drugs, cosmetics, and medical


ENVIRONMENTAL HEALTH BUREAU devices (drugs, etc.)
(PSEHB)
The Pharmaceutical Safety and Environmental • Office of International Regulatory Affairs
Health Bureau (PSEHB) (except for the Department Overall coordinating activities for international
of Food Safety) is one of the 11 bureaus of the affairs under the control of the Pharmaceutical
MHLW. In addition to polices to assure the efficacy Safety and Environmental Health Bureau.
and safety of drugs, quasi-drugs, cosmetics and
medical devices, and policies for safety in medical 1.2 Pharmaceutical Evaluation Division
institutions, the PFSB tackles problems directly
related to the lives and heath of the general public 1) Technical guidance and supervision concerning
including policies related to blood supplies and blood the production of drugs, quasi-drugs, cosmetics,
products, and narcotics and stimulant drugs. This and medical devices (drugs, etc.)
new bureau consists of a Secretary-General, 2) Manufacturing/marketing business licenses and
Councilor in charge of drugs, five divisions, and one approvals to manufacture and market drugs,
office* (Fig. 2 Organization of Pharmaceutical Safety etc.
and Environmental Health Bureau (PSEHB) 3) Reexamination and reevaluation of drugs
and Pharmaceuticals and Medical Devices Agency 4) Issues related to the Japanese Pharmacopoeia
(PMDA)). These divisions have the functions (JP)
described below.
5) Standards and specific precautions concerning
drugs, etc.
1.1 General Affairs Division
6) Designation of orphan drugs
1) Overall planning and coordinating activities for 7) Work related to the PMDA (limited to approval to
the Pharmaceutical Safety and Environmental manufacture and market drugs, medical devices,
Health Bureau etc.)
2) Matters related to pharmacists
3) Supervision of the PMDA (excluding areas 1.3 Medical Device Evaluation Division
under the control of the Pharmaceutical
1) Technical guidance and supervision concerning
Evaluation Division, Medical Device Evaluation
the production of medical devices,
Division, Pharmaceutical Safety Division, and
extracorporeal diagnostic medicines and
Compliance and Narcotics Division)
regenerative medicine products
4) Issues related to PSEHB not governed by other
2) Manufacturing business licenses for
divisions
regenerative medicine products and
manufacturing business registrations for
• Office of Drug Induced Damages medical devices and extracorporeal diagnostic
1) The relief systems operated by the PMDA for medicines, as well as approvals to manufacture
damage caused by adverse drug reactions and market medical devices, extracorporeal
including biological products-induced infection diagnostic medicines and regenerative
2) Measures for handling health injury caused by medicine products
3) Reexamination and reevaluation of regenerative

2018 -2-
Pharmaceutical Regulations in Japan:

medicine products 1.4 Pharmaceutical Safety Division


4) Evaluation of treatment outcomes of medical 1) Planning and drafting of policies to assure the
devices and extracorporeal diagnostic safety of pharmaceuticals and medical devices,
medicines etc.
5) Business license and approvals to market, loan, 2) Manufacturing/marketing business licenses to
or repair medical devices, or to market manufacture and market pharmaceuticals and
regenerative medicine products (excluding medical devices, etc.
areas under the control of Health Policy Bureau
3) Review of the safety of pharmaceuticals and
[HPB])
medical devices, etc. (excluding items handed
6) Standards and specific precautions concerning by the Pharmaceutical Evaluation Division and
medical devices, extracorporeal diagnostic Medical Device Evaluation Division)
medicines and regenerative medicine products
4) Guidance and advice concerning preparation
7) Designation of orphan medical devices and and storage of records of biological products
orphan regenerative medicine products and designated medical devices
8) Work related to PMDA (limited to work related to 5) Work related to the PMDA (limited to matters
medical devices, extracorporeal diagnostic related to improve safety of pharmaceuticals
medicines and regenerative medicine products) and medical devices, etc. and excluding items
9) Control and dissemination of industrial handed by the Pharmaceutical Evaluation
standards for medical devices, other hygiene Division and Medical Device Evaluation
products, and regenerative medicine products, Division)
and other industrial standards

• Office of Chemical Safety 1.5 Compliance and Narcotics Division

1) Enforcement of laws pertaining to poisonous 1) Control of poor quality or falsely labeled


and deleterious substances (excluding areas pharmaceuticals and medical devices, etc
under the control of the Compliance and 2) Guidance and supervision related to advertising
Narcotics Division) of pharmaceuticals and medical devices, etc
2) Regulations related to evaluation of chemicals 3) Testing and government certification of
that might cause damage to the health of pharmaceuticals and medical devices, etc
humans, animals, and plants from the 4) Matters related to pharmaceutical inspectors,
standpoint of environment and public health, as etc.
well as regulations related to manufacturing,
5) Control of narcotics and stimulants, etc
importing, using, and other handling of such
chemicals 6) Duties of narcotics control officers and staff

3) Control of household products containing 7) Matters related to international cooperation


harmful substances concerning narcotics and stimulants, etc

4) Establishment of tolerable daily intake (TDI) of 8) Work related to the PMDA (limited to matters
dioxins and related compounds related to on-site inspection, etc. by the PMDA)

2018 -3-
Pharmaceutical Regulations in Japan:

1.6 Blood and Blood Products Division clinics (hospitals, etc.)

1) Regulation of blood collection services 5) Guidance on enterprises related to the


improvement of the management of hospitals,
2) Promotion of blood donation
etc. (excluding those governed by the national
3) Assurance of proper use of blood products and
and local governments)
assurance of stable supply of blood products
6) Issues related to hygiene inspection offices. This
4) Maintenance of stable supply of blood products
Division includes the Office of Direction for
5) Promotion, improvement, and coordination Health-Related Services with the following
concerning production and marketing of functions.
biological products (excluding items handed by
 Office of Medical Device Policy
the Health Service Bureau)
1) Promotion, improvement and coordination of
manufacturing, marketing and consuming
2. HEALTH POLICY BUREAU medical devices and other sanitary products
With the aging of society, changes in disease (other than those handled by PSEHB and the
structure, and increasing demands from the public for Research and Development Division)
better quality health care, the Health Policy Bureau is 2) Promotion, improvement and coordination of
drafting policies aimed at achieving a high quality, business of manufacturing,
efficient health care supply system for the 21st manufacturing/marketing, selling, leasing and
century. repairing medical devices and other sanitary
The Economic Affairs Division and the Research products (other than those handled by the
and Development Division, the two divisions most Research and Development Division)
closely related to the pharmaceutical industry, have 3) Foreign trades (import and export) of medical
the functions described below. devices and other sanitary products
4) Installation and use of medical devices (other
2.1 Economic Affairs Division
than medical, dental, and sanitary supplies)
1) Promotion, improvement and coordination (other than those handled by the Guidance of
related to production, marketing and Medical Service Division)
consumption of drugs, quasi-drugs, medical
devices, sanitary materials, and other 2.2 Research and Development Division
hygiene-related products (drugs, etc.) (excluding
1) Matters related to research and development of
items handed by PSEHB and the Research and
drugs, etc. (excluding items handed by PSEHB)
Development Division)
2) Matters related to the cultivation and production
2) Advancement, improvement, and coordination
of medicinal plants
of manufacturing of drugs, etc. (excluding items
handed by the Research and Development 3) Promotion, improvement, and coordination of
Division) manufacturing business of drugs, etc. (limited to
items related to research and development)
3) Matters related to foreign trade (import and
export) of drugs, etc. 4) Matters related to installation and use of medical
devices (excluding medical supplies, dental
4) Matters related to outsourcing the work of
supplies, and hygiene-related products)
managers of hospitals, clinics, and maternity

2018 -4-
Pharmaceutical Regulations in Japan:

(excluding items handled by the Guidance of in April 2004, through the integration of the
Medical Service Division of the HPB) Pharmaceutical and Medical Devices Evaluation
5) Matters related to the improvement of health Center in the National Institute of Health Sciences, the
care information-processing and management OPSR, and part of the Medical Devices Center, and
system the PMDA started handling all consultation and
review work from the preclinical stage to approvals
6) Matters related to the evaluation of medical
and post-marketing surveillance.
technology (excluding those handled by other
The work of the PMDA can be divided into three
bureaus of MHLW)
main categories: ADR relief work, review work and
 Office of Clinical Trial Promotion safety measures.
Promotion of clinical trials specified in Article 2, The PMDA consists of 25 offices, 6 groups, and
Paragraph 16 of the Pharmaceutical Affairs Law the Kansai and Hokuriku branches as shown in Fig. 2,
(Law No. 145 issued in 1960) (other than those and, the duties are indicated below.
handled by PSEHB) The PMDA is currently working to achieve goals
under the Third Medium Range Plan (2014-2018),
including strengthening and enhancing
3. NATIONAL INSTITUTE OF HEALTH
post-marketing safety measures to ensure the quality
SCIENCES
of products and prevent the occurrence or escalation
In July 1997, the name of the former National of health hazards and striving to speed up and
Institute of Hygienic Sciences was changed to the improve the quality of reviews, in order to be the first
National Institute of Health Sciences. In addition to in the world to facilitate practical use of innovative
its long-standing work related to testing and research drugs, pharmaceutical medical devices and
on drugs, quasi-drugs, cosmetics, medical devices, regenerative m relief systems are definitely used
foods, poisonous and deleterious substances, the when necessary. medicine products, as well
Institute supervised the Pharmaceuticals and Medical conducting publicity activities so that
Devices Evaluation Center to undertake the reviews
1) Drug ADR Relief Work
required for approval to manufacture or import drugs,
quasi-drugs, cosmetics and medical devices, as well  Provision of medical benefits to cover
as the reexamination and the reevaluation of drugs, healthcare expenses, disability pensions,
and medical devices. Thereafter, the Evaluation and survivors pensions for individuals
Center was incorporated into the Pharmaceuticals suffering disease or disability due to adverse
and Medical Devices Agency (PMDA) in April 2004. drug reactions or bioderived infections
 Provision of medical allowances for
treatment of myelo-optico-neuropathy
4. PHARMACEUTICALS AND MEDICAL
(SMON) patients and for HIV carriers and
DEVICES AGENCY, AN INDEPENDENT
AIDS patients
ADMINISTRATIVE ORGANIZATION
 Surveys on damage caused by drugs and
In accordance with the special corporation
research on treatment, etc. of adverse drug
rationalization plan passed by the Cabinet in
reactions as health and welfare work
December 2001, and enactment of the
 Provision of medical allowances based on
Pharmaceuticals and Medical Devices Agency Law in
the Special Measures Law for Provision of
December 2002, the PMDA (KIKO) was established

2018 -5-
Pharmaceutical Regulations in Japan:

Medical Allowances for Treatment of 4.2 Office of Review Management


Hepatitis C Patients Infected by Specified
This office handles tasks related to the planning
Fibrinogen Concentrates or Specified
and drafting of review works, etc., management of the
Coagulation Factor XI Concentrates.
protocol and reports of adverse reactions observed in
2) Review Related Work clinical trials, publication (disclosure) of approval
review results, and receipt and processing of clinical
 Approval reviews of new drugs and medical
trial consultations on new drugs. The office also
devices based on the Pharmaceutical and
handles consultation on regulatory science strategy
Medical Device Act
on drugs and medical devices mainly for universities,
 Guidance and advice related to clinical trials
research institutes, and venture companies.
 Reviews of GLP and GCP compliance of
attached data of approval applications and
4.3 Office of Standards and Guidelines
reexamination and reevaluation applications
Development
 Reviews of manufacturing facilities,
This office handles tasks related to the preparation
processes, and quality control based on
of draft Japanese Pharmacopoeia, standards on
GMP, QMS, etc.
medical devices, standards on drugs, master file
 Confirmation of reexaminations and
systems, and generic names (JAN).
reevaluations based on the Pharmaceutical
and Medical Device Act
4.4 Office of New Drug I
3) Safety Measures
This office confirms clinical trial notifications and
 Collection, analysis, and dissemination of adverse drug reactions and conducts reviews
information related to the quality, efficacy, required for approval, reexaminations, and
and safety of drugs and medical devices reevaluation of gastrointestinal drugs, dermatologic
 Consultations with consumers and other drugs, hormone preparations, and metabolic disease
parties concerning drugs and medical drugs (e.g., anti-diabetic, osteoporosis, gout, and
devices congenital metabolic disorder drugs)
 Guidance and advice for manufacturers, etc.
to improve the safety of drugs and medical 4.5 Office of New Drug II
devices This office confirms clinical trial notifications and
The work of the review and safety offices is adverse drug reactions and conducts reviews
detailed below. required for approval, reexaminations and
reevaluation of new cardiovascular drugs, drugs to
4.1 Office of Review Administration treat Parkinson’s disease, drugs to treat Alzheimer’s
disease, urogenital and anal drugs, combination
This office handles tasks related to the receipt and
drugs, radiopharmaceuticals, and contrast media.
processing of license and other applications, drug
master file (MF) registrations and modifications,
clinical trial notifications, simple consultation 4.6 Office of New Drug III
applications on generic drugs and the issuance of This office confirms clinical trial notifications and
manufacturing/marketing authorization letters, etc. adverse drug reactions and conducts reviews

2018 -6-
Pharmaceutical Regulations in Japan:

required for approval, reexaminations, and 4.11 Office of OTC/Quasi-drugs


reevaluation of new central nervous system drugs,
This office conducts reviews required for the
peripheral nervous system drugs, anesthetic agents,
approval, export certification, and quality
sensory organ drugs (other than drugs for
reevaluations of guidance-mandatory drugs
inflammatory diseases), and narcotics.
non-prescription drugs, quasi-drugs, and cosmetics.

4.7 Office of New Drug IV


4.12 Office of Generic Drugs
This office confirms clinical trial notifications and
This office conducts reviews required for the
adverse drug reactions and conducts reviews
approval, export certification, and quality
required for approval, reexaminations, and
reevaluations of generic drugs, etc. (ethical drugs
reevaluation of antibacterial drugs, antiviral agents
excluding new drugs and extracorporeal diagnostic
(except for anti-HIV/AIDS agents), new respiratory
medicines).
tract drugs, anti-allergy drugs, sensory organ drugs
(limited to drugs for inflammatory diseases), and
4.13 Office of Medical Devices I
anti-HIV/AIDS agents.
This office conducts reviews required for approval
4.8 Office of New Drug V of medical devices intended for use in the fields of
robots/information and communication technology
This office confirms clinical trial notifications and
(ICT)/others and orthopedics/plastic and
adverse drug reactions and conducts reviews
reconstructive surgery.
required for approval, reexaminations, and
reevaluations of antineoplastic drugs.
4.14 Office of Medical Devices II

4.9 Office of Cellular and Tissue-based This office conducts reviews required for approval
Products of medical devices intended for use in the fields of
neurology/psychiatry, respiratory/cerebro/vascular
This office confirms clinical trial notifications and
systems, gastroenterology, reproductive systems,
defects and conducts reviews required for approval,
and dentistry/oral cavity.
reexaminations, and reevaluations of regenerative
medical products (cellular and tissue-based products
4.15 Office of Medical Devices III
and gene therapy products), preliminary reviews for
approval or verification based on the Cartagena This office conducts reviews required for approval
Protocol, and quality review of biological products. of medical devices intended for use in the fields of
ophthalmology/otorhinology, and cardiopulmonary
4.10 Office of Vaccines and Blood Products circulation.

This office confirms clinical trial notifications and


4.16 Office of in Vitro Diagnostics
adverse drug reactions of globulins, blood
coagulation-factor products, vaccines, and antidotes This office conducts reviews required for approval
and performs the reviews required for approval, of in vitro diagnostics.
reexamination, or reevaluation.

2018 -7-
Pharmaceutical Regulations in Japan:

4.17 Office of Compliance and Standards 4.21 Office of Manufacturing/Quality and


Compliance
This office reviews the documentation included
with applications for approval, reexamination, or Work related to compliance inspections for GMP,
reevaluation of drugs, medical devices, and GCTP, QMS, etc. Additionally work related to
regenerative medicine products to assure that the compliance inspections on third-party certification
studies on which the data is based comply with GLP, bodies
GCP, GPSP, study protocol, etc. both ethically and
scientifically to determine if the documents have been 4.22 Office of International Programs
prepared appropriately and accurately based on the
This office makes plans and proposals concerning
study results in accordance with the Criteria for
international activities and undertakes surveys and
Reliability of Application Data (Article 43 of the
coordinations associated with this, coordinates the
Enforcement Regulations, Pharmaceutical Affairs
matters related to international conferences,
Law) (hereinafter “Reliability Criteria”) and examined
international organizations, and foreign government
on site and on paper. Compliance of facilities
organizations and groups, and conducts works
performing GLP-based studies is also examined and
related to the collection and analysis of overseas
certified.
information and foreign public relations campaign.

4.18 Office of Safety I


4.23 Office of International Cooperation
This office undertakes centralized collection and
This office makes plans and proposals concerning
compilation of information related to the quality,
the works conducted by Asia Training Center for
efficacy, and safety of drugs and medical devices,
Pharmaceuticals and Medical Devices Regulatory
conducts surveys and guidance on the application of
Affairs and undertakes surveys and coordinations
such information in medical institutions, and conducts
associated with this.
scientific analysis and evaluation of such safety
information using pharmaceutical and epidemiological
4.24 Advanced Review with Electronic Data
procedures. It also undertakes consultations and
Promotion Group
information dissemination work.
This group makes plans and proposals
4.19 Office of Safety II concerning the use of electronic application data and
undertakes surveys and adjustments associated with
This office undertakes analysis and evaluation of
this. It also proposes education and training relating
adverse reactions of drugs and medical devices.
to the viewing and analysis of electronic application
data, and gathers and organizes information
4.20 Office of Medical Informatics and
concerning the use of electronic application data.
Epidemiology
This office conducts pharmacoepidemiological 4.25 Kansai Branch
evaluation of drugs and works related to
This branch undertakes regulatory science
establishment of MID-NET®.
strategy consultations and GMP and QMS
inspections in the Kansai area.

2018 -8-
Pharmaceutical Regulations in Japan:

4.26 Hokuriku Branch Council (PAFSC) serves as an advisory body to the


MHLW, and reviews and discusses important
This branch provides training on GMP inspections
pharmaceutical and food sanitation-related matters
at manufacturing sites in Toyama prefecture held by
Fig. 3 Organization of the Pharmaceutical Affairs and
Asia Training Center for Pharmaceuticals and Medical
Food Sanitation Council (PAFSC). This council was
Devices Regulatory Affairs (PMDA-ATC).
created by merging of the Central Pharmaceutical
Affairs Council (CPAC) and the Food Sanitation
5. NATIONAL INSTITUTE OF BIOMEDICAL Investigation Council. It is divided into a
INNOVATION, HEALTH AND NUTRITION Pharmaceutical Affairs Committee and a Food
(NIBIOHN) Sanitation Committee. The latter comes under the
The National Institute of Biomedical Innovation Food Sanitation Law and the former under other laws.
was established in April 2005 based on the Law for The Council has as members experts in various
the National Institute of Biomedical Innovation which fields1) including the medical and pharmaceutical
was approved by the 159th National Diet Session and sciences.
promulgated in 2004 to make a major contribution to The frequency of committee meetings differs.
drug research and development by integrating basic For example, the First Committee on New Drugs2) and
research, research on bioresources, and promotion of the Second Committee on New Drugs2), which review
research and development. new drug applications, each meet approximately eight
Research promotion and orphan drug times a year and the Committee on Non-prescription
development promotion, which had been conducted Drugs3) meets four times a year.4) New drugs are
by the PMDA, were transferred to the institute. then reviewed or reported and approved by the
Pharmaceutical Affairs Committee that meets four
times a year.5) 6)
6. JAPAN AGENCY FOR MEDICAL
Note 1) Expert areas: Nursing, life sciences,
RESEARCH AND DEVELOPMENT (AMED)
applied biochemistry, mathematics and
AMED was established on April 1, 2015 to statistics, law, and economics
promote integrated research and development in the
Note 2) Categories of drugs for the Second
field of medicine (medical R&D), from basic research
Committee on New Drugs to review:
to practical application; to ensure smooth application
Antiviral drugs, chemotherapeutic agents,
of the R&D outcomes to practices; and to establish
anti-malignant tumor agents, blood
and maintain an encouraging environment for
products, and biological products. Those
medical R&D comprehensively and effectively.
for the First Committee: Remaining
By supporting research activities of universities therapeutic categories
and research institutions, AMED promotes R&D and
Note 3) Categories of drugs for the Committee on
furthermore establishes an encouraging environment
Non-prescription Drugs to review: New
for R&D.
non-prescription drugs which are
apparently different from existing
7. PHARMACEUTICAL AFFAIRS AND FOOD non-prescription drugs in active ingredient,
SANITATION COUNCIL (PAFSC) strength, dosage/administration,
indications, etc.
The Pharmaceutical Affairs and Food Sanitation

2018 -9-
Pharmaceutical Regulations in Japan:

Note 4) The First and Second Committees on


New Drugs meet in January, February,
April, May, July, August, October, and
November in principle. The Committees
on Non-prescription Drugs meets in
February, May, August, and November in
principle.
Note 5) The Pharmaceutical Affairs Committee
meets in March, June, September, and
December in principle.
Note 6) For recent new drugs, refer to the
homepage on drug information.
(http://www.info.pmda.go.jp)

8. NATIONAL INSTITUTE OF INFECTIOUS


DISEASES
In April 1997, the name of the National Institute of
Health was changed to the National Institute of
Infectious Diseases. The institute undertakes basic
and applied research, reference and surveillance
activities, and collection, analysis, and supply of
information pertaining to infectious diseases, performs
research on the quality control of antibiotics and other
biological products, and undertakes national
certification/testing and activities related to
international cooperation.

 Infectious Diseases Information Center


This Center was established in April 1997 to
undertake surveys and research, and collect and
supply information on infectious diseases, etc.

 AIDS Research Center


This Center was established in April 1988 to
undertake HIV basic research and to develop
methods of prevention and treatment of AIDS.

2018 - 10 -
Pharmaceutical Regulations in Japan:

Ministry of Health, Labour,


and Welfare (MHLW)

Ministry Proper

Minister’s Secretariat

Health Policy Bureau Councils, etc. Affiliated Institutions Local Branches

• Pharmaceutical • National Institute • Regional Bureaus


Health Service Bureau
Affairs and Food of Health Sciences of Health and
Sanitation Council • National Institute Welfare
(PAFSC) of Infectious
• Social Insurance Diseases
Pharmaceutical Safety Council • National Institute
and Environmental
• Central Social of Population and
Health Bureau
Insurance Social Security
(PSEHB)
Medical Council Research
(Chuikyo)
Social Welfare and
War Victim’s Relief
Bureau

Health and Welfare


Bureau for the Elderly

Equal Employment,
Children, and Families
Bureau

Insurance Bureau

Pension Bureau

Director-General for
Policy Planning and
Evaluation

Fig. 1 Organization of Ministry of Health, Labour, and Welfare (Health-related


organizations only)

2018 - 11 -
Pharmaceutical Regulations in Japan:

Pharmaceutical Safety
and Environmental
Pharmaceutical and Medical Devices Agency
Health Bureau (except
(PMDA)
for the Department of
Food Safety)

• General Affairs
• Audit Office • Office of Cellular and Tissue-based
Division
Products
• Pharmaceutical • Office of Vaccines and Blood
Evaluation Products
• Office of General
Division • Office of OTC
Affairs
• Office of Generic Drugs
• Office of Financial
• Medical Device • Office of Medical Devices I
Evaluation Management
• Office of Planning • Office of Medical Devices II
Division
and Coordination • Office of Medical Devices III
• Office of Relief • Office of in Vitro Diagnostics
• Pharmaceutical
Safety Division Funds • Office of Compliance and Standards

• Compliance and
Narcotics
Division • Office of Regulatory • Advanced Review with Electronic
Science Data Promotion Group
• Blood and Blood • Office of Medical Informatics and
Products Epidemiology
Division • Information Technology Promotion
Group
• Office of International Programs
• Office of Review • Asia Training Center for
Administration Pharmaceuticals and Medical
• Office of Review Devices Regulatory Affairs: Office of
Management International Cooperation
• Office of Standards • Kansai Branch
and Guidelines • Hokuriku Branch
Development • Office of Safety I
• Office of Safety II
• Office of Manufacturing/Quality and
Compliance

• Office of New Drug I


• Office of New Drug II
• Office of New Drug III
• Office of New Drug IV
• Office of New Drug V

Fig. 2 Organization of Pharmaceutical Safety and Environmental Health Bureau (PSEHB)


and Pharmaceuticals and Medical Devices Agency (PMDA)

2018 - 12 -
Pharmaceutical Regulations in Japan:

Committee on Japanese Pharmacopoeia

First Committee on Judgment of Sufferers


Subcommittee on Evaluation of Adverse Drug
from Adverse Drug Reactions and ・
Infections Reactions of HPV vaccines

Second Committee on Judgment of


Subcommittee on Evaluation of Adverse Effects of
Sufferers from Adverse Drug Reactions ・
Biological Products
and Infections

First Committee on New Drugs

Second Committee on New Drugs

Committee on Blood Products ・ Subcommittee on Safety of Blood Products


・ Subcommittee on Proper Use of Blood Products
・ Subcommittee on Blood Donation Promotion
Committee on Medical Devices and in
vitro Diagnostics

Committee on Reevaluation of Drugs

Committee on Handling Regulations for


・ Subcommittee on Medicinal Products for Animals by
Regenerative Medicine Products and
Application of recombinant DNA Technology
Biological Products

Committee on Guidance-Mandatory
Drugs and Non-prescription Drugs

Committee on Cosmetics and


Quasi-Drugs

Committee on Safety of Drugs ・ Subcommittee on Safety Measurements

Committee on Safety of Medical Devices


・ Subcommittee on Safety Measurements
and Regenerative Medicine Products

Committee on Designated Substances

・ Subcommittee on Regulations for Handling


Committee on Poisonous and Deleterious
Poisonous and Deleterious Substances
Substances
・ Subcommittee on Poisons and Deleterious Substances

・ Subcommittee on Chemical Substances


Committee on Safety of Chemical
・ Subcommittee on PRTR substances
Substances
・ Subcommittee on safety measures for household products

2018 - 13 -
Pharmaceutical Regulations in Japan:

・ Subcommittee on Veterinary Biological Products


・ Subcommittee on Veterinary Antibiotics

Committee on Veterinary Drugs ・ Subcommittee on Veterinary Non-proprietary drugs


・ Subcommittee on Reexamination of Veterinary Drugs
・ Subcommittee on Residues in Veterinary Drugs
・ Subcommittee on Fishery Drugs

Fig. 3 Organization of the Pharmaceutical Affairs and Food Sanitation Council (PAFSC)
(17 Committees and 19 Subcommittees)

2018 - 14 -
Pharmaceutical Regulations in Japan:

CHAPTER 2 Modern pharmaceutical legislation originated in


Japan with the enactment of the Regulations on
PHARMACEUTICAL LAWS Handling and Sales of Medicines in 1889. The
Pharmaceutical Affairs Law was enacted in 1943 and
AND REGULATIONS has been revised several times since then. The
current Pharmaceutical Affairs Law (Law No. 145) is
the result of complete revisions in 1948 and 1960.
Subsequent revisions have included those related to
1. PHARMACEUTICAL LAWS
reevaluation of new drugs after reexamination,
Pharmaceutical administration in Japan is based notification of clinical study protocols, and items
on various laws and regulations, consisting mainly of: required for sponsoring clinical studies in 1979, those
(1) Pharmaceutical and Medical Device Act, (2) Law related to direct manufacturing approval applications
Concerning the Establishment for Pharmaceuticals by overseas pharmaceutical manufacturers, and the
and Medical Devices Organization, (3) Law transfer of manufacturing or import approvals in 1983,
Concerning Securing Stable Supply of Blood and those related to promotion of R&D of orphan
Products, (4) Poisonous and Deleterious Substances drugs and priority reviews for such drugs in 1993.
Control Law, (5) Narcotics and Psychotropics Control
In 2002, the Pharmaceutical Affairs Law (Law No.
Law, (6) Cannabis Control Law, (7) Opium Law, and
96 dated July 31, 2002) was revised based on
(8) Stimulants Control Law.
demands for augmentation of safety assurance in
For the enforcement and management of these keeping with the age of biotechnology and genomics,
laws, detailed regulations are prepared by the augmentation of post-marketing surveillance policies,
government in the form of ministerial ordinances and revisions of the approval and licensing system
notices, such as the Enforcement Ordinance and the (clarification of the responsibility of companies for
Enforcement Regulations of the Pharmaceutical and safety measures and revisions of the manufacturing
Medical Device Act, and notifications issued by the approval system in accordance with international
Director General of the Bureaus or the directors of the coordination) and a radical revision of safety policies
Divisions in charge in the Ministry of Health, Labour, for medical devices. According to the revised Law,
and Welfare. the Provisions on the enhancement of safety
measures for biological products came into effect on
July 30, 2003 and the provisions related to the
2. PHARMACEUTICAL AND MEDICAL
manufacturing/marketing approval system,
DEVICE ACT
manufacturing/marketing businesses, and
The objectives of the Pharmaceutical and Medical manufacturing businesses, as well as the provisions
Device Act are to improve public health through related to medical devices came into effect on April 1,
regulations required to assure quality, efficacy, and 2005.
safety of drugs, quasi-drugs, cosmetics, medical
Thereafter, the Law for Partial Amendment of the
devices, and regenerative medicine products and to
Pharmaceutical Affairs Law (Law No. 69 dated June
prevent hazard and expansion of hazard in public
14, 2006) to revise the OTC drug selling system and
health caused by use of those products, as well as
strengthen the control of illegal drugs was issued in
through measures required to promote R&D of drugs,
June 2006 and enforced on June 1, 2009 as planned.
medical devices and regenerative medicine products
The amended Pharmaceutical Affairs Law has
that are especially essential for health care.

2018 - 15 -
Pharmaceutical Regulations in Japan:

classified non-prescription drugs according to Businesses of Drugs, Quasi-drugs


potential risks (type 1: especially high risk, type 2: and Cosmetics (Articles 12 to 23)
relatively high risk, and type 3: relatively low risk) and Chapter 5: Manufacturing/Marketing
the systems of information dissemination and Businesses, etc. of Medical
consultation on drugs for each classification were Devices and in vitro Diagnostics
implemented.
Section 1 Manufacturing/Marketing
In 2013, the Law for Partial Amendment of the Businesses of Medical Devices and
Pharmaceutical Affairs Law (Law No. 84 dated in vitro Diagnostics (Article 23-2 to
November 27, 2013) was issued for strengthening 23-2-22).
safety measures and for establishing regulations and
Section 2 Third-party Certification
control on medical devices and regenerative medicine
Bodies (Article 23-2-23 to 23-19)
products in view of their properties and
Chapter 6: Manufacturing/Marketing
characteristics. The Law was enacted on November
Businesses of Cellular and
25, 2014. In conjunction with this law, the Law for
Tissue-based Products (Article
Partial Amendment of the Pharmaceutical Affairs Law
23-20 to 23-42)
and the Pharmacists Law (Law No. 103 dated
December 13, 2013) was issued in the same year for Chapter 7: Retail Sellers, etc. of Drugs,
clarifying the Internet retailing rules of non-prescription Medical Devices and Cellular and
drugs and for tightening regulations on designated Tissue-based Products
drugs/substances. The Law was enacted on June Section 1 Retail Sellers of drugs
12, 2014 (provisions strengthening regulation of (Articles 24 to 38)
designated substances were enacted on April 1, Section 2 Retail Sellers, Leasers
2014). and Repairers of Medical Devices
In the revised Pharmaceutical Affairs Law enacted (Articles 39 to 40-4)
on November 25, 2014, regulations on drugs, medical Section 3 Retail Sellers of Cellular
devices and regenerative medicine products were and Tissue-based Products
divided into individual chapters to restructure the (Articles 40-5 to 40-7)
entire framework, as well as the Pharmaceutical
Chapter 8: Standards and Government
Affairs Law was renamed to be the Law for Ensuring
Certification for Drugs (Article 41 to
Quality, Efficacy, and Safety of Drugs and Medical
Article 43)
Devices (commonly-called the Pharmaceutical and
Chapter 9: Handling of Drugs
Medical Device Act).
Section 1 Handling of Poisonous
The revised Law, Pharmaceutical and Medical
and Deleterious Substances
Device Act, consists of 17 chapters and 91 articles as
(Articles 44 to 48)
outlined below.
Section 2 Handling of Drugs
Chapter 1: General Provisions (Articles 1 to 2)
(Articles 49 to 58)
Chapter 2: Prefectural Pha rmaceutical
Section 3 Handling of Quasi-drugs
Affairs Councils (Article 3)
(Articles 59 and 60)
Chapter 3: Pharmacies (Articles 4 to 11)
Section 4 Handling of Cosmetics
Chapter 4: Manufacturing/Marketing (Articles 61 and 62)

2018 - 16 -
Pharmaceutical Regulations in Japan:

Section 5 Handling of Medical 1) Substances listed in the Japanese


Devices (Articles 63 to 65) Pharmacopoeia.
Section 6 Handling of Cellular and 2) Substances (other than quasi-drugs and
Tissue-based Products (Articles regenerative medicine products), which are
65-2 to 65-6) intended for use in the diagnosis, treatment,
Chapter 10: Advertising of Drugs, etc. (Articles or prevention of disease in humans or
66 to 68) animals, and which are not equipment or
instruments, including dental materials,
Chapter 11: Safety of Drugs, etc. (Articles 68-2
medical supplies, sanitary materials, and
to 68-15)
programs.
Chapter 12: Special Handling of Biological
3) Substances (other than quasi-drugs,
Products (Articles 68-16 to 68-25)
cosmetics or regenerative medicine
Chapter 13: Supervision (Articles 69 to 76-3)
products) which are intended to affect the
Chapter 14: Handling of Designated structure or functions of the body of
Substances (Articles 76-4 to 77) humans or animals, and which are not
Chapter 15: Designation of orphan drugs, equipment or instruments.
orphan medical devices and
cellular and tissue-based orphan 3.2 Classification of Drugs
products (Articles 77-2 to 77-7)
Drugs (medicinal products) (“iyakuhin” in
Chapter 16: Miscellaneous Provisions (Article Japanese) can be classified as follows based on the
78 to 83-5) regulatory provisions in the Pharmaceutical and
Chapter 17: Penal Provisions (Article 83-6 to Medical Device Act, etc. among others.
91)
1) Classification according to use and supply
(1) Pharmacy drugs (Article 4 in the Law)
3. OUTLINE OF PHARMACEUTICAL
Drugs other than guidance- mandatory
REGULATIONS
drugs and non-prescription drugs.
Various regulations apply to the development, Includes prescription drugs
manufacture, import, marketing, and proper use of (drugs intended for use by a physician or dentist
drugs and medical devices in the form of the or under the prescription or instructions of a
Pharmaceutical and Medical Device Act, cabinet physician or a dentist)
orders, MHLW ordinances, etc. An outline of the (2) Guidance-mandatory drugs (Article 4 in the
main regulations affecting pharmaceuticals is Law)
presented here.
Guidance-mandatory drugs are designated by
the MHLW as drugs which clinical effects are not
3.1 Definition of Drugs
as significant as prescription drugs and intended to
Drugs subject to the regulations in the be selected and used by the consumer based on
Pharmaceutical and Medical Device Act are defined information provided by the pharmacist, etc. and
as follows in Article 2, Paragraph 1 of the Law. must be sold via face-to-face consultation with a
The term "drugs" refers to the following substances: pharmacist. Deleterious substances and early
switch OTC products are applicable. This is a

2018 - 17 -
Pharmaceutical Regulations in Japan:

new classification created in amendment of the (7) Psychotropic drugs (Narcotics and
Pharmaceutical Affairs Law enacted on June 12, Psychotropics Control Law).
2014 (Law No. 103 dated December 13, 2013). (8) Opium (Opium Law).
(3) Non-prescription drugs (Article 4 in the Law) (9) Cannabis (Cannabis Control Law).
Non-prescription drugs are defined as those (10) Stimulants (Stimulant Control Law).
in which clinical effects are not as significant as
3) Biological products and specified biological
in prescription drugs and which a consumer
products
may select and use based on information
provided by a pharmacist, etc. Those are Biological products were classified as follows
neither pharmacy drugs nor based on the definition by the regulations and risk
guidance-mandatory drugs. Those are classified of infection as specified in Notification No.
into three types based on the degree of risks to 0731011 of the PMSB dated July 31, 2002, from
humans: Type 1 (highly risky), Type 2 (moderately the standpoint of augmentation of safety
risky) and Type 3 (relatively low risky). In the measures in keeping with advances in science
revised Pharmaceutical Affairs Law enacted on and technology including biotechnology and
June 12, 2014, non-prescription drugs may be genomics.
retailed via the Internet in accordance with the (1) Biological products
proper rule. Drugs, quasi-drugs, cosmetics, or
2) Classification according to handling medical devices using materials
regulations related to safety manufactured from humans or other
organisms (excluding plants) as raw
Drugs include those that are highly poisonous,
materials or packaging materials, which
which have serious adverse reactions and which
are designated as requiring special
are addictive or habit forming. They are
precautions in terms of public health and
classified as follows in related laws such as the
hygiene.
Pharmaceutical and Medical Device Act or the
Stimulants Control Law (Table 1 Main regulatory (2) Specified biological products
drug classification). Biological products designated as
(1) Poisonous substances (Article 44 of the requiring measures to prevent the onset
Law). or spread of risk to public health and
hygiene due to the biological product
(2) Deleterious substances (Article 44 of the
concerned after selling, leasing, or
Law).
giving.
(3) Drugs requiring a prescription (Article 49 of
Biological products and specified biological
the Law).
products are specified by the Minister of Health,
(4) Habit-forming drugs (Article 50 of the Labour and Welfare in its Ordinance No. 209
Law). issued in 2003 and Notification No. 0520001 of the
(5) Drugs for specially designated diseases PMSB dated May 20, 2003 that came into effect on
(Article 67 of the Law). July 30, 2003.
(6) Narcotics (Narcotics and Psychotropics Based on the provisions in the Pharmaceutical
Control Law). and Medical Device Act for biological products and

2018 - 18 -
Pharmaceutical Regulations in Japan:

specified biological products, the “Manufacturing issued specifying the basic technical requirements
Supervisors and Import and Marketing Supervisors to assure the quality and safety of human-derived
for Biological Products,” “Labeling on the Immediate (autologous) somatic stem cells, human-derived
Container or Packaging,” “Entries in the Package (homologous) somatic stem cells, human-derived
Inserts (Notification No. 0515005 of the PMSB (autologous) iPS (-like) cells, human-derived
dated May 20, 2003),” ”Periodic Infection Reporting (homologous) iPS (-like) cells, and human-derived
System (Notification No. 0515008 of the PMSB ES cells, (Notification Nos. 0907-(2) to (6) of the
dated May 15, 2003),” ”Records and Their PFSB dated September 7, 2012).
Retention,” “Outsourcing of Records and Their
Retention,” “Dissemination of Information,” and 3.3 License for Manufacturing/Marketing
“Manufacturing Control and Quality Control” are Businesses
specified in Notification No. 0515017 of the PMSB
A person wishing to start manufacturing/marketing
dated May 15, 2003 and Notification No. 0520004
business for drugs, medical devices and cellular and
of the PMSB dated May 20, 2003, etc.
tissue-based products, etc. must obtain a
4) Regenerative medicine products manufacturing/marketing business license of the
The Pharmaceutical and Medical Device Act prefectural governor depending on the type of
specifies a new definition for cellular and business.
tissue-based products to be distinguished from These licenses are of the following nine types.
“drugs” and “medical devices”. These are Manufacturing/Marketing businesses of in vitro
specifically defined as products derived from diagnostics and cellular and tissue-based products
human cells via cultures, etc., to be used for (1) were newly established in accordance with
reconstruction, repair or formulation of structure or amendment of the Pharmaceutical Affairs Law
function of the body and (2) treatment or prevention enacted on November 25, 2014.
of disease, or to be induced into human cells for
(1) Type 1 drug manufacturing/marketing
gene therapy.
business license: Marketing of prescription
The basic technical requirements to assure the drugs
quality and safety of drugs and medical devices
(2) Type 2 drug manufacturing/marketing
processed from human-derived (autologous) cells
business license: Marketing of drugs other
and tissues are specified on February 8, 2008
than prescription drugs
(Notification No. 0208003 of the PFSB). On
(3) Quasi-drug manufacturing/marketing
March 27, 2008, the manufacturing control and
business license: Marketing of quasi-drugs
quality control of drugs and medical devices
processed from human-derived (autologous) cells (4) Cosmetic drug manufacturing/marketing
and tissues (Notification No. 0327027 of the business license: Marketing of cosmetics
Compliance and Narcotics Division, PFSB) was (5) Type 1 medical device
issued. The basic technical requirements to manufacturing/marketing business license:
assure the quality and safety of drugs and medical Marketing of specially controlled medical
devices processed from human-derived devices
(homologous) cells and tissues are specified on (6) Type 2 medical device
September 12, 2008 (Notification No. 0912006 of manufacturing/marketing business license:
the PFSB). In addition, separate notifications were Marketing of controlled medical devices

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Pharmaceutical Regulations in Japan:

(7) Type 3 medical device 3.4 License for Manufacturing Business and
manufacturing/marketing business license: Accreditation of Overseas Manufacturers
Marketing of general medical devices
1) Licenses for manufacturing businesses
(8) Manufacturing/marketing business license A person wishing to start manufacturing business
of in vitro diagnostics: Marketing of in vitro for drugs, quasi-drugs or cosmetics is required to
diagnostics comply with the Regulations for Buildings and
(9) Manufacturing/marketing business license Equipment of Pharmacies, etc., that specify standards
of cellular and tissue-based products: for structures and equipment in manufacturing plants
Marketing of cellular and tissue-based for each manufacturing category specified by the
products applicable Ministerial ordinance and must obtain a
The licensing requirements for drug manufacturing business license for individual
manufacturing/marketing businesses include the manufacturing categories from the prefectural
appointment of a general marketing compliance governor. These licenses are of the following five
officer of drugs, etc., who is a pharmacist, and categories:
compliance with Good Quality Practice (GQP) for (1) Category of biological products
quality control and Good Vigilance Practice (GVP) for
(2) Category of radioactive products
postmarketing safety surveillance.
(3) Category of sterile products
Manufacturing/marketing business license is valid for
a period of 5 years after every renewal. (4) General category of products
The general drug marketing compliance officer, (5) Category of packaging, labeling and
the quality assurance supervisor of the quality storage
assurance unit in charge of GQP, and the safety Manufacturing business license is valid for a
management supervisor of the general safety period of 5 years after every renewal.
management division in charge of GVP are known as A person wishing to start manufacturing business
the “manufacturing/marketing triumvirate” and are at for cellular and tissue-based products is required to
the center of the marketing system. Appropriate comply with the Regulations for Buildings and
implementation of the activities of the triumvirate is Equipment of Pharmacies, etc., and must obtain a
required for the manufacturing/marketing business manufacturing business license for cellular and
license holder, and a notification covering the points to tissue-based products in each manufacturing plant
consider to clarify the position and requirements of a from the prefectural governor.
general drug marketing compliance officer as well as
After enforcement of the Law for Partial
the chain of command, roles and authority of the
Amendment of the Pharmaceutical Affairs Law in
triumvirate, to ensure the human resources
November 2014, registration is required for
necessary for notifying them in the company and
manufacturing business of medical devices and
carrying out the activities, and to conduct quality
extracorporeal diagnostic medicines, instead of
management activities and safety assurance
previously required business licenses. Each
activities, etc. was issued (Notification No. 0626-(3) of
manufacturing plant is required to register its
the PSEHB dated June 26, 2017).
manufacturing business.

2) Accreditation of manufacturing business of


overseas manufacturers

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Pharmaceutical Regulations in Japan:

A person wishing to manufacture drugs, - When the applicant is a corporation, the


quasi-drugs or cosmetics exported to Japan from representative (director with representative
overseas (overseas manufacturers) must receive authority) makes the application.
accreditation from the Minister. The specifications - The agent applying on behalf of a person
for accreditation are the same as those for intending to obtain a
manufacturing licenses for domestic manufacturers. manufacturing/marketing business license
A person intending to start manufacturing should apply with the confirmed type of
regenerative medicine products to be exported to corporation, name, address and
Japan in a foreign country must also obtain representative of the oversea manufacture.
accreditation of an overseas manufacturer of The name and contact information for the
regenerative medicine products. agent is entered in the Remarks section of
Accreditation of overseas manufacturers is valid the application form. The note “Application
for a period of 5 years. Application for accreditation by an associated manufacturing/marketing
renewal has to be submitted at least 5 months before business license holder” should also be
end of the valid period (Office communication of the entered in the form, if the application is filed
Evaluation and Licensing Division, PSEHB, dated by an agent manufacturing/marketing
March 29, 2016). authorization holder (of drugs, etc.
After enforcement of the Law for Partial manufactured by the person applying for
Amendment of the Pharmaceutical Affairs Law in accreditation of an overseas manufacturers).
November 2014, registration is also required for An application by an agent should be made
overseas manufacturing business of medical devices by an authorized agent of the
and extracorporeal diagnostic medicines, instead of manufacturing/marketing business license
previously required business accreditation. Each holder, as a rule; however, there are other
manufacturing plant is required to register its permissible cases of application not
manufacturing business. The procedures for involving authorized agent (Notification No.
obtaining the accreditation of overseas manufacturers 1008-(1) of PMDA dated October 8, 2010).
are described as follows in the “Q&A on Accreditation (2) Timing of applications for accreditation of
of Overseas Manufacturers” (Office communication of overseas manufacturers
the Evaluation and Licensing Division, PFSB dated The application should be submitted by the time
February 14, 2006), etc. Refer to the PMDA of the marketing approval application. When
homepage for reference. accreditation is not obtained beforehand, “under
Japanese HP: application” should be entered in the marketing
http://www.pmda.go.jp/review-services/drug-reviews/f approval application form. (Marketing approval
oreign-mfr/0010.html cannot be obtained without accreditation
English HP: approval.)

http://www.pmda.go.jp/english/review-services/review (3) Outline of the structure and facilities of the


s/foreign-mfr/0001.html manufacturing plant required for accreditation of
overseas manufacturers and attached
(1) Applicants for accreditation of manufacturing
documentation
business of overseas manufacturers and their
- The outline of the structure and facilities of
agents
the manufacturing plant should be based on

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Pharmaceutical Regulations in Japan:

that in the manufacturing business license Marketing approvals require a review to determine
application in Japan. A list of the structures whether or not the product in the application is
and facilities must be included. suitable as a drug to be marketed by the marketing
- When Japanese cannot be used as the authorization holder and confirmation that the product
language in the attached documentation has been manufactured in a plant compliant with the
under special circumstances, a foreign criteria in GMP.
language can be used, but a Japanese Approval items specified in the approval certificate
translation must be attached in such cases. are as follows: When a change is made on approval
If the foreign language is not English, items except for brand name, a partial change
certification of the translator must be application or slight modification notification has to be
attached. submitted.
- For executive officers, if a corporation, prima Brand name
facie documents should be submitted to Ingredients and quantities, or nature
assure that they are not affected by
Manufacturing process
psychosomatic disorder or intoxicated with
Dosage and administration
narcotics, cannabinoids, opium or
psychostimulants (Article 35-2 of the Indications
Enforcement Regulations). Storage condition and shelf life
(4) On-site surveys for accreditation of overseas Specifications and testing methods
manufacturers Manufacturing plant of item to be marketed
When a GMP compliance survey is performed Manufacturing plant of the drug substance
simultaneously with the accreditation, the
structures and facilities are required for 3.6 Good Manufacturing Practice (GMP)
accreditation to be confirmed in the GMP
GMP specifies that compliance with the
compliance survey, as a rule.
Regulations for Buildings and Equipment of
Pharmacies, etc. that specify standards for structures
3.5 Manufacturing/Marketing Approvals
and equipment in manufacturing plants for each
Formal approvals are required for individual manufacturing category without relation to the
formulations of drugs in order to market the drugs in products manufactured is a requirement for a
Japan. Formal approval must be obtained prior to manufacturing business license. Compliance with
market launch from the Minister of the MHLW or the criteria in GMP that specifies standards for
prefectural governor by submitting data and structures and equipment required for the product
documents for required review on product quality, concerned as well as standards for manufacturing
efficacy, and safety. control and quality control for each manufactured
The approval and licensing system has been product is a condition for approval of the drug
revised in the amended Law and manufacturing concerned (refer to Chapter 3).
(import) approvals became marketing approvals from In consideration of the characteristics of clinical
April 2005. Product licenses have been abolished trials including the early exploratory stage, the GMP
and compliance with the criteria in GMP for each for investigational products was amended on July 9,
product has been specified as an approval condition. 2008 to make it possible to assure the quality of the

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Pharmaceutical Regulations in Japan:

investigational product at each stage of the clinical trial medicine products (e.g., cells, media, medium
(Notification No. 0709002 of the PFSB). Thereafter, additives or processing materials of cells) may also be
Q&A on the GMP for Investigational Products was registered through the system.
published (Office Communication of the Inspection When an overseas drug substance manufacturer
and Guidance Division, Narcotics Division, PFSB submits an MF registration application, it is necessary
dated July 2, 2009). to appoint a drug substance in-country caretaker to
MHLW, PMDA, and prefectures had submitted bid handle the activities of the MF registrant in Japan (MF
for membership to the office of Pharmaceutical in-country caretaker). The MF in-country caretaker
Inspection Cooperation Scheme (PIC/S) in March mediates communication between the MF registrant
2012, which guarantees a high level of the and the manufacturer or Japanese regulatory
implementation of the internationally recognized GMP authority.
rules, to further promote international standardization When the registered contents of the MF are
and conformity in GMP inspection, and then became changed, an application to change the MF or a minor
members since July 1, 2014. The enforcement MF modification notification must be submitted.
notification of the GMP was amended accordingly in
When an application to change of the MF is
August 2013 to meet criteria in the PIC/S. (Notification
submitted, the manufacturing/marketing authorization
No. 0830-(1) of the Compliance and Narcotics
holder also must submit a partial change application
Division dated August 30, 2013.)
or a slight modification notification for the MF
depending on the contents of the change. When a
3.7 Drug Master File (MF) minor MF modification notification is submitted,
With the amendment of the Pharmaceutical Affairs however, a procedure for changing the approval
Law enforced in April 2005, approvals for drug certificate is not required. In either case, the MF
substances that had been necessary in the past were registrant must notify the manufacturing/marketing
no longer required and instead the information of authorization holder of the change(s) in advance
quality and manufacturing method of drug substance through the MF in-country caretaker.
are required to be included in the application Information of chemicals, drug substances, drug
document of finished product. The master file (MF) products, etc. registered under the MF system is
system aims at protecting intellectual property of publicly available at the following PMDA homepages.
relevant information at the time of license application Japanese HP:
and facilitating review work by allowing a registrant
http://www.pmda.go.jp/review-services/drug-reviews/
(master file registrant) of drug substances to submit
master-files/0008.html
information on quality and the manufacturing method
English HP:
of drug substances to be used in drug products in the
form of MF (Notifications No. 1117-(3) of the http://www.pmda.go.jp/english/review-services/review
Evaluation and Licensing Division of PFSB and No. s/mf/0001.html
1117-(1) of the Director of Medical Devices Evaluation,
Evaluation and Licensing Division of PFSB dated 3.8 Drug Retail Seller Licensing
November 17, 2014). MF registration is optional. A license must be obtained from the Prefectural
Items that may be registered through the MF Governor or other specified officials for marketing or
system are drug substances, intermediates, and otherwise providing of drugs. Licenses for drug
additives, nevertheless raw materials of regenerative retailers have been classified as follows based on

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Pharmaceutical Regulations in Japan:

amendment of the Pharmaceutical Affairs Law included. Entries in the package inserts of biological
enacted on June 1, 2009 (Law No. 69 dated from products are specified in Notification No. 0515005 of
June 14, 2006): the PMSB dated May 15, 2003 and labeling on the
(1) Store-based drug sellers: Operations in immediate container or packaging of biological
which guidance-mandatory drugs or products is specified in Notification No. 0515017 of
non-prescription drugs are marketed or the PMSB dated May 15, 2003. These
provided at a store specifications came into effect from July 30, 2003.
According to the Pharmaceutical Affairs Law
(2) Drug sellers by household distribution:
amended on April 1, 2005, a new regulatory category
Operations in which non-prescription
for prescription drug labeling “Caution: Use only with a
drugs are marketed or provided through
prescription from a physician” and a labeling item for
distribution
manufacturer/marketing business instead of
(3) Drug sellers wholesale distribution:
manufacturer or importer were added.
Operations in which drugs are marketed or
The Law for Partial Amendment of the
provided to proprietors of pharmacy,
Pharmaceutical Affairs Law enforced on June 1, 2009
pharmaceutical manufacturing/marketing
(Law No. 69, June 14, 2006) mandates
authorization holders, manufacturers or
non-prescription drugs to be classified into one of type
distributors, or hospitals, clinics or other
1, type 2, and type 3 according to the risk and to bear
parties specified under the MHLW
a label indicating the type.
Ordinance
In addition, barcode labeling of prescription drugs
Marketing business license is valid for a period of
(excluding extracorporeal diagnostic medicines) was
6 years.
partially mandated in July 2015 to prevent medical
At pharmacies and store-based drug sellers,
accidents due to misunderstandings, ensure
pharmacists can market guidance-mandatory drugs
traceability, and improve the efficiency in prescription
or type 1 non-prescription drugs, and pharmacists or
drug distribution (Notification No. 1 of the Economic
registered sellers can market type 2 and type 3
Affairs Division, HPB and No. 1 of the Safety Division,
non-prescription drugs..
PFSB both dated June 29, 2012). Moreover, it has
Non-prescription drugs may be marketed on the been requested to increase the range of essential
Internet since June 2014, only if these are also labeling, to take more rapid and reliable measures to
marketed in an actual store with an applicable identify and manage batch numbers, etc. in the
marketing business license. distribution process, and to carry out important
For drug sellers by wholesale distribution, a responsibilities in taking safety measures by April
pharmacist must be allocated to each sales office and 2020 (or by April 2022 in special circumstances).
thereby assigned to management of the office. Furthermore, preparation of medication guides for
patients are being promoted so that the patient
3.9 Labeling and Package Inserts understands the prescription drug correctly, and
Specified items must be entered on the immediate serious adverse drug reactions can be discovered at
container of drugs. The package inserts must an early stage (Notification No. 0630001 of the Safety
contain indications, dosage/administration, Division, PFSB dated June 30, and No. 0331-1 of the
precautions, and precautions for handling. In Safety Division, PFSB and No. 0331-8 of the
addition, all ingredients used as excipients must be Compliance and Narcotics Division, PFSB both dated

2018 - 24 -
Pharmaceutical Regulations in Japan:

March 31, 2014). include interpretation of the Law about description of


In the revised Pharmaceutical Affairs Law enacted names, indications or dosage/administrations, etc. of
on November 25, 2014 (Law No. 84, November 27, the drug, etc. as well as matters to be adhered to
2013), the new package insert notification system otherwise misuse or abuse may be encouraged or
was introduced to enhance safety assurance confidence may be lost among general users
measures. Manufacturing/marketing authorization (Notification No. 0929(4) of the PSEHB dated
holders must prepare package inserts based on September 29, 2017, and Notification No. 0929(5) of
scientific knowledge and information obtained from the Compliance and Narcotics Division of PSEHB
latest literatures, etc. to provide related information. dated September 29, 2017).
Furthermore, before initiation of Appropriateness of advertisement of drugs shall
manufacturing/marketing or amendment, they must be judged based on the following requirements: the
submit to the PMDA the package insert that covers all advertisement clearly intend to attract customers
the required information such as precautions for use (enhances purchase motivation of customers); it
and handling. The package insert must be present the commercial name and class clearly such
published on the PMDA homepage immediately after as specified drug; and it be accessible to general
submission of the notification. public (Notification No. 148 of the Inspection and
The guidelines on preparation of package inserts Guidance Division, PMSB dated September 29,
(except for vaccines) have been revised into the 1998).
guidelines which are easier to understand and use. With the recent increased awareness of the public
They will be applied from April 1, 2019. The package concerning health and the spread of the Internet,
inserts for the drugs which have already been there have been cases of advertisement of
approved and the drugs for which application for unapproved drugs by persons acting as importers.
approval has already been filed must be revised as Therefore, a notification has been issued concerning
soon as possible according to the revised guidelines guidance and control of individual importers including
on preparation of package inserts by March 31, 2024 items related to drug advertising (Notification No.
(Notification No. 0608-(1) of the PSEHB dated June 8, 0828014 of the PMSB dated August 28, 2002).
2017)
3.11 Good Laboratory Practice (GLP)
3.10 Proper Advertisement
GLP specifies standards that must be met by
The “Standards for Proper Advertisement of Drugs, testing facilities for nonclinical safety tests on drugs
etc.” have been established for the purpose that from the viewpoint of the structure/equipment and the
advertisement of drugs, etc. should made properly operation/management of the facilities. The first
and should not include false information or GLP guideline was issued as a PAB notification in
exaggerated statement, so that harm caused by 1982, but was changed to a MHW ordinance on
drugs, etc. should be prevented in public health. The March 26, 1997 (Ordinance No. 21: GLP dated
standards shall be applied to advertisements on all March 26, 1997) that was enforced on April 1, 1997 to
media including newspapers, magazines, TV, radio, assure greater reliability of application data.
website, and social network services. A person The GLP ordinance was partially revised by
intending to advertise drugs, etc. should make efforts MHLW Ordinance No. 114 entitled “MHLW
to disseminate accurate information so that users Ordinance to Partially Amend the MHLW Ordnance
may use the drug, etc. properly. The standards on Standards for Implementation of Nonclinical

2018 - 25 -
Pharmaceutical Regulations in Japan:

Studies on Safety of Drugs” dated June 13, 2008 and On receiving results of discussion from the MHLW
the amendment was enacted on August 15, 2008. Council of Ideal Registration-Directed Clinical Trials,
Notification No. 0620059 of the PMDA entitled the requirements for designating IRB members have
“ Establishment of Guidelines for Drug GLP and been relaxed as measures for securing the reliability
Medical Device GLP On-site Inspections” was issued of the IRB and improving the functions of the IRB
on June 20, 2008 and partially amended on (MHLW Ordinance No. 72 issued in 2006).
November 21, 2014 (Notification No. 1121005 of the ● 2007
PMDA).
In accordance with a report compiled by the
Council of Ideal Registration-Directed Clinical Trials,
3.12 Good Clinical Practice (GCP) the Notification entitled “the Common Application
”Clinical trials” refer to studies with the objective of Form for Clinical Trial Notification” was jointly issued
collecting data on clinical trial results from among the by the Research and Development Division of HPB
data attached to drug approval application forms. In (Notification No. 1221002 of the Research and
Japan, clinical trials are conducted in accordance with Development Division of HPB dated December 21,
the GCP which was implemented to assure scientific 2007; revised by Notification No. 0326-(1) of the
quality and reliability of clinical study data. This GCP Research and Development Division of HPB and
was replaced by the Standards for the Conduct of Notification No. 0326-(1) of the Evaluation and
Clinical Studies (MHW Ordinance No. 28, dated Licensing Division of PFSB dated March 26, 2013)
March 27, 1997) based on the ICH-GCP Guidelines was issued to reevaluate and rationalize the type and
(E6) (see Chapter 3 for details). Operating scope of documents necessary for the conduct of
procedures of the implementation of the New GCP clinical trials.
were issued as notifications of the Pharmaceutical ● 2008
Affairs Bureau (March 1997) and the Evaluation and The GCP ordinance (MHLW Ordinance No. 24,
Licensing Division, PFSB (May 1997). 2008) made public disclosure of IRB review results in
Since then, standards intended to activate clinical summary format compulsory. Then, “the
trials have been established for utilization of site Registration of IRB Information (Request)”
management organizations (SMOs), training of (Notification No. 1001013 of the Evaluation and
clinical research coordinators (CRCs), and Licensing Division, PFSB dated October 1, 2008) was
implementation of a site monitoring system. In 2003, issued to provide an environment for trial-related
a system of investigator-initiated clinical trials was people to easily access IRB information and to inform
officially introduced (Ministerial Ordinance No. 106, the public of such information.
2003). Even after that, discussion has been held for Further, limitations for selecting the IRB were
measures to ensure reliability of clinical trials and reviewed and currently the director of medical
safety of study subjects as well as smooth and institution is permitted to select the IRB from among
transparent conduct of clinical studies. IRBs available inside and outside the institution
Consequently, the GCP has been often revised in (MHLW Ordinance No. 24 issued in 2008).
addition to the ministerial ordinances and notifications
● 2011
for implementation.
Notifications for GCP operating procedures were
Other: Enforcement Notification of major changes
revised to include changes in procedures made with
in GCP Ordinance, etc.:
the intent of enhancing efficiency in the conduct of
● 2006

2018 - 26 -
Pharmaceutical Regulations in Japan:

clinical trials and the requirement of precision controls The program came into operation on January 25,
in laboratory tests in global clinical trials, etc. 2016 (Notification No. 0122-7 of the Evaluation and
● 2012 Licensing Division, PSEHB, dated January 22, 2016).

The latest amendment to the GCP was a partial An expanded access trial is conducted after
revision entitled “Ordinance for Partially Modifying the conduct of a trial at the final development phase in
Pharmaceutical Affairs Law Enforcement Regulations, Japan (pivotal trial) in which patients are highly likely
Etc.” (the Ministerial Ordinance No. 161) issued on to benefit from an unapproved drug or off-label use as
December 28, 2012. The main objectives of the expected, or while such trial is ongoing (after
amendment were to improve the efficiency of trial completion of the enrollment). Applicable
procedures, accelerate trial processes, reduce burden investigational products have to be used for serious
on study personnel in investigator-initiated trials, and life-threatening diseases for which no effective
promote industrial-academic cooperation in order to conventional treatment is available.
fulfill unmet medical needs while promoting global To enforce expanded access trials, the GCP
harmonization on the conduct of clinical trials. Ordinance was revised. More specifically, the
Specific points of revision included removal of trial revisions included: (1) a trial conducted from a
parameters of low significance (e.g., target number of compassionate viewpoint is defined as an “expanded
subjects) from clinical trial contract and change from access trial”; (2) a part of matters to be described on
“the coordinating investigator” who submitted trial the investigational product are to be exempted if it is
notification to the regulatory body to “a person” who an investigational product used outside of Japan or a
submitted trial notification to the regulatory body in commercially available approved drug; and (3) a drug
multicenter investigator-initiated trial. to be used in the expanded access trial is required to
be quarantined from the other drugs appropriately
● 2016
(investigational product control/accountability)
The GCP Ordinance was revised on January 22,
(Notification No. 0122-2 of thePSEHB, dated January
2016 according to the "Ministerial Ordinance to
22, 2016).
Partially Revise the Ordinance on Standards for
http://www.pmda.go.jp/review-services/trials/0019.htm
Conduct of Clinical Trials (GCP)" (MHLW Ordinance
l
No. 9). The major points of revision were associated
with the implementation of expanded trials (see 3.13
Trial Conducted from a Compassionate Viewpoint 3.14 Patient-requested Therapy System

(expanded trial)). This system enforced in April 2016 allows patients


to receive an unapproved drug as an uninsured
3.13 Trial Conducted from a Compassionate concomitant therapy at a local medical institution as
Viewpoint (expanded trial) accessible to him or her as possible with the safety
and efficacy being monitored. It is intended to collect
For “unapproved drugs and drugs of off-label use
data that may lead to application of insurance and
with high medical needs,” discussion was held on
scientific evidences.
introduction of a program for enhanced access of
patients not eligible for ongoing trials of these drugs to Medical care potentially supported by the
a trial (trial conducted from a compassionate patient-requested therapy system is one that is
viewpoint or expanded access trial), while the expanded from “advanced medical care” under the
development and process for approval are continued. uninsured concomitant therapy expense system and

2018 - 27 -
Pharmaceutical Regulations in Japan:

is intended to be covered by insurance in the future. so that efficacy and safety can be reconfirmed by
In addition, it has to be originated by the request from reexamination by the MHLW for a specified period
a patient to the MHLW. If the medical care has not after marketing approval.
been used as a patient-requested therapy, a clinical The drugs to be reexamined are the drugs which
research central hospital shall judge the feasibility, have been designated by the Minister of Health,
and submit an application form to the MHLW with Labour and Welfare at the time of marketing approval
attached documents such as protocol. If it has been as the drugs obviously different from existing
used previously, a clinical central hospital shall review approved drugs in terms of active components,
the application, and judge whether it can be used or contents, administration method, dose levels,
not before the clinical use. indications, and so on.
When a patient requests for use of an unapproved The concept of the risk management plan has
drug that has been already used in clinical trials, firstly been incorporated in reexamination. At the same
participation in a pivotal clinical trial or expanded trial time, a notification regarding the documents to be
should be considered. attached to application for reexamination was revised
in 2017 to cope with the above-described revision of
3.15 Good Post-marketing Study Practice the GPSP ordinance (Notification No. 1128-(2) of the
(GPSP) Evaluation and Licensing Division, PSEHB, dated
The GPMSP ordinance was enacted to specify November 28, 2017).
the system and scope of activities of pharmaceutical Refer to Designation for Reexamination in
companies to assure proper implementation of Chapter 4 for the timing of reexamination.
post-marketing surveillance of drugs and reliability of In this connection, applications for generic drugs
the data obtained after marketing. (Ordinance No. cannot be filed until completion of the reexamination.
10 of the MHW dated March 10, 1997) Thereafter, the Branded products are protected from generics during
GPMSP was divided into Good Vigilance Practice this period.
(GVP) and Good Post-marketing Study Practice
(GPSP). The GPSP ordinance was enforced from 3.17 Reevaluation
April 1, 2005. The ordinance was revised on
All drugs, including those that have completed
October 26, 2017 to add the "post-marketing
reexamination must undergo reevaluation to recheck
database survey" to the "drug use-results survey" and
their efficacy, safety, and quality in accordance with
the "post-marketing clinical study," which had been
progress in medical and pharmaceutical sciences.
prescribed as the surveys to be conducted after
marketing. The ordinance will be enforced on April 1, The Minister of Health, Labour and Welfare will
2018 (refer to Chapter 4). hear the opinions of the Pharmaceutical Affairs and
Food Sanitation Council regarding the drugs to be
Data submitted with applications for reexamination
reevaluated, and publicly announce the drugs which
or reevaluation must be collected and compiled in
are judged to necessitate reevaluation. In public
accordance with the GPSP.
announcement, the scope of the drugs to be
reevaluated, documents to be submitted, and due
3.16 Reexamination
date for submission of documents will be presented.
Manufacturing/marketing authorization holders If the documents to be submitted are not collected
must perform post-marketing surveys on new drugs and application is not filed before the due date, the

2018 - 28 -
Pharmaceutical Regulations in Japan:

approval of the drug will be cancelled or other during the development to post-marketing phases of
necessary measures will be taken according to the a new drug’s life cycle. The Ministry issued the Risk
provision in Article 74-2, Paragraph 3 of the Law. Management (RMP) Guidance (Notification No.
0411-(1) of the Safety Division of PFSB and No.
3.18 Adverse Drug Reaction (ADR) and 0411-(2) of the Evaluation and Licensing Division of
Infection Reporting PFSB both dated April 11, 2012) to support the
manufacturing/marketing authorization holder in
When manufacturing/marketing authorization
developing risk minimization plans for the reduction of
holders of drugs are informed of any adverse
treatment-related risks in addition to conventional
reactions, infections, etc. as specified by MHLW
pharmacovigilance plans following drug approval.
ordinance for trial products or their marketed products,
they must report them to the Minister within the The RMP Guidance has applied to new drugs and
specified period (Notification No. 0317006 of the biosimilar products for which manufacturing/marketing
PFSB dated March 17, 2005). Handling of safety approval application is made on or after April 1, 2013
reporting is described in CHAPTER 4. and to generic drugs for which
manufacturing/marketing approval application is
Any serious adverse drug reaction that cannot be
made on or after August 26, 2014.
expected from the investigator’s brochure of the
currently ongoing trial should be reported, whenever it Moreover, details of the guidance have been
occurs. In addition, adverse drug reactions must be presented by the notification entitled, “Formulation of
periodically reported through DSUR on an annual the RMP” (Notification Nos. 0426-(2) of the Evaluation
basis. and Licensing Division and 0426-(1) of the Safety
Division, PFSB both dated April 26, 2012),
As of December 28, 1999, the use of the
“Formulation of the RMP Questions and Answers”
Japanese version of ICH MedDRA (MedDRA/J) was
(Office communication dated September 7, 2012),
authorized for reporting of adverse drug reactions and
“Publication of the RMP” (Notification No. 0304-(1) of
infectious diseases and its use was enforced on April
the Evaluation and Licensing Division and 0304-(1) of
1, 2004 (Notification No. 0325001 of the Safety
the Safety Division, PFSB dated March 4, 2013),
Division and Notification No. 0325032 of the
“Formulation of the RMP Questions and Answers (2)”
Evaluation and Licensing Division, PFSB dated
(Office communication dated March 6, 2013),
March 25, 2004).
“Formulation of the RMP Questions and Answers (3)”
Since October 27, 2003, electronic adverse drug (Office communication dated December 25, 2013),
reaction reports have been accepted (Notification No. and “Formulation of the RMP Questions and Answers
0828010 of the PFSB dated August 28, 2003.). The (4)” (Office communication dated July 29, 2016).
reports are required to be sent to the PMDA from April
https://www.pmda.go.jp/safety/info-services/drugs/ite
1, 2004. (Notification No. 0325013 of PFSB dated
ms-information/rmp/0001.html
March 25, 2004)

3.20 Dissemination of Information


3.19 Risk Management Plan
Marketing authorization holders of drugs or
The basic requirement to ensure the safety of
medical devices, wholesalers, marketing authorization
drugs in clinical practice is to develop and implement
holders or leasers of medical devices, and overseas
appropriate measures to manage potential risks of
restrictive approval holders are asked collect and
drug-related events based on information collected
examine information on efficacy, safety, and proper

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use of drugs and medical devices and supply such which no forms are designated, examples are given
information to health professionals such as physicians and the criteria for disclosure and non-disclosure are
and pharmacists. specified.
Approval application documentation from
3.21 Measures related to the Law Concerning pharmaceutical companies is not accessible as a rule
Access to Information Held by before approval but becomes accessible after
Administrative Organizations approval. However, even after the approval is
With the enactment of the Law Concerning granted, where there is a risk that, by being made
Access to Information Held by Administrative public, the rights, competitive standing, or other
Organizations on April 1, 2001, anyone has the right legitimate interests of the corporation, etc. are harmed,
to request disclosure of documents retained by the information (such as that on the manufacturing
national government organizations. This law covers method, specifications/test methods,
disclosure of documents retained by government comments/discussion of the applicant, etc.) are not
organizations except those concerning disclosed. Out of attached application data, Module
non-disclosable information such as information on 3 (“Quality-Related Documentation” section), Module
individuals, information on corporations, etc. This 4 (“Nonclinical Study Reports” section), and Module 5
was partially amended by Cabinet Order No. 371, on (“Clinical Study Reports” section) are not accessible.
December 21, 2005. The criteria for disclosure of Adverse Drug
Based on this Law, the MHLW must disclose the Reaction Report Forms were revised by Notification
contents of its reviews (records of meetings of the No. 4 of the Federation of Pharmaceutical
PAFSC, new drug approval information dossiers, etc.), Manufacturers' Associations of Japan (FPMAJ) dated
as a rule, and new procedures for processing work January 6, 2004. Notification No. 0330011 of the
related to public disclosure of information retained by PMDA dated March 30, 2011 specifies points to
the PFSB were specified (Notification No. 0330022 of consider in the disclosure of information related to
the PFSB dated March 30, 2007). new drug approval reviews and subsequently issued
Notification No. 0325-(1) of the Evaluation and
These procedures clarify the actual decisions on
Licensing Division, PFSB dated March 25, 2013
whether or not disclosure is granted for documents
partially modified the procedures for public disclosure.
retained by the PFSB (not including those retained by
the Department of Food Safety) (currently PSEHB).
3.22 Patent System
These documents are classified into six types: (1)
evaluation and licensing-related documents, (2) The patent term is 20 years from the time of
safety-related documents, (3) compliance-related application as a rule. However, if the patent cannot
documents, (4) narcotics-related documents, (5) be implemented because of laws and regulations to
blood and blood products-related documents, and (6) ensure safety of drugs and regenerative medicine
other activity-related documents. products, etc. the patent term can be extended for a
Documents for which the forms are designated maximum of 5 years. The extension is for the period
(drug approval application forms, adverse drug that the patented invention cannot be used, such as
reaction report forms, narcotics import license the period from the date of the start of clinical trials
application forms, etc.) are clearly marked as ○ (submission date of clinical trial plan) or date of patent
(disclosure), ● (non-disclosure) or ∆ (partial registration, whichever is later, until one day prior to
disclosure). For approval application summaries for the date on which the patentee receives approval for

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Pharmaceutical Regulations in Japan:

the drug. (For regenerative medicine products, the Drugs of 1961, the Convention on Psychotropic
term may be extended until acquisition of conditional Substances of 1971, and the United Nations
approval and the extension does not cover the Convention against Illicit Traffic in Narcotic Drugs and
subsequent period to acquisition of approval.) Psychotropic Substances of 1988, and has ratified all
Patentees who want an extension of the patent of these conventions. In addition, Japan has
term must submit an application to the Patent Office enacted five laws of its own: the Narcotics and
for extension of registration including the required Psychotropics Control Law, the Opium Law, the
items such as the requested extension period before Cannabis Control Law, the Stimulants Control Law,
the patent rights become invalid within 3 months from and the Law Concerning Special Provisions for the
the date of receipt of drug approval. In cases where Narcotics and Psychotropics Control Law, etc., and
it is anticipated that it will not be possible to obtain Other Matters for the Prevention of Activities
approval as specified by government ordinance by Encouraging Illicit Conduct or Involving Controlled
the day before 6 months prior to the date on which the Substances through International Cooperation.
patent expires, a document showing necessary June 26, the final day of the International Narcotics
information including the patent number must be Conference held in 1987, was designated as
submitted to the Commissioner of Patents. If an “International Drug Abuse Eradication Day.” At a
application for an extension is submitted, it can be special United Nations meeting on narcotics in 1998,
considered that the patent term has been extended the “Declaration on Guidance to Prevent Drug Abuse”
until rejection becomes final or the extension is was adopted.
registered (Fig. 4 Flowchart of Patent-Life Extension). The problem of drug abuse, including narcotics,
Generic drugs will not be approved until the stimulants, and hemp, has spread worldwide at
substance (application) patent has expired. Branded present and it is one of the most serious social
products are protected from generics during this problems affecting the human race not only in terms
period. However, in the past if some of the of survival but also as a threat to safe and stable
indications or dosage and administration of branded societies and nations. Japan is now facing a serious
products were patented, partial approvals were not situation of stimulant abuse with feelings of resistance
granted because of patent protection, but with and alarm concerning drug abuse waning among
Notification No. 065001 of the Economic Affairs young people such as middle and high school
Division, HPB and No. 0605014 of the Evaluation and students.
Licensing Division, PFSB dated June 5, 2009, partial One aim of the Law for Partial Amendment of the
approvals of indications or dosage and administration Pharmaceutical Affairs Law (Law No. 69) issued on
not covered by the patent are permitted. June 14, 2006 was to strengthen control of
Japanese HP of the Patent Office: “dangerous drugs” because such drugs are being
http://www.jpo.go.jp/indexj.htm sold in a disguised form suggesting they are not
intended for human consumption even though they
English HP:
can cause health damage due to abuse and risk
http://www.jpo.go.jp/index.htm
leading to the use of other illegal drugs such as
narcotics and stimulants.
3.23 Drug Abuse Control
Measures for the regulation of designated drugs
Japan has become signatory to the following three (drugs with a high probability of such actions as
conventions: the Single Convention on Narcotic excitation of the central nervous system that present a

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Pharmaceutical Regulations in Japan:

risk to public health and hygiene) have been added to and used for healthcare in Japan. Whether or not a
the Pharmaceutical and Medical Device Act as substance under application is appropriate for human
countermeasures against “dangerous illegal drugs”. health care is objectively determined in light of state of
In particular, importing, manufacturing, marketing, the art medical and pharmaceutical technology.
giving and storing for selling, etc. of such designated Specifically, the Minister or prefectural governor
drugs with intended use other than healthcare have reviews the name, quality, dosage and administration,
been prohibited (MHLW Ordinance No. 14 dated indications, ADRs, etc. of the product in an application
February 28, 2007). On February 28, 2007, the submitted by a person with a marketing business
Guidelines on Monitoring of Import of Designated license. A GMP compliance review is performed to
Drugs were issued (Notification No. 0228009 of the assure that the plant manufacturing the product
PFSB, partially amended by Notification No, 0218-5 complies with the manufacturing control and quality
of the PSEHB dated February 18, 2016). On control standards. Marketing approval is granted to
February 20, 2013, MHLW Ordinance No. 19 was products meeting these standards. This approval
revised and issued to implement comprehensive system is the essential basis for ensuring good
control of controlled drugs/substances. quality, efficacy, and safety of drugs and related
In the Law for Partial Amendment of the products, which is the principal objective of the
Pharmaceutical Affairs Law enacted on April 1, 2014 Pharmaceutical and Medical Device Act.
(Law No. 103 dated December 13, 2013), new
provisions have been added for possessing, using, 4.2 Marketing Approval Reviews
purchasing and receiving such designated drugs. The entire process of approval review from
Furthermore, in the Law for Partial Amendment of review-related inspections and clinical trial
the Law enacted on December 17, 2014 (Law No. consultation to review works is undertaken by the
122 dated November 27, 2014), additional measures PMDA.
were established for prevention of public health risk Application forms for approval to market drugs are
caused by “dangerous illegal drugs”, i.e., the usually submitted to the PMDA. When application
inspection order and the sales-suspension order forms for new drugs are received by the PMDA, a
should apply more widely, goods subjected to the compliance review of the application data (certification
sales-suspension order must not be sold in a wide from source data), GCP on-site inspection, and
area, and advertisement should be restricted more detailed review are undertaken by review teams of
strictly. the PMDA and the team prepares a review report.
The approval review process consists of expert
4. MARKETING APPROVALS meetings of review team members and experts to
discuss important problems. A general review
4.1 Drug Marketing Approvals conference attended by team members, experts and
representatives of the applicant is held after the expert
Drug marketing approval refers to governmental
meeting.
permission for a drug with the quality, efficacy, and
safety or a drug that is manufactured by a method in The evaluation process followed by the PMDA is
compliance with manufacturing control and quality as follows (see the PMDA homepage). The applicant
control standards based on an appropriate quality and can confirm the status of review progress for each
safety management system, generally distributed, product applied for with the manager of the PMDA
review team (Notification No. 1227001 of the PMDA

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Pharmaceutical Regulations in Japan:

dated December 27, 2010, Notification No. 1003001 Diseases prior to approval, as necessary.
of the PMDA dated October 3, 2016). When active ingredients, dosage, administration
http://www.pmda.go.jp/review-services/drug-revi route, and indications are the same as those of
ews/0001.html approved drugs (so-called “generic drugs”), a review
(1) Interview (presentation, inquiries, and by the PMDA is undertaken after reviews on drug
replies) equivalence and compliance, and approval is
granted.
(2) Team review
A basic notification concerning drug approval
(3) Inquiries and replies
reviews was issued on April 8, 1999 and came into
(4) Application for GMP inspection (about 6
force for approval reviews of drugs from April 1, 2000.
months before the meeting of the
Later, following repeated revisions and with the
Committee on Drugs)
enactment of the Pharmaceutical and Medical Device
(5) Review report (1) Act, “On Drug Approval Applications” (PFSB
(6) Expert meeting (includes at least three Notification No. 1121-(2) dated November 21, 2014)
clinical specialists as experts) was issued. The current categories are as follows:
(7) General review conference (main agenda (1) Drugs containing new active ingredients
items and names of participating experts (2) New prescription combination drugs
made available 2 weeks prior to meeting;
(3) Drugs with new routes of administration
presentation) (very uncommon)
(4) Drugs with new indications
(8) Follow-up expert meeting
(5) Prescription drugs with new dosage forms
(9) Review report (2)
(6) Drugs with new dosages
(10) Report to the Evaluation and Licensing
(7) Biosimilar Products
Division, PFSB
The PAFSC is then consulted for discussions by (8) Prescription drugs with additional dosage
the related committees and the Pharmaceutical forms
Affairs Committee as required on the basis of the (9) Prescription combination drugs with similar
review report. After the report of the PAFSC report is formulations
obtained and it is confirmed that the standards are (10) Other prescription drugs
met in a separate GMP compliance review, the With the agreement reached on the common
Minister grants the new drug technical document (CTD) guidelines of the
manufacturing/marketing approval (Fig. 5 Flowchart International Conference on Harmonization (ICH),
of Approval Review). “Information Concerning New new guidelines for preparation of approval application
Drug Approval” prepared from the review data is data were issued (Notification No. 899 of the
placed on the homepage of the PMDA so that Evaluation and Licensing Division, PMSB dated June
accurate information concerning the quality, efficacy, 21, 2001). Applications using the CTD became
and safety obtained during the approval review obligatory for new products in applications filed on or
process is supplied to medical institutions, etc. after July 1, 2003.
In reviews of new drugs prepared from vaccine or These guidelines consist of five parts: Module 1
blood, the specifications and test methods are (Regulatory Information Such as Application Forms
examined on site by the National Institute of Infectious and Information Concerning Attached

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Pharmaceutical Regulations in Japan:

Documentation), Module 2 (Data Summary), Module Japanese HP:


3 (Data on Quality), Module 4 (Nonclinical Study http://www.pmda.go.jp/review-services/outline/0002.h
Reports), and Module 5 (Clinical Study Reports). tml
Modules 2 to 5 should be prepared on the basis of the
English HP:
CTD guidelines. Part 1 consists of documents
http://www.pmda.go.jp/english/review-services/review
requested by each regulatory authority. Detailed
s/0001.html
standards are shown in the Appendix (organization
and format) of the CTD guidelines.
4.3 Manufacturing/Marketing Approval
For the generic products, their application will
Application with Electronic Data
require submission of CTD, in principle, from March 1,
2017 (the conventional format will be accepted by The specifications of the electronic CTD (eCTD)
February 28, 2018) (Notification No. 0311-3 of the have been published for electronic application
Evaluation and Licensing Division, PSEHB dated documents submitted since April 1, 2005.
March 11, 2016). (Notification Nos. 0527004, 0825001, and 0707-(3)
Regarding the total review time for new drugs, it [partial amendment] of the Evaluation and Licensing
was decided to raise the percentile of the standard Division, PFSB dated May 27, 2004, August 25,
total review time in stages starting from FY2014, 2008, and July 7, 2009, respectively).
aiming to reach a review time of 9 months for priority For products for which marketing application will be
review products and 12 months for ordinary review made since October 1, 2016, clinical trial data should
th
products at 80 percentile by FY2018. In view of this, be submitted in accordance with the specifications in
“On the Handling of Approval Applications for the Clinical Data Interchange Standards Consortium
Improvement of the Predictability, etc. of New Drug (the CDISC standards), so that PMDA itself may
Approvals and Approach to Total Review Time” proceed with analyses or investigation with clinical
Notification No. 1006-(1) of PFSB and Notification No. data, etc. and establishment of more reasonable and
1006-(1) of Compliance and Narcotics Division dated efficient evaluation and assessment process in review
October 6, 2014” was issued, setting out the policy of and consultation. When clinical study data are
conducting preliminary interviews for planned reviews submitted as electronic data at the time of application
and indicating procedures, etc. for contacting for approval, a consultation with PMDA should be
applicants in case of difficult approval reviews, with a held in advance to check submission of the electronic
view to improving the predictability of reviews and the data for application. The consultation will cover the
transparency of the review process. A timeline for the contents of the electronic data to be submitted
standard process of new drug approval reviews was (including the specification, etc., definition file, and the
also indicated (Administrative Notice of the Evaluation program for preparation of data set). As a rule, final
and Licensing Division dated January 30, 2015). On confirmation with PMDA regarding the scope of the
April 17, 2008, “Points to Consider for Reviewers electronic data to be submitted should be made in a
Related to New Drug Approval Review Work” was preliminary interview for planned reviews for approval
issued. This showed the basic conditions related to of a new drug (Attachment to Notification No.
new drug review activities in the PMDA and was 0427001 issued by Office of Next Generation Review
intended to clarify the main points to consider in System, PMDA dated April 27, 2015).
reviews and to assure uniform awareness of PMDA In line with submission of electronic data of clinical
reviewers concerning review work. studies, application documents are required to be

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Pharmaceutical Regulations in Japan:

submitted in the form of eCTD. (Notification No. (B) Overall assessment of therapeutic
0620-(6) of the Evaluation and Licensing Division, usefulness
PFSB dated June 20, 2014) (i) There is no existing method of
Documents for manufacturing/marketing approval treatment, prophylaxis, or diagnosis.
application are to be submitted via gateway system, in (ii) Therapeutic usefulness with respect to
principle, to improve efficiency of information existing treatment
processing between the applicant and PMDA, share
a) Standpoint of efficacy
information between them, and manage progress of
b) Standpoint of safety
review-related paperwork. (the conventional
submission will be accepted by March 31, 2020) c) Standpoint of physical and mental
(Notification No. 0427-1 of the Evaluation and burden on the patient
Licensing Division, PFSB dated April 27, 2015) (2) Designation of drug products for priority
reviews
4.4 Priority Review System and Designation of When drugs are designated for priority reviews,
Drug Products for Priority Reviews opinions of experts on such designations are
compiled by the PMDA immediately after the
1) Priority review system
application and reported to the MHLW. Based on
Drug approval reviews are normally processed in
this report, the Evaluation and Licensing Division
the order that the application forms are received, but
decides whether or not to apply the priority review.
for drugs designated as orphan drugs, ones covered
The Evaluation and Licensing Division notifies this
by the SAKIGAKE Designation System and the other
decision to the applicant and the PMDA. The
ones considered to be especially important from a
Evaluation and Licensing Division reports this
medical standpoint such as new drugs to treat serious
application to the next meeting of the review
diseases, a decision must be made whether or not to
committee concerned of the PAFSC and obtains
specify an overall evaluation of (1) the seriousness of
their approval. Products for priority review are
the targeted disease and (2) the clinical usefulness,
given priority at each stage of the review process as
as stipulated in Article 14-(7) of the Pharmaceutical
much as possible. When products subject to
Affairs Law. With this system, applications for
priority review are approved as new drugs, this fact
specified drugs are reviewed on a priority basis
is made public.
(Notification No. 0122-(12) of the Evaluation and
Licensing Division, PSEHB / Notification No. 0122-(2) 2) Review of products designated for priority
of the Medical Device Evaluation Division entitled interview advice
“Handling of Priority Review” dated January 22, When products have been designated for priority
2016). interview advice at the development stage, it is
possible to obtain priority interview advice on
(1) Priority review criteria
indications and other items concerning the designated
(A) Seriousness of indicated diseases
product. Products are designated on the basis of an
(i) Diseases with important effects on overall evaluation of the seriousness of indicated
patient’s survival (fatal diseases) disease and clinical usefulness using the propriety
(ii) Progressive and irreversible diseases review selection criteria. Hearings and inquiries are
with marked effects on daily life undertaken for the applicant as required and the
(iii) Other designation is decided after hearing opinions of

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Pharmaceutical Regulations in Japan:

experts in the field. The results, including reasons, are 4.7 Drugs for Pediatric Use
notified to the applicant in writing. Orphan drugs and
Drugs used in pediatric clinics are often
ones covered by the SAKIGAKE Designation System
considered as “therapeutic orphans” throughout the
are all handled as products for priority interview
world because they are difficult to develop and are not
advice without the relevant application.
provided with sufficient information. This also
applies in Japan and very few drug products are
4.5 Restrictive Approval System indicated for pediatric use. The number of clinical
The drugs to which this system applies are those trials performed in children is not sufficient, the
used in emergencies to prevent the spread of number of products that can be used for children is
diseases that might have a major effect on the public insufficient, and information contained in package
health. It also applies to drugs for diseases for which insert (dosage, efficacy, safety, etc.) in relation to
the drug concerned is the only method of treatment applications in children is also insufficient. Therefore,
and which are marketed overseas. Such products “off-label use” of drugs basically intended for adults,
may be granted a restrictive approval by the Minister use of in-hospital products without adequately verified
without going through ordinary approval review stability, and use of drugs for pediatric use obtained
procedures after hearing the opinion of the PAFSC by individual import are common.
(Article 14-3 of the law). At present, laws and regulations aimed at drug
development and direct promotion of information
4.6 Orphan Drugs dissemination in the pediatric field such as those in
the EU and United States do not exist in Japan.
Policies to promote research and development on
When clinical trials are planned for dose setting, etc.
orphan drugs were adopted in 1993, and a notification
in children during approval applications or after
was issued by the MHW concerning designation
approval of drugs intended for use in children to
criteria and measures to promote research. The
collect information on experience of use in pediatric
criteria for designation include less than 50,000
populations, the reexamination period can be now
patients (except for intractable diseases specified by
extended for a set period not exceeding 10 years in
the national agency) indicated for the drug concerned
consideration of the results of special drug use-results
and excellent usefulness of the drug from the medical
surveys or post-marketing clinical studies during the
standpoint. The designation is conducted after
reexamination period (Notification No. 1324 of the
deliberation by PAFSC.
PMSB dated December 27, 2000).
Drugs designated as orphan drugs are entitled to
Guidance on Clinical studies on Drugs in Pediatric
certain priority measures such as financial aid, tax
Populations was issued as a guideline for
relief on research expenses, guidance and advice,
implementation of clinical studies in the pediatric
priority review, and extension of the reexamination
population (Notification No. 1334 of the Evaluation
period from the conventional 8 years to a maximum of
and Licensing Division, PMSB dated December 15,
10 years for drugs.
2000). PMDA consultations include those on clinical
A list of specified intractable diseases is available
development of drug in pediatric populations and
on the homepage of MHLW.
development of pediatric formulations.
http://www.mhlw.go.jp/stf/seisakunitsuite/bunya/000 A supplement was issued to supplement the
0084783.html contents of the guidance, and to propose a new way
of thinking necessary for development of pediatric

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Pharmaceutical Regulations in Japan:

drugs (Notification No. 1227-5 of the Evaluation and 4.8 Unapproved Drugs and Drugs of Off-label
Licensing Division, PSEHB dated December 27, Use
2017).
In May 2010, “a List of Drugs for Which
Requests for the addition of indications by related Developing Companies are Being Recruited or
academic societies can be handled by an application Requests for Development Made” was issued based
for partial changes in approved items such as on the results of discussions by the Special
indications or dosage/administration on the basis of Committee on Unapproved Drugs and Drugs of
clinical studies or clinical results in accordance with Off-label Use Urgently Required for Healthcare. As
notifications (No. 4 of the Research and Development a result of the first recruitment, the development
Division, Health Policy Bureau and No. 104 of the request was issued for 165 items, and the clinical
Evaluation and Licensing Division, PMSB dated development of 20 unapproved items or those of
February 1, 1999), when the necessity of additional off-label use requested for development was started.
indications in healthcare are confirmed and requests In the second recruitment, the development request
to study are made by the Research and Development was issued for 88 items, and the clinical development
Division of the Health Policy Bureau. This can also of 15 unapproved items or those off-label use was
be applied to drugs intended for use in the pediatric started in sequence one after the other. In the third
field. In these notifications, it states that whole or part recruitment, the development request was issued for
of the clinical studies do not have to be performed 45 items, and developing companies were recruited
again and when the indications related to off-label use for the 454 items. In the fourth recruitment, the
are public knowledge in medicine or pharmacology, development request was issued for 7 items, and
this can be applied to judgments on whether or not to developing companies were recruited for 2 items (the
approve indications. latest version of the drug list is available at the
The Special Committee on Unapproved Drugs following site). The fourth recruitment of requests for
was founded in December 2004 to study drugs not unapproved or off-label use drugs was started in July
approved in Japan for which efficacy was established 2015, and requests have been received as needed.
and approvals granted in the West and perform Recruitment is still ongoing. From July 2015 and
periodic surveys and scientific evaluations of requests onward, not only development requests for
of academic societies and patients. Separately, in unapproved drugs in Japan but also those for
March 2006, the Special Committee on Pediatric unapproved drugs overseas are discussed.
Drug Treatment was established to collect and Development of unapproved drugs and those of
evaluate evidence on the efficacy and safety of off-label use in requests is discussed within the
unapproved pediatric drugs. Thereafter, both special Scheme for prompt practical use of unapproved
committees were developmentally reorganized into a drugs under the Packaging Strategy for World-first
new “Special Committee to Investigate Unapproved Products (Strategy of Sakigake). (Notification No.
Drugs and Off-Label Use of Drugs Urgently Required 0701-2 of the Evaluation and Licensing Division,
for Healthcare” in February 2010. The committee PFSB and Notification No. 0701-2 of the Research
started wide-ranging discussions on off-label drugs and Development Division, HPB both dated July 1,
including unapproved drugs and pediatric drugs. 2015)
Contents of previous discussion meetings are
available on homepage of the MHLW.
http://www.mhlw.go.jp/stf/shingi/other-iyaku.html?tid=

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Pharmaceutical Regulations in Japan:

128701 PFSB dated April 1, 2015)


In August 2010, a new approach has started to For designation, a drug has to meet all of the
make unapproved drugs and drugs of off-label use following 4 requirements.
available for use in clinical practice: the cost of drugs (1) Designation requirement 1: innovativeness of
with unapproved indications, etc. can be reimbursed the therapeutic drug
by the national health insurance system even prior to In principle, the following drugs are
the official approval of such unapproved indications, applicable: a drug has to have a mechanism
etc., provided that the Review Conference on of action different from that of any approved
Unapproved or Off-label Use Drugs of High drug; a drug that has the same mechanism of
Therapeutic Needs has approved the rationale for the action as that of approved drug, but is
public knowledge-based application of the drug use developed to have different indications; and a
and the Pharmaceutical Affairs and Food Sanitation drug that is to use an innovative drug delivery
Council has accepted the public knowledge-based system.
application.
(2) Designation requirement 2: Seriousness of
the disease targeted by the drug
4.9 Packaging Strategy for World-first The drug has to be indicated for any of the
Products following diseases.
The “Strategy of Sakigake” for leading the world in - Life-threatening serious diseases
the practical application of innovative medical - Diseases presenting persistent symptoms
products was drawn up. The strategy covers (in a state hard to maintain social life) and
everything from basic research to clinical without radical treatment
research/trials, approval reviews, insurance coverage,
(3) Designation requirement 3: Considerably
and global expansion. It includes, as measures
high efficacy on the target disease
relating to the approval review process, the “Review
The drug has to have no competing
system for designated world-first products” and the
approved drugs, or has to have the efficacy
“Scheme for prompt practical use of unapproved
expected to be considerably higher than that
drugs”.
of conventional therapeutic drugs /therapies
1) Review system for designated world-first (or expected to have the considerably
products improved safety)
This strategy is intended to designate drugs (4) Designation requirement 4: Intention /system
expected to be highly effective against life-threatening of world’s leading early development and
serious diseases by mechanism of action different
application in Japan
from that of approved drugs in principle. The PMDA The drug has to be planned to be applied for
will assign a review coordinator as a concierge to approval in Japan before anywhere in the
strengthen cooperative relationship among relevant
world (or applied concurrently in multiple
divisions of the MHLW and PMDA and to manage the regions including Japan) with great
progress to accelerate the development. In addition, importance attached to the development
to reduce the review period to 6 months, consultation
initiated in Japan, and the drug has to have
scheme to be newly established and prioritized review the appropriate system for application for
system will be preferentially applied. (Notification No. approval. Drugs of which steadily advanced
0401-6 of the Evaluation and Licensing Division,

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Pharmaceutical Regulations in Japan:

development in Japan can be demonstrated development, the scheme will encourage clinical
are desirable. That is, therapeutic drugs research central hospitals and National Centers to
applicable to both of the following conditions conduct investigator-initiated clinical trials or provide
are desirable. advanced medical care, and thereby to obtain data
- Drugs of which a First In Human (FIH) potentially used in drug approval application actively.
study has been conducted in Japan. As described the above, the scheme will support the
research and development intensively to ensure the
- Drugs of which a Proof Of Concept (POC)
environment in which companies can readily initiate
study has been conducted in Japan.
the development. (Notification No. 0701-(2) of the
When an application is to be filed for a drug Evaluation and Licensing Division, PFSB and
which needs to be used together with Notification No. 0701-(2) of the Research and
companion diagnostics, etc., there should be Development Division, HPB entitled "Expansion of the
a system for concurrently filing an application Targets of Demand among Unapproved Drugs and
for approval of the diagnostic drug (including Drugs Off-label Use Urgently Required for Healthcare
cooperation with other companies). dated July 1, 2015)
A list of the products subject to this system is
available on the homepage of PMDA. 4.10 Regulatory Science Strategy Consultations
http://www.pmda.go.jp/review-services/drug-r for Regenerative Medicine Products (former
eviews/0003.html Regulatory Strategy Consultations)
2) Scheme for prompt practical use of It is specified in the notifications that safety- and
unapproved drugs quality-related issues on drugs, etc. processed from
The extent of products considered for review from cells and tissues as well as drugs for gene therapy
the Special Committee on Unapproved Drugs and are to be discussed with PMDA through regulatory
Drugs Off-label Use Urgently Required for Healthcare science strategy consulting from the early stage of
has been expanded to include drugs with high research and development (Notification of No.
medical needs that are unapproved in the West 0630-(2) of PFSB entitled “Modifications of Handing of
provided they are drugs for serious or life-threatening Medicinal Products and Medical Devices Utilizing
diseases that satisfy any of the requirements set out Cells and Tissues to Comply with Implementation of
in 1. to 3. below; 1. a Phase III clinical trial in Japan Regulatory Strategy Consultation” dated June 30,
initiated by a medical investigator is ongoing or has 2011 and Notification of No. 0701-(13) of PFSB
been completed, 2. excellent study outcome has entitled “Abolition of the Verification Application
been published in literatures, etc. and 3. it is System for Products for Gene Therapy” dated July 1,
applicable to the advanced medical technology B with 2013). Procedures for requesting and holding a
certain experience, so that practical use of world-first regulatory science strategy consultation are available
therapeutic drugs may be realized. If there are in Notification No. 1101050 of PMDA entitled
companies involved in development of these drugs in “Guidelines for Regulatory Science Strategy
Japan, such companies would be requested to Consultations” dated November 1, 2017. For
proceed with the development and to conduct clinical regenerative medicine products, clinical trials should
trials. If there is a drug candidate developed by a be initiated after a regulatory science strategy
venture company outside of Japan, but it takes time to consultation for quality and safety with PMDA.
match with a company potentially involved in the

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Pharmaceutical Regulations in Japan:

4.11 Approval System Implemented to Promote system, surveys, etc. necessary for reconfirmation of
the Application of Regenerative Medicine the efficacy and safety become a condition for
Including Cellular and Tissue-Based approval. Medical information databases and
Products for Commercialization (Approval patient registries, etc. can be used for such surveys.
with Conditions and Time Limit) If it is appropriate to define the requirements for
Following enforcement of the Law for Partial institutions, etc. from the point of view of ensuring
Amendment of the Pharmaceutical Affairs Law (Law proper use of the drugs, they may be included in the
No. 84, November 27, 2013), a new approval system conditions for approval.
was introduced for regenerative medicine:
non-homogenous quality tissue-engineered medical 4.13 Guidelines for Promoting Optimal Use
products can be approved earlier than with the routine A drug with a new innovative mechanism of
approval system with conditions and time limit if they action may have obviously different pharmacological
are assumed to be effective and proven to be safe in actions or safety profiles as compared with existing
humans. The applicant is required to verify the drugs. Therefore, it is necessary to formulate the
efficacy and safety and resubmit the application within guidelines for promoting the optimal use for
seven years after the conditioned approval. innovative drugs with new mechanisms of action
from the point of view of promoting the optimal use
on the basis of the latest scientific findings at the
4.12 Conditional Accelerated Approval System same time with the reviews related to the approval
for Pharmaceuticals with the aim of presenting the requirements for the
For the drugs for treating serious diseases which patients and medical institutions, etc. that are to use
the drug as well as the points to consider.
occur in a small number of patients and for which
(Notification No. 0915(1) of Pharmaceutical
effective treatment methods are limited, a conditional
Evaluation Division, PSEHB, Notification No.
accelerated approval system was established in 0915(1) of Medical Economics Division, HIB entitled
which the results of confirmatory clinical trials are not "Handling of Guidelines for Promoting Optimal Use"
required, but the conduct of necessary post-marketing dated September 15, 2017).
surveys, etc. is required as a condition for approval. The drugs to be subjected to the guidelines must
(Notification No. 1020(1) of Pharmaceutical meet any of the following conditions from (i) to (iii).
Evaluation Division, PSEHB entitled "Implementation (i) The drugs that have a mechanism of action
of conditional accelerated approval system for different from that of existing drugs
pharmaceuticals" dated October 20, 2017). available for treatment of the disease
The drugs to be subjected to this system must (ii) The drugs that have the same mechanism
meet all of the following conditions from (i) to (iv). of action as a drug which has already been
subjected to the guidelines
(i) The drug is indicated for serious diseases.
(iii) The drugs that meet the condition (i) or (ii)
(ii) The medical usefulness is high. and have already been subjected to the
(iii) Confirmatory clinical trials are difficult to guidelines, and for which new indications
conduct. are added

(iv) The results of clinical trials, etc. other than Concerning the drugs falling under (i), eligibility
for the target drug will be judged globally considering
confirmatory clinical trials suggest some
the following points.
efficacy and safety.
For the approval of the drugs subjected to this

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Pharmaceutical Regulations in Japan:

 The pharmacological action differs was issued (Office Communication of the Evaluation
significantly from that of existing drugs. and Licensing Division, PFSB dated March 31, 2010).
 The safety profile differs significantly from
that of existing drugs, and special
4.15 Combination Products
precautions are required for the use.
 The efficacy is significantly higher than that A “combination product” is defined as a drug that
of existing drugs. was approved to be manufactured/marketed with
 The clinical positioning differs from that of other components including devices or equipments in
existing drugs, and the drug may be usable
an integrated fashion. It would be categorized as a
for a wider range of patients.
medical device, if distributed alone. Handling of
 It may be possible to increase the users
through development for other diseases combination products are specified in “Handling of
(addition of indications, etc.). Approval Application for Combination Products”
(Notification No. 1024-(2) of the Evaluation and
4.14 Biosimilar Products Licensing Division, PFSB, Notification No. 1024-(1) of
the Director of Medical Devices Evaluation,
For biological products, it is difficult to prove the
Evaluation and Licensing Division, PFSB, Notification
equivalence of active ingredients with those of
No. 1024-(9) of the Safety Division, PFSB, and
existing drugs unlike with chemically synthesized
Notification No. 1024-(15) of the Compliance and
drugs, but with the advances made in technology,
Narcotics Division, PFSB, dated October 24, 2014)
biosimilars (or follow-on biologics) have been
and has been applied since November 25, 2014.
developed in recent years as products with
Subsequently, it was revised by Notification No.
equivalence to and the same quality as existing
0915-(1) of the Pharmaceutical Evaluation Division,
biological products. WHO and major countries have
PSEHB / Notification No. 0915-(1) of the Medical
established new legal systems and specified
Device Evaluation Division, PSEHB / Notification No.
technological policies. In March 2009, policies for
0915-(3) of the Safety Division, PSEHB / Notification
the assurance of the quality, safety and efficacy of
No. 0915-(3) of the Compliance and Narcotics
biosimilar products (Notification No. 0304007 of PFSB
Division of PSEHB dated September 15, 2016, and
dated March 4, 2009) were formulated in Japan.
Notification No. 1122-(4) of the Pharmaceutical
"Biosimilar products" were established as a new
Evaluation Division, PSEHB / Notification No.
application category for prescription drugs
1122-(10) of the Medical Device Evaluation Division,
(Notification No. 0304004 of the Evaluation and
PSEHB / Notification No. 1122-(7) of the Safety
Licensing Division, PFSB dated March 4, 2009).
Division, PSEHB / Notification No. 1122-(4) of the
Documents on points to consider in approval
Compliance and Narcotics Division of PSEHB dated
applications (Notification No. 0304015 of the
November 22, 2016. After this revision, a medical
Evaluation and Licensing Division, PFSB dated
device which cannot be separated from the drug and
March 4, 2009) and handling of non-proprietary and
which is generally referred to as a container according
brand names (Notification Nos. 0304011 and
to the definition of the general term for the medical
0214-(1) of the Evaluation and Licensing Division,
device has come to be regarded as a container, and
PFSB dated March 4, 2009 and February 14, 2013,
is no longer regarded as a combination product.
respectively) were also issued. In March
However, the category of the "prefilling syringe,"
2010, ”Questions and answers on policies to verify
which used to be regarded as a container according
the quality, efficacy, and safety of biosimilar products”
to the definition of general terms of medical devices,

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Pharmaceutical Regulations in Japan:

was changed to an ordinary medical device. data. Requirements for data submitted for approval
Therefore, a "prefilled syringe product" will applications have been simplified.
continuously be handled as a combination product.
Though a combination product is deemed a drug, 4.17 Transfer of Marketing Approvals
when the device or equipment constituting the Marketing approvals can be transferred to legally
product caused a defect, the authorized marketing authorization holders through
manufacturing/marketing authorization holder of the succession, merger, contracts, etc. provided that all
combination product should report the defect in data and related information are transferred from the
accordance with the defect reporting of medical original approval holders.
devices. Handling of defect reporting is specified in
Transfer of marketing approvals of products that
“Reporting of Adverse Drug Reactions to Drugs, etc.”
have been marketed only for shorter than 1 year
(Notification No. 1002-(20) of the PFSB, October 2,
since the approval is not accepted except for that due
2014).
to business merger. For transfer in association with
disposition of the business unit, however, whether or
4.16 Codevelopment
not it is acceptable will be judged as an evaluation
The objective of codevelopment is to reduce the result of the individual content, if the specified
risk of development of new drugs and to promote requirements are met. Consultation with the
more efficient development. Codevelopment regulatory authority to which the notification is to be
regulations, including requirements for composition of submitted should be done in advance to obtain the
the codevelopment group and requirements for those acceptance (Office Communication from the
preparing the data, had been specified in the past, but Evaluation and Licensing Division / Compliance and
codevelopment was deregulated by the basic Narcotics Division dated March 29, 2016).
guidelines for drug approval applications issued on
April 8, 1999. 4.18 Approval Applications for Drugs
The main points of this deregulation included Manufactured Overseas
cancellation of the requirement that the group had to Pharmaceutical manufacturers outside Japan can
include members with previous experience in apply directly under their own name for marketing
receiving a new drug approval. Among the approval if they perform the studies regarding quality,
requirements for those preparing the data, it was efficacy, and safety required for the drugs they intend
previously required that when the codevelopment to export to Japan and undertake the necessary
group performed a clinical trial, group members had procedures (Fig. 6 Procedure for manufacturing and
to be joint sponsors of the trial, but currently other marketing approval of drugs for overseas
members in the group can use data in applications manufacturers in Japan). In such cases, the
from clinical trials performed by any member of the overseas manufacturer appoints a marketing
group. authorization holder in Japan among those that have
If clinical trials performed by other companies in received a marketing business license of the type
the group meet certain requirements, data prepared corresponding to approved product. The appointed
by persons other than the applicant can be accepted marketing authorization holder takes measures
as approval application data and reviews of required to prevent the onset of health and
applications submitted by several members of the hygiene-related hazards caused by the approved
codevelopment group can apply the same application

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Pharmaceutical Regulations in Japan:

drug in Japan and can also undertake manufacturing In October 2013, the issue of GMP certificate
and marketing in Japan. based on the mutual recognition system for drug
GMP (MRA) with the EU countries was terminated
4.19 Issuing of Certificates for Exported Drugs and replaced with product registration in the
by MHLW EudraGMDP database that was provided by the
European Medicines Agency (EMA). The countries
Upon request, the MHLW issues a certificate
to which the certification system is applied are
indicating to the effect that a drug, quasi drug, or
required to be those with which the mutual
medical device to be exported has been
agreements for GMP were exchanged with Japan.
manufactured in compliance with provisions of the
In April 2016, Japan-Europe certification system
Pharmaceutical and Medical Device Act in the format
became applicable to all the EU countries (Notification
designated by the destination country requesting the
No. 0426-3 of the Compliance and Narcotics Division
certificate.
of PSEHB dated April 26, 2016). The product items
Currently, the MHLW issues the following that are subject to this certification system do not
certificates upon request: business licenses for include biological products, bulk drugs, or sterile
marketing and manufacturing of drugs, etc., products. The contents to be certified are prepared
marketing approvals for drugs, etc., attached and registered by the PMDA in the EudraGMDP
documentation for new drug marketing applications, database based on information submitted by the
GLP compliance for drugs, notifications of clinical trial manufacturer. Registered information is publicly
for investigational products, certifications of accessible in the database, as a rule (Notification No.
pharmaceutical formulations based on the WHO 0628-(4) of the Compliance and Narcotics Division,
certification system, statements of approval and PFSB dated June 28, 2013).
licensing status of pharmaceutical products, and
GMP compliance for drugs, and GMP compliance for
investigational drugs. (Table 2 Divisions of the 5. JAPANESE PHARMACOPOEIA AND
Pharmaceutical and Food Safety Bureau in Charge of OTHER STANDARDS
Certification Work). Export certificates on drugs, 5.1 Japanese Pharmacopoeia (JP)
quasi-drugs, etc, are issued using the specified format
The Japanese Pharmacopoeia (JP) was
via the PMDA. The notification of export
established and published to regulate the properties
certifications requires the applicant of certification to
and qualities of drugs by the MHLW based on the
inquire the Ministry of availability of certification in
provisions of Article 41, Paragraph 1 of the Law after
advance, if the form of certificate designated by the
hearing opinion of the Pharmaceutical Affairs and
requesting country is different from that specified in
Food Sanitation Council (PAFSC). The JP is a book
the notification (Notification No. 1125-(12) of the
of drug standards specified and published by the
PFSB dated November 25, 2014, Partial revision of
Ministry.
Notification No. 1011-(1) of the PSEHB dated
October 1, 2015). Since it was first published in June 1886, the JP
has been revised several times. The
The certificates are also issued, when final
Pharmaceutical and Medical Device Act specifies that
products manufactured in an oversea plant are
the JP must be subjected to a complete revision at
exported to a third country (Notification No. 0604-(3)
least once every 10 years, and such revisions have
of the Evaluation and Licensing Division, PFSB dated
actually appeared every 5 years since the 9th revision
June 4, 2014).

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Pharmaceutical Regulations in Japan:

in April 1976. In addition, the JP has been partially disseminates information on drug product quality to
revised before the complete revision even 5 years the public, and fulfills accountability on the reliability of
since the 11th Edition. drug products.
Japanese HP: In addition, the JP is requested to undertake the
http://www.pmda.go.jp/rs-std-jp/standards-developme role of and achieve an expected level of contribution
nt/jp/0001.html to the maintenance and assurance of global
harmonization on drug product quality among
English HP:
advanced countries as a code book of medicinal
http://www.pmda.go.jp/english/rs-sb-std/standards-de
product quality in the international community.
velopment/jp/0009.html
The PAFSC held a meeting of its Subcommittee (2) Five major policies of 17th Edition of
on the Japanese Pharmacopoeia to cope with recent Japanese Pharmacopoeia
progress in the medical and pharmaceutical sciences 1) Complete entries of all drugs important in
and the requests from ICH in November 2001. The healthcare
basic compilation policies that include the 2) Improvement of quality by introduction of
characteristics and role of the JP, the actual the latest scholarship and technology
measures taken for the 15th edition to achieve the 3) Promotion of internationalization
basic policies, date of enforcement, and items related
4) Prompt partial revisions as required and
to the organization of the Committee on the Japanese
smooth application based on government
Pharmacopoeia were formulated. Content regulations
policies.
including clarification of significance and specifications
5) Assurance of transparency in the revision
of contents were examined and the JP basic content
process of the JP and widespread
regulations were published in a report of the PAFSC
application of the JP.
entitled “Future Approaches to the Japanese
Pharmacopoeia” in December 2002. The 16th (3) Policies for entry
edition of the JP was enforced in March 2011, and New drugs that are prioritized to be entered in the
then the basic compilation policies of the 17th edition JP are those expected to be in wide medical use,
were announced as shown below in September 2011 those expected to have high medical needs,
(Office Communication dated September 13, 2011). “first-in-class” drugs approved by priority review, those
with no alternative drugs available, and those already
(1) Role and characteristics of the JP
entered in the USP and EP and are globally in wide
The JP is an official compendium of standards,
use. Approved drugs which are important from the
specifications, and test methods in Japan necessary
point of view of insurance and the drugs approved as
for assuring the quality of drugs in accordance with
generic drugs are examined for entry as soon as
the scientific and technological progress and medical
possible. New drugs to be approved in the future will
demand at the time.
be entered after a certain period has passed after
The JP is compiled by utilizing the knowledge and
approval. For example, entry of such drugs will be
experience of many pharmaceutical professionals. It
considered as soon as it becomes possible to collect
is a book of standards that can be utilized widely by
a certain amount of information about quality, safety
people in the field.
and efficacy.
Further, the JP is a public book that requires the
• Date of enforcement
assurance of transparency in the revision process,

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Pharmaceutical Regulations in Japan:

The 17th edition of the JP was announced in concerning the methods of manufacture, properties,
Notice No. 64 of the MHLW dated March 7, 2016 quality, storage methods, etc. based on Article 42 of
and applied from April 1, 2016. The First the Law. The following standards exist at present:
Supplement was announced in Notice No. 348 of  Radiopharmaceutical Standards
the MHLW dated December 1, 2017, and applied
 Minimum Requirements for Biological Products
on the day.
 Minimum Requirements for Blood Grouping
• The compilation review organization for Antibodies
the JP  Standards for Biological Materials
Revisions of the JP had been initiated by the
 Standards for in vitro Diagnostics
Councils of the MHLW, but at present, the draft is
prepared by the PMDA’s JP Expert Committees
5.3 Standards for Biological Materials
and is approved by the MHLW’s Committee on
JP. The JP Expert Committees are headed by The Standards for Biological Materials were
the Expert Committee and include Committee on specified in Notice No. 210 issued by the MHLW in
Chemicals, Committee on Biologicals, etc. for a 2003 for quality and safety assurance of raw materials
review of draft text. The committees may and packaging materials manufactured from
organize working groups to discuss and make biological materials and used in the manufacturing
recommendations on specific issues, as needed. process for drugs, quasi-drugs, cosmetics, and
The technical research committees of the medical devices based on the provisions of Article 42,
Osaka Pharmaceutical Manufacturers Association Paragraph 1 (Standards of Drugs, etc.) of the Law.
and Pharmaceutical Manufacturers Association of These standards including interim measures came
Tokyo, and many other organizations every time into effect from July 30, 2003. They consist of
cooperate in preparation of new versions of the General Notices, General Rules for Blood Products,
JP. General Rules for Human-derived Biological
Products, and General Rules for Animal-Derived
The draft JP monograph of a candidate item to
Biological Products. The Standards for Cell and
be listed in the JP is first developed by the
Tissue-Derived Drugs and Medical Devices were
applicant on the basis of the guidelines for
abolished on July 29, 2003. With the specification of
preparation of the JP draft. The draft is reviewed
the Standards for Biological Materials, the Minimum
by the JP Draft Committee and then, after
Requirements for Biological Products were partially
collecting public comments, by the Committee on
revised by MHLW Notice No. 211 in 2003 and the
JP. After the review and approval by the
General Rules for Blood Products were abolished by
Committee on JP, public comments are collected
the Minimum Requirements for Biological Products.
again and then listed in the JP (Fig. 7 Flowchart of
Notice No. 262 issued by the MHLW on July 5,
Drug Listing in Japanese Pharmacopoeia).
2004 states that the standards for raw materials of
biological origin have been partially revised as
5.2 Standards Based on Article 42 of the
indicated below. These revisions, including interim
Pharmaceutical Affairs Law
measures, came into effect on the day of notification.
For drugs that require special precautions with
• Standards for raw materials of ruminant origin
respect to public health and sanitation, several
(1) The spine, skull, trigeminal ganglion, and
necessary standards have been established
dorsal root ganglion of ruminants have

2018 - 45 -
Pharmaceutical Regulations in Japan:

been added to the list of materials scientific knowledge and information (Notice No. 375
prohibited for use as raw materials in issued by MHLW of 2014. Gelatin (including
drugs, medical devices, quasi-drugs, and collagen) derived from wool, milk, bone and skin was
cosmetics (hereafter drugs, medical classified as “low-risk raw materials,” and the scope of
devices, etc.). countries of origin excepted from the restriction was
(2) In conjunction with the confirmation of a expanded. Previously, fatty acids, glycerin, fatty acid
cow infected with BSE in the United States esters, amino acids, synthetic oligopeptides and
in December 2003, the United States was materials processed by heat and alkali treatment
removed from the list of countries of origin were excluded from the scope of the Standards for
of raw materials originating from cows and raw materials of ruminant origin. In addition, with this
other ruminants that can be used as raw notice, materials processed by appropriate treatment
materials for drugs, medical devices, etc. are to be excluded, such as those that have been
assessed to ensure the safety of the final products on
(3) Gelatin and collagen used in drugs,
the basis of clearance data of prion potentially present
medical devices, etc., which are
in raw materials.
manufactured from raw materials derived
from skin, have been removed from the list
of regulated items from countries of origin 5.4 Quality Standards Based on Notifications
with confirmed cases of BSE. In addition to quality standards specified on the
Based on Notice No. 310 of the MHLW dated basis of laws and ordinances, the quality
September 28, 2007, Chile was removed from the list specifications have also been published as listed
of countries of origin of raw materials originating from below based on notifications for administrative
cows and other ruminants. Based on Notice No. guidance.
343 of the MHLW dated July 1, 2009, the use of raw  Japan Pharmaceutical Codex
materials of ruminant origin with Canada as the  Japan Crude Drug Codex
country of origin was approved to be used within the
 Insecticide Standards
same range as that of materials from the United
States as the country of origin.  Standards for Raw Materials for in vitro Diagnostics

Regulatory handling in application review of raw  Japan Pharmaceutical Excipient Standards


materials used in the preparation of master cell banks  Japan Standards of Quasi-drug Ingredients
or master seed banks that do not comply with the
specifications in the standards for raw materials of 5.5 Government Batch Test
biological origin are specified in Office
Government supervision and certification based
Communication of the Evaluation and Licensing
on batch tests are specified for drugs that require
Division dated March 27, 2009.
advanced and sophisticated manufacturing
In line with the revised Pharmaceutical Affairs Law
technology or testing methods. Such drugs are
enacted on November 25, 2014 (Law No. 84 of
tested in order to assure their quality in institutions
2013), the Standards for Biological Materials were
designated by the MHLW, and the drugs cannot be
partially revised as for the standards for human- or
sold or otherwise marketed unless they pass these
animal-derived materials to be used in drugs, medical
tests (Article 43 of the Law).
devices or regenerative medicine products, etc.
based on reviews of such materials with latest At present, a part of biological products is subject

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Pharmaceutical Regulations in Japan:

to such testing. The designated testing institution is Article 228-22 of the Regulation.)
the National Institute of Infectious Diseases. Such products should be recalled as having a
concern in safety or efficacy due to a failure or as
6. PHARMACEUTICAL SUPERVISION violating the Pharmaceutical and Medical Device Act
or approved condition, and all recall information is
6.1 Pharmaceutical Supervision published on the PMDA homepage by class as
Based on the provisions of the Pharmaceuticals below. Also depending on the class of the drug and
and Medical Devices Act, the Minister of the MHLW, whether or not it is exported overseas, a Rapid Alert
prefectural governors, or other may appoint Notification of Quality Defect/Recall should be issued
"pharmaceutical inspectors" in connection with the to PIC/S member countries and the EU.
rationalization of pharmaceutical manufacture, import, Class I: Serious health damage or death may be
labeling, advertisements or marketing. This caused by use of the product.
pharmaceutical inspection system covers falsely Class II: Transient or medically-curable health
labeled drugs, drugs of poor quality, drugs that have damage may be caused by use of the
not been approved or licensed, and false or product, or serious health damage may
exaggerated advertising. Pharmaceutical inspectors not be caused by use of the product.
perform on-site inspections as needed, and when
Class III: Health damage may not be caused by
violations are discovered, the inspectors may issue
use of the product.
various orders including administrative measures.
The main measures are as follows: (Notification No. 1121-(10) of the PFSB dated
November 21, 2014, partially revised by Notification
 Revocation of approval or change orders in
No. 0208-(1) of the PSEHB dated February 8, 2018)
approved items
 Revocation of licenses or business suspension
6.3 Prevention of Medical Accidents Caused
orders
by Drugs, etc.
 Temporary suspension of sales and disposal of
A notification was issued to eliminate mistakes in
drugs, etc.
the use of drugs, etc., in connection with the name,
 Recall orders
container, specifications, etc. in order to prevent
 Improvement orders in cases where the buildings medication accidents (Notification No. 935 of the
and equipment, etc. do not comply with regulatory PMSB dated September 19, 2000). More active
requirements participation of related companies was requested in
Notifications No. 1127003 of the PFSB dated
6.2 Product Recalls November 27, 2003 and No. 0602009 of the PFSB
A manufacturing/marketing authorization holder of dated June 2, 2004. For the brand names of new
drugs or medical devices, etc. or a manufacturing drugs, guidance on the use of a flowchart to avoid use
authorization holder of drugs or medical devices to be of similar names for newly approved drugs applied in
exported, intending to recall its the Japan Pharmaceutical Information Center
manufactured/marketed or manufactured products (JAPIC) is given in an Office Communication dated
should report to the effect that it initiated recall, recall October 17, 2005. General principles for brand
status, and to the effect that it has completed recall to names of generic drugs are given in Notification No.
the prefectural governor. (Article 68-11 of the Law and 0922001 of the Evaluation and Licensing Division,

2018 - 47 -
Pharmaceutical Regulations in Japan:

PFSB dated September 22, 2005. Attached Table 2 of the Notification No. 1069 of the
For new replacement approval applications for PMSB of 2001.
changes in brand names as a measure to prevent Following the confirmation of a cow infected with
accidents, the application fees were revised from April BSE in the United States in December 2003, the
2005. Entry of approved products in the NHI Price PFSB issued Notification No. 0218004 dated
List has been increased from once a year to twice a February 18, 2004 entitled “Quality and Safety
year. An environment conducive to brand name Assurance Related to Drugs, medical devices, etc.,
changes to prevent medical accidents has been manufactured using bovine and other
achieved. ruminant-derived products and bovine and other
ruminant-derived spinal products from the United
6.4 Safety Measures against Bovine States” and Notification No. 0218001 of the
Spongiform Encephalitis (BSE) Evaluation and Licensing Division, PFSB and
Notification No. 0218003 jointly issued by the
Bovine spongiform encephalitis (BSE) frequently
Evaluation and Licensing Division and the Safety
occurred in England in the latter half of the 1980s and
Division, PFSB dated February 18, 2004 entitled
there were also cases reported in EU member
“Handling of Approvals with Respect to Quality and
countries. Pharmaceutical companies have been
Safety Assurance Related to Drugs, Medical Devices,
requested to undertake voluntary inspections and
etc., Manufactured Using Bovine and Other
make adjustments in approval documentation
Ruminant-Derived Products and Bovine and Other
(Notification No. 1226 of the PMSB dated December
Ruminant-Derived Spinal Products from the United
12, 2000) in view of the need to ensure quality of and
States”. Notification No. 0705001 of the PFSB dated
to take safety measures for pharmaceutical products
July 5, 2004 entitled “Handling of Approval
manufactured using raw materials of bovine origin.
Applications Concerning Quality and Safety
Companies have been requested to respond Assurance of Drugs and Medical Devices
positively to an additional notification (No. 1069 of the Manufactured Using Bovine and Other
PMSB dated October 2, 2001) to secure high quality Ruminant-Derived Products and Bovine and Other
and safety of pharmaceutical products using raw Ruminant-Derived Spinal Products from the United
materials of bovine origin because of the first report of States Associated with the Partial Revision of the
BSE infection in Japan on September 21, 2001. Standards for Biological Materials” was issued.
As a preventive measure in keeping with The Standards for Biological Materials were
international trends to enhance safety measures for specified in Notice No. 210 issued by the MHLW in
drugs and medical devices using bovine-derived raw 2003 and specifications for raw materials and
materials, Notification No. 0414004 of the PMSB packaging materials used in the manufacture of
dated April 14, 2003 concerning bovine-derived raw biological products or raw materials and packaging
materials was issued to require precautions related to materials manufactured from biological materials and
the site of use and other factors, handling of blood used in the manufacturing process for drugs,
products, handling of products derived from human quasi-drugs, cosmetics and medical devices based
urine and handling of approvals. Based on on the Law were designated.
Notification No. 0522002 of the PMSB of 2003,
It has been considered necessary to adopt quality
“Canada” was added to countries in which BSE
and safety assurance measures based on current
occurred in Attached Table 1 and “Canada” was
scientific levels for drugs manufactured using raw
removed from countries of low risk for BSE in

2018 - 48 -
Pharmaceutical Regulations in Japan:

materials of human or animal origin. Companies The Standards for Biological Materials were
have been requested to undertake voluntary partially revised by Notice No. 375 of the MHLW in
inspections and make adjustments in approval September 2014, the countries which were evaluated
documentation. as having negligible risks according to the BSE risk
Notice 262 issued by the MHLW in July 2004 status of the Office International des Epizooties (OIE)
partially revised the Standards for Biological Materials were added to the list of countries of origin of raw
and Notification No. 0705001 of the PFSB dated July materials originating from cows and other ruminants
5, 2004 entitled “Partial Revision of the Standards for that can be used as raw materials.
Biological Materials” was issued. Notification No.
0325003 of the Evaluation and Licensing Division,
PFSB dated March 25, 2005 entitled “Handling of
TSE Data Associated with Enforcement of the
Partially Amended Pharmaceutical Affairs Law” was
also issued.
In an office communication of the Compliance and
Narcotics Division, PFSB dated September 5, 2006
entitled “Self-checking of Drugs, etc. Using Raw
Materials Derived Form Cattle Produced in the United
States,” instructions are given to verify by self-check
forms (self-check points) as an additional preventive
measures since it was clear that products in some lots
were manufactured using raw materials derived from
cattle produced in the United States even after the
deadline for changing raw materials. The Evaluation
and Licensing Division of PFSB issued Notification
No. 0928001 dated September 28, 2007 entitled
“Handling of Pharmaceutical Products Using
Bovine-Derived Materials to Comply with Partial
Revision of the Standards for Biological Materials,”
notifying the removal of Chile from the list of countries
free from where biological materials can be imported
for medical use and again requested the industry to
self-inspect the compliance with the Standards for
Biological Materials. Incidents of BSE were reported
in Brazil in December 2012 and in Norway in January
2015 and, in both cases, the Ministry issued a
notification to local departments and the industry to
implement voluntary inspection and preventive
measures (Notification No. 1211-(8) of the PFSB
dated December 11, 2012 and Notification No.
0130-(12) of the PFSB dated January 30, 2015).

2018 - 49 -
Pharmaceutical Regulations in Japan:

* PAL: Pharmaceutical Affairs Law


Procedures based on the PAL*

Start of clinical study Approval Date approval received for a drug


pursuant to the provisions of Article
14, Paragraph 1 of the
Pharmaceutical Affairs Law

Calculated from the latest date

Patent
right 1

Patent Registration of Expiration


application establishment (20 years)
of patent right
Period in which patent invention
cannot be exploited ═ Patent right extension
period

Patent
right 2 Patent Registration of Expiration
application establishment (20 years)
of patent right

Fig. 4 Flowchart of Patent-Life Extension

2018 - 50 -
Pharmaceutical Regulations in Japan:

Outside
Applicant PMDA
experts

Review Designation / consultation


experts Team review
Meeting
Reliability
Applicant +
Inspection review
experts Advice

Inquiries and confirmation from PMDA


Presentations and replies from applicant

Review report (1)

Review expert Outside


Manufacturing GMP in- Review experts +
conference I experts
sites spection
* Discussion on main issues, coordination
of opinions (*Paper discussions also held)

Summary on main issues

Interview
review meeting Review * Meeting for explanation (presentation) by
Applicant
experts applicant
+ * Discussion on main issues
Applicant’s Outside * Meeting presided over by person in
experts experts charge of review (or general review
supervisor)
* Meeting may be held twice.

Review expert Outside


Review experts +
conference II experts
To be held following interview review mtg

Review report (2)

GMP review results


Review results
(notification: results)
(Notification of results)

Inquiries
Approval Pharmaceutical Affairs
MHLW and Food Sanitation
Replies Council

Fig. 5 Flowchart of Approval Review

2018 - 51 -
Pharmaceutical Regulations in Japan:

(1) Designation of manufacturing/marketing business


license holder
Foreign manufacturer with
manufacturing approval

(4) Manufacturing/marketing order

(2) Designated manufacturing/marketing


(3) business license holder in Japan
approval application
Manufacturing/marketing

overseas
drugs manufactured
Restrictive approval of

MHLW (5) Manufacture and marketing

Fig. 6 Procedure for manufacturing and marketing approval of drugs for overseas
manufacturers in Japan

2018 - 52 -
Pharmaceutical Regulations in Japan:

PMDA MHLW

Selection of candidate drug items for Doc preparation Committee’s review PAFSC’s review & entry in JP
entry

4−6 months 3−6 months 6−12 months 6−7 months

Evaluation of
Letter of
request

Draft items of Evaluation of


Draft
presenter content items of
preparation
integrity confirmation

Submission Submission Draft Submission Reply Submission Reply


submission
Public comments

Public comments
confirmation
confirmation

Corrections
Draft after
Letter of

integrity

Items of
Candidate

Items of
request

Request

content

integrity
of draft

Reply
Draft

Draft
item

PMDA:
Division of
evaluation
Integrity

Standards

Approval Approval
Review by:
Committee Review Review Review
on Draft
Monograph

Report Approval Report

Public comments

Entry in JP
Review by Review by
PAFSC’s PAFSC’s

Approval
MHLW Committee Committee
on JP on JP

Fig. 7 Flowchart of Drug Listing in Japanese Pharmacopoeia

2018 - 53 -
Pharmaceutical Regulations in Japan:

Table 1 List of Main Controlled Substances


Category Topics
Poisonous and deleterious substances are designated by the MHLW as drugs
Poisonous and which cause or might cause damage to the functions of humans or animals when
deleterious injected and absorbed or applied externally to humans or animals because the
substances effective dose is close to the lethal dose, cumulative effects are potent or the
pharmacological effects are intense.
Prescription drugs are designated by the MHLW as drugs which may be sold or
Prescription drugs
supplied only under the prescription of a physician, dentist or veterinarian.
Habit-forming Habit-forming drugs are drugs designated by the MHLW as habit-forming.
drugs
Drugs for Drugs for designated diseases are drugs intended for the treatment of cancer and
designated other diseases designated by cabinet order, which might cause damage to patients
diseases unless used under the guidance of a physician or dentist.
Narcotics are drugs designated by the MHLW as drugs which affect psychological
function by their effects on the central nervous system, are habit forming and can
Narcotics
cause severe damage when abused. The narcotics specified in the Narcotics and
Psychotropics Control Law include morphine, codeine, pethidine and cocaine.
Psychotropics are drugs designated by the MHLW, as drugs which affect
psychological function by their effects on the central nervous system, are habit
forming and cause less severe damage than narcotics or stimulants when abused.
Psychotropics
The psychotropics specified in the Narcotics and Psychotropics Control Law
include hypnotics such as barbital, anxiolytics such as diazepam, and analgesics
such as pentazocine.
Opium and powdered opium obtained by concentration and processing of the
liquid extract from the opium poppy. Opium and powdered opium processed as
Opium
drugs are not controlled by the Opium Law but regulated as narcotics under the
narcotics and psychotropics classification.
Stimulants are drugs specified as drugs which are habit-forming, can cause severe
damage when abused and have potent stimulant effects. The stimulants
Stimulants specified in the Stimulants Control Law include phenylaminopropanes
(amphetamines), phenylmethylaminopropanes (methamphetamines), their salts
and products containing any of them.
Raw materials for stimulants are specified in the Attached Table of the Stimulants
Raw materials for
Control Law” and “Government Ordinance on Specifications of Raw Materials for
stimulants
Stimulants.”

2018 - 54 -
Pharmaceutical Regulations in Japan:

Table 2 Divisions of the Pharmaceutical and Food Safety Bureau in Charge of


Certification Work
Division Certification Item
Pharmaceutical 1. Items related to business licenses for manufacturing of drugs, quasi-drugs,
Evaluation etc.
Division 2. Items related to manufacturing/marketing approvals (notification) for drugs,
quasi-drugs, etc.
3. Items related to attached documentation for new drug
manufacturing/marketing approval applications
4. Items related to compliance of drugs with GLP Ordinance (Standards for
Conduct of Nonclinical Studies on the Safety of Drugs)
5. Items related to certification of pharmaceutical products (drugs)
6. Items related to statements of approval and licensing status of pharmaceutical
products
7. Items related to clinical trial protocol notifications for drugs
Medical Device 1. Items related to business registrations for manufacturing of medical devices
Evaluation 2. Items related to manufacturing/marketing approvals (notification) for medical
Division devices
3. Items related to business registrations and licenses for manufacturing of
extracorporeal diagnostic medicines and regenerative medicine products
4 Items related to manufacturing/marketing approvals (certification/notification)
for extracorporeal diagnostic medicines and regenerative medicine products
5. Items related to attached documentation for manufacturing/marketing approval
applications for regenerative medicine products
6. Items related to compliance of regenerative medicine products with GLP
Ordinance (Standards for Conduct of Nonclinical Studies on the Safety of
Regenerative Medicine Products)
7. Items related to certification of pharmaceutical products (extracorporeal
diagnostic medicines and regenerative medicine products)
8. Items related to statements of approval and licensing status of pharmaceutical
products (extracorporeal diagnostic medicines and regenerative medicine
products)
Pharmaceutical 1. Items related to business licenses for manufacturing/marketing of drugs,
Safety Division quasi-drugs, medical devices, extracorporeal diagnostic medicines and
regenerative medicine products
(Note: The certificate is issued by other division in case the certification is
originally requested as an attachment to the application to such division.)
Compliance and 1. Items related to compliance of drugs and quasi-drugs with GMP requirements
Narcotics Division (except for items related to certification of pharmaceutical products)
2. Items related to compliance with requirements of Ministerial Ordinance on
QMS for Medical Devices and In Vitro Diagnostics
3. Items related to compliance with requirements of Ministerial Ordinance on
GCTP for Regenerative Medicine Products
4. Items related to compliance of drug manufacturing plants with GMP
requirements for investigational products

2018 - 55 -
Pharmaceutical Regulations in Japan:

CHAPTER 3 indications, which are clearly different from those of


drugs, which have already been approved for
DRUG DEVELOPMENT manufacture and marketing.

1.1 Development of New Drugs


It is important to collect evidence sufficient for
1. PROCESS FROM DEVELOPMENT TO
proving the quality, efficacy and safety during the
APPROVAL
course of drug development. Results to show
The provisions of Article 14 of the “Law for quality, efficacy, and safety of new drugs must be
Ensuring the Quality, Efficacy, and Safety of Drugs obtained in nonclinical and clinical studies. The
and Medical Devices” (Law No. 145, 1960; nonclinical studies include physicochemical studies
hereinafter referred to as the Law) after revision and animal studies on pharmacology,
according to the Law for Partial Amendment of the pharmacokinetics, and toxicity. The clinical studies
Pharmaceutical Affairs Law (Law No. 84, 2013) usually consist of Phase I, II and III studies (or
stipulate that, when a person with an intention to human pharmacology, therapeutic exploratory,
manufacture and market a drug has filed an therapeutic confirmatory, and therapeutic use
application for approval of the manufacture and categories). On starting each phase of clinical
marketing of the drug, designated reviews should studies, it is necessary to adequately confirm the
be conducted for the drug to be applied regarding safety of the drug product from the results of
the components/contents, dosage and nonclinical studies or of previous clinical studies.
administration, and indications of, and adverse
The Pharmaceutical and Medical Device Act
reactions, etc., and the Minister of Health, Labour
specifies that the data submitted to obtain approvals
and Welfare shall give an approval for each
must be obtained and compiled according to the
product. When an application for approval is filed,
standards specified in its Article 14, Paragraph 3.
evidence sufficient for proving the quality, efficacy,
Related ordinances include the Ordinance on
and safety of the application-related drug need to
Standards for Conduct of Clinical Trials (GCP)
be presented using the documents with ethical and
(MHW Ordinance No. 28 dated March 27, 1997,
scientific validity and reliability on the basis of the
partially revised by MHLW Ordinance No. 9 dated
medical and pharmaceutical academic standards at
January 22, 2016; the Ordinance on Standards for
that time point (PFSB Notification No. 1121-(2)
Conduct of Nonclinical Studies on the Safety of
dated November 21, 2014).
Drugs (GLP) (MHW Ordinance No. 21, March 26,
When an application for approval of a drug is 1997, partially revised by MHLW Ordinance No.
filed, the data of the results of clinical trials and other 114 dated June 13, 2008) and Standards for the
data must be attached (Article 14, Paragraph 3 of Reliability of Application Data (Article 43 in the
the Law). Enforcement Regulations) which were enforced
This section explains the outline of the matters from April 1, 1997. Therefore, the acceptance of
related to the drug development including the data is conditioned on adherence to the
procedures for clinical trials, interview advice standards. It is important that studies to obtain
meetings and approval review data for approval reviews should be performed by
New drugs are defined as drugs with active standard methods whenever possible in order to
ingredients, dosage, administration route, or assure proper evaluations of drugs. Reviews on

2018 - 56 -
Pharmaceutical Regulations in Japan:

compliance with these standards are performed by At the time of the clinical trial protocol
the Pharmaceuticals and Medical Devices Agency notification, a system by which the PMDA reviews
(PMDA) at the request of the MHLW. the contents of the initial notification at the request
A flowchart from development to approval of of the MHLW is now specified by law, and a "clinical
new drugs is shown in Fig. 8 Flowchart of New trial consultation system" in which the PMDA gives
Drug Development and Approval. guidance and advice concerning study protocols
has also been established (refer to Section 1.4:
1.2 Procedures for Clinical Trials Interview Advice Meetings).
It is necessary to submit clinical trial (protocol)
For clinical studies (trials) to be conducted for
notifications in the following instances:
collection of data to be submitted in marketing
approval application of a new drug, etc., the Law (1) Drugs with new active ingredients
and the GCP specified sponsor’s responsibility for (2) Drugs with new administration routes
submitting a notification of the clinical trial plan in (excluding bioequivalence studies)
advance and matters that a sponsor must comply (3) New combination drugs, drugs with new
with in requesting a medical institution to conduct a indications or new dosage and administration
clinical trial. (excluding bioequivalence studies)
Scope of GCP includes not only clinical trials in (4) Drugs containing the same active ingredients
patients but also Phase I studies in healthy with the drugs with new active ingredients, for
volunteers, bioequivalence studies in human, which the reexamination period has not been
studies for additional indication of an approved drug completed yet (excluding bioequivalence
and post-marketing clinical trials after marketing. studies)
Furthermore, its partial amendment 2003 specifies (5) Drugs considered to be biological products
investigator-initiated clinical trials as well. [excluding (1) to (4)] (excluding bioequivalence
According to the new GCP, when a clinical studies)
study is requested, a contract for clinical trials can (6) Drugs manufactured using gene recombinant
be concluded only when 30 days have passed from technology [excluding (1) to (5)] (excluding
the initial notification of the study protocol is bioequivalence studies)
received by the PMDA (at least 2 weeks for
The types of clinical trial protocol notifications
subsequent notifications, as a rule). The sponsor
and documents to be submitted are shown below.
must report to the authorities any severe adverse
(1) Clinical trial protocol notifications (when
reactions or infections that occur during the study,
notifications are first made for drugs with new
and the authorities may undertake on-site
active ingredients or new routes of
inspections concerning GCP compliance in the
administration and new combination drugs,
sponsor's facilities and the medical institution
they must be submitted at least 31 days before
performing the study when problems arise during
the planned start date of the trial stated in the
the study. For drugs required in emergencies to
contract with the medical institution performing
prevent diseases that have a major effect on the life
the clinical study. Otherwise, they must be
or health of the patient or to prevent other damage
submitted at least 2 weeks before the planned
to the health, clinical study protocols may be
date of the trial.)
submitted within 30 days after the start of the study
(MHLW Ordinance No. 89 dated May 15, 2003). a. Document that gives the reason why the

2018 - 57 -
Pharmaceutical Regulations in Japan:

request for the clinical study was judged to be virus or not


scientifically appropriate (from the 2nd - Conformity to the Standard for Biological
notification, it should include a description of Ingredients if a human or animal-derived raw
the results of new clinical studies since the material is used
previous notification and a summary of
- Virus safety of the investigational product if
information)
animal cells or biological raw material is used in
b. Clinical study protocol its manufacture
c. Explanatory materials and consent form used - Removal states of impurities and transient
for obtaining informed consent specifications for safety-related test parameters
d. Sample of the case report form (CRF) (The under specification tests of the drug substance
sample is not required if information to be and drug product
contained in the CRF is explicitly stated in (2) Notification of changes in clinical study
protocol.) protocols (submitted as a rule for each clinical
e. Latest investigator's brochure trial protocol notification before changes in
In response to issuance of the guideline of the notification items)
International Council for Harmonisation of Technical Data related to the changes as required:
Requirements for Pharmaceuticals for Human Use (3) Clinical study discontinuation notification (This
(ICH), “Assessment and Control Of DNA Reactive notification must be submitted for each clinical
(mutagenic) Impurities in Pharmaceuticals to Limit trial protocol notification without delay when a
Potential Carcinogenic Risk (ICH-M7),” protocols clinical study is discontinued.)
submitted on January 15, 2016 or later have to Data related to the reason for discontinuation
include “Document on assessment and control of as required (including information on study
DNA reactive (mutagenic) impurities” as an subjects collected until discontinuation):
attachment in addition to those of the above a. to e. (4) Clinical study completion notification (This
(with a transition measure) (Notification No. 1110-(3) notification must be submitted for each clinical
of the Evaluation and Licensing Division, PSEHB trial protocol notification without delay when a
dated November 10, 2015). notification of completion of the clinical study is
When a protocol notification of a protein drug received from all medical institutions and
manufactured from established cell line is submitted recovery of the investigational product is
for the first time, reference documents on the quality completed.)
of the investigational product covering the following (5) Development discontinuation notification (to be
information have to be attached separately (Office submitted, when development for the drug is
Communication dated December 14, 2015). discontinued as a whole in Japan.)
- Manufacturing flow chart of the investigational From April 1, 2011, attachments to the clinical
product trial notification (including protocol revision
- Whether the cell line is contaminated with notification, clinical trial completion notification,
infectious agents or not clinical trial discontinuation notification and
- Whether conditioned culture medium before development discontinuation notification) are
purification is contaminated with pathogens required to be submitted in electronic format as well
such as bacteria, mycoplasma and aberrant as in paper format (Notification No. 0531-(8) of the

2018 - 58 -
Pharmaceutical Regulations in Japan:

Evaluation and Licensing Division, PFSB dated brochure of the investigational product
May 31, 2013). concerned: the report must be made within 7
In view of a recent increase of international days.)
multi-center clinical trials, the sponsor of a clinical a) Death
trial is required to include information concerning b) Cases that might result in death
international clinical trials in the clinical trial
B: 15-Day reports (For the following events: the
notification submitted on or after April 1, 2008
report must be made within 15 days.)
(Notification No. 0321001 of the Evaluation and
a) Any of the following events suspected to be
Licensing Division, PFSB dated March 21, 2008).
caused by an adverse reaction of the
Additionally, in view of a trend of development of
investigational product concerned or by an
drugs with associated companion diagnostics
infection suspected of being caused by the
relating to the individualized medicine, a sponsor is
investigational product concerned, which is
required to include whether a companion
not expected from the description in the
diagnostics is being developed for the drug with its
investigator's brochure of the investigational
development status, if any, in the remarks in a
product concerned.
clinical trial notification of a drug to be submitted
since February 1, 2014 (Notification No. 0701-(10) • Any case that requires hospitalization for
of the Evaluation and Licensing Division, PFSB treatment or prolongs the duration of
dated July 1, 2013). hospitalization.
• Disability
1.3 Safety information on Adverse Reactions • Cases that might result in disability
and Infections during the Study • Other medically serious condition
Safety information obtained during the study • Congenital diseases or abnormalities in
must be reported promptly, as is specified in the next generation
"Clinical Safety Data Management" (Notification No. b) Predicted deaths or events that might result
227 of the Evaluation and Licensing Division, PAB in death.
dated March 20, 1995; ICH-E2A).
c) Measures related to safety problems of the
In the revision of the Enforcement Regulations investigational product concerned, including
of the Law in April 1997 for which the ICH discontinuation of manufacture and/or
guidelines served as a reference, the obligation to marketing in a foreign country.
report adverse reactions, etc. related to the
d) Research reports showing the possibility of
investigational product, including those occurring in
causing cancer or other serious diseases
foreign countries, to the Minister was specified by
due to adverse reactions, etc. of the
law. These provisions are outlined below.
investigational product concerned.
A: 7-Day reports (When either of the following
The Enforcement Regulation of the Law, which
events is suspected to be caused by an
was modified in February 2008 require the sponsor
adverse reaction of the investigational product
to report to the MHLW cases of serious ADRs, etc.
concerned or by an infection suspected of
expected according to the IB periodically at 6-month
being caused by the investigational product
intervals. Later, this reporting period was changed
concerned, and the event is not expected
to 1-year intervals by further revising the
from the description in the investigator's

2018 - 59 -
Pharmaceutical Regulations in Japan:

Enforcement Regulations (Ministerial Ordinance consultations with respect to preparation for


No. 161 entitled “Ordinance for Partially Modifying consultations, implementation of consultations,
the Pharmaceutical Affairs Law Enforcement preparation of records, etc. as measures to meet
Regulations, etc.” dated December 28, 2012) to the demands for those requesting consultations
harmonize the period with relevant ICH guidelines. (Notification No. 0302070 of the PMDA dated
Basic standards for periodically reporting safety March 2, 2012, partially revised on January 4,
information during the development phase, 2018). Main items of the interview advice meeting
common to all drugs, etc., are available in handled by the PMDA are as described below.
“Development Safety Update Report (DSUR)” Details of the consultation items, the latest
(Notification No. 1228-(1) of the Evaluation and information on consultation fees, and application
Licensing Division, PFSB dated December 28, procedures for interview advice meeting are
2012: ICH E2F) available at the following homepages of the PMDA.
http://www.pmda.go.jp/review-services/f2f-pre/cons
Any manufacturer or marketing authorization
ultations/0007.html
holder who has submitted plan of a trial of a product
Preparatory consultation is also available to
deemed as a combination product at a market shall
assure smooth interview advice.
be obligated to report any malfunction of a part of
device or equipment in the combination product as (1) Clinical trial consultation
specified for malfunction reports of medical devices • Consultations on procedures
(Notification No. 1024-(2) of the Evaluation and • Consultations on bioequivalence studies
Licensing Division, PFSB, Notification No. 1024-(1)
• Consultations on safety
of the Medical Devices Division, PFSB, Notification
• Consultations on quality
No. 1024-(9) of the Safety Division, PFSB, and
Notification No. 1024-(15) of the Compliance and • Consultations before start of Phase I studies
Narcotics Division, PFSB all dated October 24, • Consultations before start of early Phase II
2014, revised by Notification No. 1122-(4) of the studies
Pharmaceutical Evaluation Division, PSEHB, • Consultations before start of late Phase II
Notification of No. 1122-(10) of the Medical Device studies
Evaluation Division, PSEHB, Notification No.
• Consultations after completion of Phase II
1122-(7) of the Safety Division, PSEHB, and
studies
Notification No. 1122-(4) of the Compliance and
• Consultations before license application
Narcotics Division of PSEHB dated November 22,
2016). • Consultations on plans of post-marketing
clinical studies of drugs, etc.

1.4 Interview advice meetings • Consultation at completion of post-marketing


clinical studies of drugs, etc.
The PMDA has established a consultation system
• Additional consultations on drugs
for clinical study protocols to improve and reinforce
the quality of clinical studies. The consultations • Consultations before start of expanded trials
and review work have been united under the same of drugs
teams in the Review Department. With the (2) Consultations on preliminary assessment
increasing demand for clinical trial consultations, of new drugs
improvements have been made in the quality of Assessment of data in preparation for license

2018 - 60 -
Pharmaceutical Regulations in Japan:

application (preliminary assessment of data • Consultations on the applicability of priority


concerning the following areas planned to be review status (consultation in conjunction with
submitted for application in order to identify potential that before license application)
issues to be addressed during review): • Consultations on the applicability of conditional
• Quality accelerated approval status
• Nonclinical: Toxicology • Consultations on the applicability of conditional
• Nonclinical: Pharmacology accelerated approval status (consultation in
conjunction with that before license application)
• Nonclinical: Pharmacokinetics
(4) Consultations on the applicability as
• Phase I studies
pharmacogenomics markers or biomarkers
• Phase II studies
• Assessment of applicability
• Phase II/III studies
• Assessment of major aspects of clinical trial
(3) Consultations on eligibility for priority
design
review and conditional accelerated
• Additional consultation (on the applicability)
approval for new drugs
• Additional consultation (on major aspects of
Evaluation of new drugs to determine the
clinical trial design)
eligibility of drugs, other than the drugs covered by
the SAKIGAKE designation system or orphan (5) Consultations on epidemiological surveys
drugs, for priority review or conditional accelerated • Consultations on the procedure of
approval system when an applicant desires a new epidemiological surveys of drugs
drug to be designated as a product for priority • Consultations on the plan of epidemiological
review or conditional accelerated approval. surveys of drugs
Procedures for handling priority review are available
• Additional consultation on epidemiological
in Notification No. 0901-(1) of the Evaluation and
surveys of drugs
Licensing Division of PFSB dated September 1,
(6) Consultations for preliminary confirmation
2011. Subsequently, the drugs subjected to
of the revision of package inserts and
SAKIGAKE designation were added to the list of
consultations on the revision of package
drug products for the designation of priority
inserts
interview advice as the implementation of the
SAKIGAKE designation system was started (7) Consultations on generic drugs
(Notification No. 0122-(12) of the Evaluation and • Consultations on bioequivalence of generic
Licensing Division, PSEHB and Notification No. drugs
0122-(2) of the Medical Device Evaluation Division, • Consultations on quality of generic drugs
PSEHB dated January 22, 2016). (8) Consultations on generic drugs before start
The consultation fee is different between the of clinical studies or license application
case of only priority assessment consultation and • Switch OTC drugs
that in conjunction with the consultation before
• Major aspects of clinical trial design
license application.
• Rationale for clinical development as a new
• Consultations on the applicability of priority
generic drug
review status
(9) Consultations on GCP/GLP/GPSP of a drug

2018 - 61 -
Pharmaceutical Regulations in Japan:

(10) Simple consultations (14) Consultations on compliance review for


Brief consultations with reviewers in charge of drug reexamination
the approval review of generic prescription drugs, Guidance and advice are provided to the
non-prescription drugs, etc. as well as the applicant concerning compliance of the following
registration of drug master files documents with the reliability standards: applicable
• Generic drugs documents are planned to be attached in the
application for drug reexamination and are related
• Non-prescription drugs
to the previously completed post-marketing clinical
• Drugs for controlling harmful insects and
study, drug use-results survey or special drug
animals
use-results survey.
• Quasi drugs
(15) Consultations on compliance review for
• Revision of text in labeling of new drugs data used as the rationale for revision of
• GCP/GLP/GPSP inspection of a drug package inserts of drugs
• GMP/QMS inspection Guidance and advice are provided to the
• GCTP inspection applicant concerning reliability of the documents
(11) Post-interview consultations on new dugs regarding clinical trials used as the rationale for
revision of package inserts of drugs according to
These are additional consultations for matters
the reliability standards.
for which both of PMDA and the consulter agreed to
be addressed later in an interview advice meeting. (16) Regulatory science general consultations
Matters such as data evaluation should not be / Regulatory science strategy
addressed in a post-interview consultation, because consultations (former consultations on
those should have been addressed already in the regulatory strategies)
previous interview advice meeting. A post-interview Consultations to discuss plans for necessary
consultation may be recorded at an extra charge, if clinical trial or development mainly with universities,
required by the consulter. research institutes, and venture companies who
(12) Preparatory consultation or meeting have found seeds throughout the R&D period from
the final stage of lead compound or candidate
Preparatory consultations or meetings prior to
medical device selection mainly until the early
formal consultation to sort out consultation items
phase of clinical development [Phase IIa]).
and assure smooth interview advice. In the
Preparatory consultations and main consultations
preparatory consultation, data are not evaluated
are held as "regulatory science strategy
and official meeting records are not issued.
consultations," and individual consultations are held
(13) Consultations on compliance review with as "regulatory science general consultations." In
reliability standards addition, guidance and advice for quality and safety
Based on data planned to be submitted together may be provided from an early development phase
with the application form, guidance and advice are for regenerative medicine products or preventive
provided to the applicant concerning GCP and GLP products to be used for expressing transgenes in
compliance of drugs that have undergone “the the human body (other than regenerative medicine
evaluation of drug products for the designation of products; e.g., recombinant live vaccine). The
priority interview advice” and of new drugs that have verification application system for products for gene
undergone “a preparatory consultation or meeting”. therapy has been abolished.

2018 - 62 -
Pharmaceutical Regulations in Japan:

(17) Consultations on SAKIGAKE matters to be kept in mind in preparation of the


comprehensive assessment documents. Related notifications are available on
Consultations on drugs covered by the the PMDA homepages.
SAKIGAKE Designation System (prior data Japanese HP:
assessment of planned application documents on http://www.pmda.go.jp/review-services/drug-review
the following fields to organize issues and tasks to s/about-reviews/otc/0001.html
be addressed before the review) The recommended standard format for the
• Quality data quality and clinical safety information on CTD is
• Non-clinical data presented by PMDA (Office Communication
entitled "Format for Preparing the Common
• Clinical data
Technical Document for Submission of New Drug
• Reliability
Applications to Reduce Total Review Time" dated
• GMP/GCTP/QMS January 17, 2011).
(18) Consultations on electronic data PMDA is mainly in charge of the activities related
submission for application for new drugs to an approval review of a new drug. Once the
Consultations to ensure smooth preparation of application form is received by PMDA, a detailed
approval application and subsequent review, in team review is performed by the review staff.
which the following contents are investigated on a Moreover, compliance review (certification from
specific product at a stage prior to approval source data) and GCP on-site inspection are
application: the contents are to be submitted in a conducted to confirm the reliability of application
form of electronic data for approval application of a data (Refer to Section 4.2: Marketing Approval
new drug, of which clinical data are planned to be Reviews of Chapter 2). As the points to consider
attached in an electronic form (including formats in the review of new drugs, the document entitled
and programs for constructing definition files and “Points to Be Considered by the Review Staff
data set). Involved in the Evaluation Process of New Drug”
(19) Preparatory consultation on minor change has been issued and accessible at the following
notification of drugs PMDA homepages:
Consultation on issues that generally require Japanese HP:
prior data assessment for appropriateness of items http://www.pmda.go.jp/files/000157674.pdf
to be included in a minor change notification English HP:
http://www.pmda.go.jp/files/000153830.pdf
1.5 Approval review
After the review by PMDA is completed, the
The documents to be attached at the time of application is then discussed by the Committees
application are designated for each application and Department on Drugs of the PAFSC on the
category (PFSB Notification No. 1121-(2) entitled basis on the most recent and advanced scientific
"Approval Applications for Drugs" dated November knowledge and the final decision concerning
21, 2014). See the "Points to Consider for Approval approval is made by the Minister of Health, Labour
Application Data for New Drugs" (Notification No. and Welfare.
1121-(12) of the Evaluation and Licensing Division
The current fee for approval of medicines, etc. is
of PFSB dated November 21, 2014), etc. for the
available at the following PMDA homepage:

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Pharmaceutical Regulations in Japan:

http://www.pmda.go.jp/review-services/drug-review • Points to consider when using a drug master


s/user-fees/0001.html file (MF)
The timeline after application for approval of a Points to consider for adequate contact with
new drug is shown in the notice “Timeline for the person registering the MF, verification of the
Completing the New Drug Application Review MF registration conditions, and submission of
under the Standard Process" (Office information of registered MF corresponding to
Communication dated January 30, 2015) (Fig. 9 Module No. 2 of the CTD without delay after filing
Timeline in the standard process of new drug an approval application for the product.
approval). • Application for GMP compliance inspection
The PMDA review period for new drugs is Application for inspections of the facilities
expected to be shortened through the efforts of both concerned and preparation for receiving
the regulatory authorities and the applicants, and inspectors at sites when the applicant judges
the points to consider in the application from the based on contract, etc. from the department in
standpoint of shortening the period on the applicant charge of the inspection that the inspections are
side are specified in the Office Communication likely to take place.
entitled “Points to consider in shortening of the
For the purpose of improving predictability of
PMDA review period for new drugs” dated June 9,
approvals, it is required that PMDA holds a
2010. The main points are as follows.
preparatory meeting with a potential applicant
• Handling of data from long-term clinical studies ( “Handling of approval application for increased
Data obtained on completion of predictability of approval of new drugs and concept
administration to all patients for at least 6 on total review period” (Notification No. 1006-(1) of
months should be appended as application the Evaluation and Licensing Division, PFSB and
data. The final report (including data on Notification No. 1006-(1) of the Compliance and
completion of administration to all patients Narcotics Division, PFSB both dated October 6,
for at least one year) and the revised draft of 2014).
the CTD should be submitted at the earliest
possible time as additional data. At the 1.6 Compliance review
latest, it should be submitted by 6 months
Following revision of the Pharmaceutical Affairs
before the end of the targeted total PMDA
Law in June 1996, the PMDA started reviews of
review period.
compliance with quality standards, GLP, and GCP
• Handling of data from long-term stability by verification and comparisons with raw data to
studies determine if the attached data used in approval
Additional data should be submitted as a reviews of new drugs has been compiled correctly
final report (including data required for based on study results. Compliance reviews are
setting the planned expiration period) at the applied after approval applications are filed. They
latest by 6 months before the end of the total consist of both paper reviews and on-site reviews.
targeted PMDA review period. Additional Paper review had been conducted as directed in
data obtained thereafter should be submitted the “Application Procedures for Paper Review of the
by the time of data submission to the Conformity of New Drug Application with Relevant
Committee of Experts. Regulations” (Notification No. 0528027 of the

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Pharmaceutical Regulations in Japan:

PMDA dated May 28, 2010) and on-site inspection Compliance Review of New Drug Application
as directed in the “Application Procedures for (for Sponsor’s Use)” in November 2012 and
On-site GCP Inspection for Drug Application” “Checklists for Compliance Review of New
(Notification No. 0528028 of the PMDA dated May Drug Application (Quality/Non-clinical)” in
28, 2010). These notifications were integrated into March 2014. The checklists are publicly
the “Application Procedures for Paper available for self-compliance review by the
Review-Conformity Inspection and On-site GCP applicant.
Inspection for Drug Application” (Notification No. When case report forms are prepared by
1012063 of the PMDA dated October 12, 2012) using Electronic Data Capture (EDC) system,
and paper review and on-site inspection have been EDC management sheets are required to be
regulated to be conducted simultaneously, as a prepared and submitted in advance of
rule. Subsequently, in association with the start of application as directed in “Compliance
submission of electronic data from October 1, 2016 Inspection Procedures for Clinical Trials,
on the basis of the "Notification on Practical Post Marketing Clinical Trials, and Use
Operations of Electronic Study Data Submissions" Results Survey by Using EDC System”
(Notification No. 0427-(1) of the Evaluation and (Office Director’s Notification No. 0327001 of
Licensing Division of PFSB dated April 27, 2015), PMDA dated March 27, 2013).
"Pharmaceuticals and Medical Devices Agency:
 On-site reviews
Procedures for Implementation of Document-based
Assessment and GCP On-site Inspection for Drug In these reviews, the PMDA review staff
Application" (PMDA Notification No. 0511005 dated examines the data at the sites where it was
May 11, 2016) was revised. collected or compiled. The guideline for
on-site GCP compliance reviews is available
 Paper reviews
as the “Inspection Procedures for the On-site
Paper reviews are performed based on Verification of GCP Compliance for Drug
“the Guidelines for Paper Compliance Application” (Notification No. 0131006 of the
Review for New Drug Approval Application Evaluation and Licensing Division, PFSB
Data” (Notification No. 0131010 dated dated January 31, 2006, revised by
January 31, 2006 and revision No. 1121-(5) Notification No. 1121-(1) of the Evaluation
dated November 21, 2014 of the Evaluation and Licensing Division, PFSB dated
and Licensing Division, PFSB) when the November 21, 2014).
applicant provides the PMDA with data as
The reviews are generally performed in
evidence for approval reviews. The review
the applicant’s offices and facilities and
is basically performed by reviewing approval
medical institutions performing the clinical
application data brought into the PMDA
study (four facilities as a rule for new drugs;
(“document-based inspection”); however, the
two facilities for additional indications or
Agency’s personnel may visit sites (including
orphan drugs). In selection of review
those outside Japan) where application data
facilities, consideration should be given to
as well as source data are archived, as
the number of subjects in clinical trials and
needed, to inspect such data (“on-site
dates of GCP reviews performed in the past.
inspection”). The PMDA issued “Checklists
The PMDA also provides a checklists,
for On-site and Document-Based GCP
“Checklists for GCP Compliance On-site

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Pharmaceutical Regulations in Japan:

Review of New Drug Application (for Medical 1.7.1 GMP Compliance Reviews
Institution’s Use)” and “EDC Checklists” (for When an application is submitted for a new drug
Medical Institution’s Use), as references for manufacturing and marketing approval, the plant
self-inspections before on-site inspections of must be inspected by the authorities to determine if
medical institutions. it actually complies with the GMP standards.
Checklists and management sheets for (“Establishment/abolishment of the Ministerial
paper reviews and on-site reviews are Ordinances and Notices on Good Manufacturing
available at the following PMDA homepage. Practice and Quality Management System
On March 1, 2017, the "GCP Management (GMP/QMS) of drugs and medical devices, etc. in
Sheet" to be used by companies for association with enforcement of the Law for partial
document-based inspection and GCP on-site amendment of the Pharmaceutical Affairs Law and
inspection was officially published by PMDA. the Blood Collection and Donation Service Control
The companies that wish to use it should Law” Notification No. 0330001 of the Compliance
submit it to PMDA as the document to be and Narcotics Division, PFSB dated March 30,
used immediately before the inspection. 2005.)
http://www.pmda.go.jp/review-services/inspections/ First, a review is conducted for each product
gcp/0002.html#r=s&r=s using the following criteria for GMP compliance as
to each article in the control regulations and building
1.7 GMP compliance inspection and facility regulations.
Formal approvals are required for individual
Evaluation rank criteria
formulations of drugs in order to market the drugs in
Japan. Formal approval must be obtained prior to A (Compliance): Manufacturing is
market launch from the Minister of the MHLW or performed properly.
prefectural governor by submitting data and B (Slightly defective): There is little effect on
documents for required review on product quality, drug quality but improvement necessary
efficacy, and safety. for complete compliance with control
Marketing approvals require a review to regulations.
determine whether or not the product in the C (Moderately defective): Effect on drug
application is suitable as a drug to be marketed by a quality cannot be ruled out and
person who has obtained a marketing business improvement necessary for compliance
license (marketing authorization holder) for the type with control regulations.
of drug concerned and confirmation that the product D (Seriously defective): Clear violation of
has been manufactured in a plant compliant with control regulations
GMP. Thus, GMP compliance is a requirement for
Next, a review is undertaken for each product
manufacturing and marketing approval of drugs,
using the following criteria on the basis of the results
etc. (Article 14-2, Paragraph 4 of the
of the review of GMP compliance for each article in
Pharmaceutical Affairs Law).
the control regulations and building and facility
When a manufacturing plant does not conform regulations:
to GMP standards, the MHLW minister or
 Compliance: Cases of A only.
prefectural governor may not grant a license.
 General compliance: Cases of A and B or B only.

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Pharmaceutical Regulations in Japan:

 Improvement required: Cases of C evaluated for recognized GMP rules contained in Pharmaceutical
half or less of all items and no D. Inspection Cooperation Scheme (PIC/S) was
 Non-compliance: Cases not corresponding to any recommended to secure closer international
of the above. standardization and conformity in GMP inspections.
MHLW, PMDA, and prefectural governments bid
When GMP compliance by product is
membership to the office of PIC/S in March 2012
determined as "General compliance" or
and became a member on July 1, 2014. ("Concepts
"Improvement required," an order for
of Utilization of GMP Guidelines of PIC/S," Office
improvement(s) for the item(s) rated as B is issued
Communication dated February 1, 2012, partially
in writing.
revised on August 9, 2017).
In such cases, the applicant must submit a
The enforcement notification of the GMP
concrete plan of improvements. When
(Notification No. 0330001 of the Compliance and
improvements are completed, a report on the
Narcotics Division, PFSB dated March 30, 2005)
improvement must be submitted. When the
was amended in August 2013 in order to align with
improvements have been confirmed, the rating of
the GMP guideline in PIC/S (Notification No.
the corresponding item is changed to "Compliance."
0830-(1) of the Compliance and Narcotics Division,
The results of reviews or assessments at each
PFSB dated August 30, 2013).
of the above stages are compiled, and a report of
the GMP compliance review is prepared for the 1.7.3 Regulations for Imported Drug
plant in the application concerned. When the initial Management and Quality Control
GMP compliance review results of a product
Since it is very important to assure the quality of
correspond to "General compliance" or
imported drugs in the same way as drugs
"Improvement required," the subsequent course is
manufactured in Japan, items related to regulations
entered in the GMP compliance review report.
for manufacturing control and quality control, when
1.7.2 Global Harmonization of GMP importers and marketing authorization holders
import drugs, were specified in the Import Control
Japan has concluded mutual agreements for
and Quality Control of Drugs and Quasi-drugs
GMP (MOU) approvals with countries with
(MHW Ordinance No.62, June 2, 1999), but since
equivalent levels of GMP. These agreements are
the import business license has been including in
meant to assure the quality of drugs imported into
the manufacturing/marketing business license, this
Japan through mutual acceptance of GMP
was abolished on March 31, 2005. These
inspection results and exchange of information on
regulations included matters to be agreed upon with
drugs marketed in the two countries. These
the manufacturer in foreign country by the importer
mutual agreements have been concluded with
in accordance with the agreement. The importer
Germany, Sweden, Switzerland and Australia.
must confirm that the drug to be imported is
Mutual recognition agreement of drug GMP (MRAs)
manufactured under appropriate manufacturing
with the EU countries was firstly concluded in May
control and quality control, and must import, store,
2003, and in April 2016, Japan-Europe MRA
and conduct testing in accordance with standards,
became applicable to all the 28 EU countries
etc.
(Notification No. 0426-(3) of the Compliance and
In addition, when a mutual agreement for GMP
Narcotics Division of PSEHB dated April 26, 2016).
approvals has been concluded between the
Positive utilization of the internationally

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Pharmaceutical Regulations in Japan:

exporting country and Japan, part of the quality 2009 for partial amendment on biosimilar products;
control work may be omitted if the following two Notification No. 0701-(10) of the Evaluation and
conditions are met: that it is confirmed by the Licensing Division, PFSB dated July 1, 2013 for
government organization in the exporting country partial amendment on companion diagnostics and
that the plant where the imported drug was associated drugs; and PFSB Notification No.
manufactured complies with the GMP in the 0612-(6) dated June 12, 2014 for partial
country; and that the records of tests performed by amendment on guidance-mandatory drugs) with
the manufacturer of the drug are provided to the abolishment of Notification No. 481 of PFSB, as
importer in Japan. well as the handling procedures were detailed in
From April 1, 2005, a manufacturer/marketing “Points to Consider in Approval Application of
authorization holder or manufacturer had to submit Drugs” (Notification No. 0331009 of the Evaluation
an import certificate before custom clearance when and Licensing Division, PFSB dated March 31,
importing drugs as business, but this regulation was 2005 ; Notification No. 1020002 of the Evaluation
abolished in December 2015. No import certificate and Licensing Division, PFSB dated October 20,
is currently required. Instead, from January 2016, 2008 for partial amendment on non-prescription
the custom clearance procedure requires drugs; Notification No. 0304015 of the Evaluation
presentation of business license and marketing and Licensing Division, PFSB dated March 4, 2009
approval certificate of a product to be imported. for partial amendment on biosimilar products ;
Notification No.0701-(10) of the Evaluation and
Licensing Division, PFSB dated July 1, 2013 for
2. DATA REQUIRED FOR APPROVAL partial amendment for companion diagnostics and
APPLICATIONS associated drugs; and Notification No. 0612-(1) of
The data to be attached to approval applications the Evaluation and Licensing Division, PFSB dated
for drugs is specified in the basic notification entitled June 12, 2014 for partial amendment on
“Approval Applications for Drugs” (Notification No. guidance-mandatory drugs).
481 of PMSB dated April 8, 1999 and partial Later, with the enactment of the Pharmaceutical
revision: Notification No. 0525003 of the Evaluation and Medical Device Law, “Approval Application for
and Licensing Division, PFSB dated May 25, 2004). Drugs” (Notification No. 1121-(2) of the PFSB) and
Detailed handling procedures are specified in “Points to Consider in Approval Application of
“Points to Consider in Drug Approval Applications” Drugs” (Notification No. 1121-(12) of the Evaluation
(Notification No. 666 of the Evaluation and and Licensing Division, PFSB) were issued. The
Licensing Division, PMSB dated April 8, 1999). In new notifications were based on the information
addition, in association with enforcement of the contained in the old notifications, with some
revised Pharmaceutical Affairs Law in April 2005, changes such as the addition of information in
revised handling procedures of documents to be attached data, etc. as data to be attached to
attached to manufacturing/marketing approval approval applications.
application for drugs were specified in “Approval Subsequently, an agreement was reached on
Applications for Drugs” (Notification No. 0331015 of the Common Technical Document (CTD) by the
PFSB dated March 31, 2005; Notification No. ICH (International Conference on Harmonization of
1020001 of PFSB dated October 20, 2008 for Technical Requirements for Registration of
partial amendment on non-prescription drugs; Pharmaceuticals for Human Use) and a notification
Notification No. 0304004 of PFSB dated March 4,

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Pharmaceutical Regulations in Japan:

entitled “Handling Data Attached to Drug Approval to eCTD Version 4.0 ICH agreement. The date of
Applications” (Notification No. 663 of the PMSB application of this partial revisions will be separately
dated June 21, 2001), which is a partial revision of notified.
the previous notification mentioned above. On the It was decided that, with the start of submission
same day, another notification entitled “the of electronic clinical study data from October 1,
Guidelines for Preparation of Data Attached to 2016, data attached to approval applications will, as
Applications for Approval to Manufacture or Import a general rule, be in eCTD format. (The period until
New Drugs” (Notification No. 899 of the Evaluation March 31, 2020 will be the transitional measure
and Licensing Division, PMSB, dated June 21, period.)
2001, partially revised by Notification No. 0202-(1)
As the PMDA was required to progress further in
of the Pharmaceutical Evaluation Division of
the “Japan Revitalization Strategy” (Cabinet
PSEHB dated February 2, 2017) was issued to
Decision dated June 14, 2013) and to utilize clinical
specify guidelines for preparation of data to be
data for review by itself in the “Health and Medicine
attached to approval applications based on the
Strategy” (Related Ministers’ Consensus dated
CTD. The data required for approval applications
June 14, 2013), the notification entitled “Basic
using CTD format is shown below. The data in
concept of electronic data submission in approval
Modules 2 to 5 are prepared on the basis of the
application” (Notification No. 0620-(6) of the
CTD guidelines shown in Attachments 1 and 3 to 5
Evaluation and Licensing Division, PFSB dated
of these guidelines. In the notification of partial
June 20, 2014) was issued with its Q&A (Office
revision dated February 2, 2017, the procedure to
Communication dated June 20, 2014). Moreover,
describe "Benefits and Risks Conclusions" was
"Notification on Practical Operations of Electronic
completely reconsidered.
Study Data Submissions" (Notification No. 0427-(1)
For electronic specifications of the CTD (eCTD), of the Evaluation and Licensing Division of PFSB
“Electronic Specifications of the Common Technical dated April 27, 2015 and the Q&As (Office
Document” (Notification No. 0604001 of the PFSB Communication dated April 27, 2015) were issued,
dated June 4, 2003, partially revised by Notification and the range of submission of electronic data is
No. 0707-(3) of the Evaluation and Licensing explained by these notifications and Q&A, etc.
Division, PFSB dated July 7, 2009). Version 3.2.2 Furthermore, submission of electronic data through
was enforced from October 1, 2009. Handling of gateway was started on October 1, 2016.
submissions of electronic data and Q&A are shown Applicable clinical trial data should be submitted in
in the Handling of Electronic Specifications for the formats according to the specifications in
Common Technical Documents (Notification No. Clinical Data Interchange Standards Consortium.
0527004 of the Evaluation and Licensing Division,
1) Module 1: Administrative information such
PFSB dated May 27, 2004, partially revised by
as application forms and prescribing
Office Communication dated July 5, 2017).
information
On July 5, 2017, “Approval Applications using
(1) Application documentation table of
Electronic Common Technical Documents (eCTD)”
contents (including Module 1)
(Notification No. 0705-(1) of the Pharmaceutical
Evaluation Division of PSEHB) and Q&As (Office (i) Table of contents of application
Communications) was issued and mentioned the document including Part 1
partial revisions on preparation of eCTD according (ii) Synopsis

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Pharmaceutical Regulations in Japan:

(2) Approval application (copy) form for drugs other than biological
(3) Certificates (Declarations of those products should be tabulated and the
responsible for collection and list be attached to the application
compilation of data for approval document as directed in “CTD Format
applications, GLP and GCP related for Reducing Total Review Time for
data, contracts for codevelopment New Drugs” (Office Communication
[copies], and declarations required to of the Evaluation and Licensing
be attached in accordance with Division, PFSB dated January 17,
Notification No. 0527004 of the 2011).
Evaluation and Licensing Division, Review data on new additives, if any,
PFSB dated May 27, 2004 entitled should be included in the application
“Handling of Computer Formatting of dossier (copies) as directed in the
the Common Technical Document”). “Submission of Review Data on New
Additives” (Notice of the PMDA dated
(4) Patent status
June 23, 2017).
(5) Background of origin, discovery, and
<5> Points to consider in formatting the
development
eCTD
(6) Data related to conditions of use in
foreign countries, etc. 2) Module 2: Data summaries or CTD
“Gaiyo”
(7) List of related products
(1) Modules 2 to 5 (CTD) table of contents
(8) Package insert (draft)
(2) CTD introduction
(9) Documents concerning non-proprietary
name (3) Quality overall summary

(10) Data for review of designation as (4) Nonclinical overview


poisons, deleterious substances, etc. (5) Clinical overview
(11) Risk management plan (RMP) (draft): (6) Nonclinical summary (text and tables)
<1> Pharmacology
(12) List of attached documentation <2> Pharmacokinetics
(13) Other <3> Toxicity
<1> Data related to approved drugs (7) Clinical summary
<2> Clinical trial consultation records <1> Summary of biopharmaceutics and
(copies) associated analytical methods
<3> Inquiries (copies) and responses to <2> Summary of human pharmacology
inquiries (copies)
<3> Summary of clinical efficacy
<4> Other data [data submitted to the
<4> Summary of clinical safety
PMDA (copies), data submitted to the
<5> Literature references
MHLW (copies)]
Laboratory target and set values to <6> Synopses of individual studies
be entered in the manufacturing 3) Module 3: Quality
method column of the application

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Pharmaceutical Regulations in Japan:

(1) Module 3 table of contents to persons who participated in clinical studies


(2) Data or reports submitted as application data immediately after
application submission, prior to the expert meeting,
(3) Literature references
and prior to meeting of the Committee on Drugs.
4) Module 4: Nonclinical study reports
It was decided that the applicant should submit
(1) Module 4 table of contents the conversion factor, etc. for calculating the
(2) Study reports maximum daily use of drug additives during the
(3) Literature references process of application for marketing approval
(including application for a change) in order to
5) Module 5: Clinical study reports
enable appropriate management of the maximum
(1) Module 5 table of contents daily use of drug additives by the regulatory
(2) Tabular listing of all clinical studies authority. (Notification No. 1007001 of the Office of
(3) Clinical study reports Review Management, PMDA dated October 7,
(4) Literature references 2016).
(Fig. 11 Organization of ICH Common
Technical Documents). 2.1 Data to be Attached to Approval
Application of Drugs

Separately from CTD, submission of the 2.1.1 Prescription drugs


following documents is required at the time of The data required for approval application of
application for approval. prescription drugs according to drug classification is
• FD application document (sample), presented in Attached Tables 1 and 2-(1) of the
document of FD contents basic notification of application, “Approval
Applications for Drugs”(Notification No. 1121-(2) of
• Marketing license (copy)
the PFSB dated November 21, 2014).
• Application for examination for drug approval
(Table 3 Data to be Submitted with an
review
Application for Approval to Manufacture/Market: A
• Import contract or equivalent document
New Prescription Drug). Data corresponding to (1)
• MF registration certificate (copy) if MF is to (8-2), (9), and (10) to (10-4) in the application
used dossier are required to be prepared and submitted
• Contract with MF registrant regarding the by the CTD format. Attached documents can be
use of MF (copy) prepared in the conventional manner for (8-2) and
• List of persons involved in compilation of (10) to (10-4) until February 28, 2018.
attached data 2.1.2 Non-prescription drugs
• List of competitive products and companies The Law for Partial Amendment of the
• List of persons involved in competitive Pharmaceutical Affairs Law and the Pharmacists
products Law (Law No. 103, 2013) was enacted on June 12,
It is necessary to submit a "list of persons 2014, and a category of guidance-mandatory drugs
involved in compilation of attached data," a "list of was newly established in addition to the
competitive products and companies," and a "list of conventional categories of prescription drugs and
persons involved in competitive products" in relation non-prescription drugs. The range of data to be

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Pharmaceutical Regulations in Japan:

submitted with applications for non-prescription Two notifications were issued in relation to the
drugs is specified as shown in Table 4 (Data to be acceptance of foreign clinical data: “Handling of
Submitted with an Application for a Non-prescription Data on Clinical trials on Drugs Performed in
Drug) ( Notification No. 1121-(2) of the PFSB dated Foreign Countries” (Notification No. 739 of the
November 21, 2014). After complete enforcement PMSB dated August 11, 1998) and “Ethnic Factors
of the CTD (from July 1, 2003), the present to be Considered in the Acceptance of Foreign
guidelines for preparation of data to be attached to Clinical Trial Data” (Notification No. 672 of the
approval applications can be applied to approval Evaluation and Licensing Division, Pharmaceutical
applications for non-prescription drugs as in the and Medical Safety Bureau dated August 11, 1998
past. For the time being, data on the manufacturing and partial revision by Office Communication dated
method and specifications and test methods for January 4, 1999) and its Q and A (Office
non-prescription drugs with new active ingredients Communications dated February 25, 2004 and
are prepared using the CTD only for reference October 5, 2006). According to these notifications,
purpose. when data from clinical studies performed in foreign
countries are used for new drug application in
Japan, the data is first checked to assure that it
3. GUIDELINES CONCERNING DRUG
complies with legal requirements in Japan.
APPROVAL APPLICATIONS
Whether or not the drug is apt to be affected by
Guidelines outlining standard test methods and ethnic factors (intrinsic or extrinsic factors) is then
essential criteria for reference in the preparation of evaluated. When necessary, a bridging study is
data for drug manufacturing and marketing performed, and when it is concluded that the clinical
approval applications have been published in order study outcome in a foreign population can be
to assure efficient and appropriate research and extrapolated to the Japanese population, the
development. These guidelines have been foreign data can be accepted. Since the possibility
prepared on the basis of results of studies of acceptance is actually left up to the authorities
undertaken by groups of experts in the field concerned, it is recommended that the
concerned. requirements for bridging studies be confirmed as
In recent years, various standards and acceptable for the regulatory agencies through
guidelines have been established and implemented consultations with PMDA.
according to ICH harmonization and the reliability With the intent to promote global clinical trials to
and amount of research data has been achieve more efficient and rapid development of
internationally harmonized. To meet demands for new drugs and to eliminate drug lag in which the
more efficient and less costly development of new approval timing of new drugs is several years
drugs, international utilization of data is on the behind that in other countries, basic concepts
increase. related to global clinical trials have been compiled
Japan has taken various measures in keeping (Notification No. 0928010 of the Evaluation and
with this change in the international environment, Licensing Division, PFSB dated September 28,
and data from nonclinical studies such as 2007). In addition, the notice “Basic Principles on
physicochemical studies, stability studies and Global Clinical Trials (Reference Cases)” (Office
animal studies performed in foreign countries are Communication dated September 5, 2012) was
accepted, in principle, if their study designs comply issued based on achievements of mutual
with the Japanese guidelines. cooperation and latest knowledge obtained relating

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Pharmaceutical Regulations in Japan:

to multinational clinical trials among Japanese, granted overseas, sufficient experience of use
Chinese, and South Korean regulatory authorities in medical practice is available, scientific
with an objective of a smooth and appropriate evidence has been published in internationally
conduct of global clinical trials, especially in East reputable scientific journals, or review articles,
Asia. In addition, “Basic Approach to Conduct of etc. of international organizations can be
Phase I Clinical Trial in Japanese Before Start of obtained.
Global Clinical Trial” (Office Communication of the (3) Cases where there are clinical study results
Evaluation and Licensing Division of the PFSB, that can be confirmed in terms of ethics,
MHLW dated October 27, 2014) indicates points to science, and reliability by such means as
consider when examining whether or not a phase I contract research performed as part of public
clinical trial is necessary in the case where Japan research projects.
takes part in a global clinical trial.
The data attached to applications for approval to
Marketed drugs that have been used for
manufacture and market drugs must be in
unapproved indications or dosage and
Japanese, but as part of the deregulation process, it
administration in clinical practice (off-label use)
was specified in Notifications No. 256 of the PMSB
should be used appropriately by receiving
and No. 265 of the Evaluation and Licensing
marketing approval based on the Law. But in the
Division, PMSB, both dated March 18, 1998, that
cases the indications and dosage and
documents in English in Modules 3, 4, and 5 need
administration related to off-label use are confirmed
not be completely translated into Japanese as long
by medical and pharmaceutical knowledge in the
as a Japanese summary is attached. In approval
public domain, a judgment is made of whether or
applications using the CTD format, a Japanese
not the use can be approved without performing
summary is not required for entries in the original in
whole or part of the clinical trials again (Notifications
English.
No. 4 of the Research and Development Division,
Health Policy Bureau and No. 104 of the Evaluation
3.1 Nonclinical Studies
and Licensing Division, Pharmaceutical and
Medical Safety Bureau dated February 1, 1999). 1) Guidelines on physicochemical
After this notification was issued, applications based properties, specifications, and tests
on public knowledge have been filed and approved. methods
(1) Cases where an official approval of The contents of specifications and test methods
indication(s) unapproved in Japan has already in approval applications must include required test
been granted overseas (countries with items in reference to the specified test guidelines.
approval systems confirmed to be on the same For drugs with new active ingredients manufactured
level as the system in Japan or with by chemical synthesis, refer to “Setting of
corresponding systems; the same hereinafter), Specifications and Test Methods of New Drugs”
sufficient experience of use in medical practice (ICH Q6A) (Notification No. 568 of the Evaluation
is available, and data appended to the and Licensing Division, PMSB dated May 1, 2001)
application for the regulatory authorities can be For new biological products (biotechnological
obtained. products/drug products derived from living
(2) Cases where an official approval indication(s) organisms), refer to “Setting of Specifications and
unapproved in Japan has already been Test Methods of Biological Products
(biotechnological products/drug products derived

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from living organisms)” (ICH Q6B) (Notification No. formulation and storing conditions of a drug.
571 of the Evaluation and Licensing Division, The former guidelines for stability tests of
PMSB dated May 1, 2001). These guidelines on prescription drugs with new active ingredients
specifications and test methods were prepared (Notification No. 565 of the Evaluation and
based on ICH agreements. To achieve sufficient Licensing Division, PMSB dated May 1, 2001) has
utilization of ICH-Q6A and ICH-Q6B, it is necessary been abolished and new stability guidelines based
to harmonize the General Test, Processes and on ICH agreements have been established
Apparatus of Pharmacopoeia among ICH regions, (Revision of Stability Test Guidelines (ICH
and hence the Guidelines on Evaluation and Q1A(R2)). Photostability tests for drugs with new
Recommendation of Pharmacopoeial Texts for Use active ingredients and new combinations are
in the ICH Regions (Notification No. 0526001 of the performed on the basis of the Guidelines for
Evaluation and Licensing Division, PFSB dated Photostability Tests of New Bulk Drugs and New
May 26, 2009, No.1; ICH-Q4B) were issued. Preparations (ICH Q1B) (Notification No. 422 of the
Based on these guidelines, when it is judged that it Evaluation and Licensing Division, PAB dated May
is possible to utilize the pharmacopoeial texts in the 28, 1997). For drugs with new routes of
ICH regions, these texts can be used mutually in administration, stability tests must be performed as
accordance with the conditions set in annexes. specified in the Guidelines for Handling Results of
The guidelines shown in Table 6 have been Stability Tests of Drugs with New Routes of
revised or established concerning physicochemical Administration (ICH Q1C) (Notification No. 425 of
properties, specifications, and tests methods. the Evaluation and Licensing Division, PAB dated
May 28, 1997), and for biological products, stability
tests must be performed as specified in the
The quality standards published in the Japanese
Guidelines for Handling Results of Stability Tests of
Pharmacopoeia, Japan Pharmaceutical Codex, etc.
Biological Products (biotechnological products/drug
serve as references for specifications and test
products derived from living organisms) (ICH Q5C)
methods including content specifications,
(Notification No. 6 of the Evaluation and Licensing
identification, purity and assay.
Division, PMSB dated January 6, 1998).
For sustained-release drugs, refer to the
Concepts concerning simplification of stability
Guidelines for Design and Evaluation of
tests on a scientific basis have also been specified
Sustained-Release (Oral) Preparations (Notification
in Application of Bracketing and Matrixing Methods
No. 5 of the First Evaluation and Registration
in Stability Tests on Drug Substances and Drug
Division, PAB dated March 11, 1998) in addition to
Products (ICH Q1D) (Notification No. 0731004 of
the above guidelines.
the Evaluation and Licensing Division, PMSB dated
2) Guidelines for stability tests July 31, 2002, partially revised by Office
Stability tests for approval application of drugs Communication dated June 3, 2003).
are conducted to evaluate change in quality over For generic drugs, etc., standard methods for
time with various environment factors including long-term stability studies, stress stability studies
temperature, humidity or light, through which and accelerated stability studies are specified in the
necessary information may be obtained for Guidelines for Stability Tests Attached to Approval
establishing a period of retest of an active Applications to Manufacture or Import Drugs
pharmaceutical ingredient, an available period of a (Notification No. 165 of the PAB and No. 43 of the

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Pharmaceutical Regulations in Japan:

Evaluation and Licensing Division, PAB dated Dependence (Notification No. 383 of the Narcotics
February 15, 1991). Division, PAB dated June 7, 1978).

3) Guidelines for toxicity tests For biotechnological products, the guideline


“Nonclinical Safety Evaluation of Biotechnological
The notification entitled “Guidelines for Toxicity
Drugs” (Notification No. 0323-(1) of the Evaluation
Studies for Manufacturing (Importing) Approval
and Licensing Division, PFSB dated March 23,
Application of Drugs” (Notification No. 24 of the First
2012) should be referred to. For infection
Evaluation and Registration Division, PAB dated
prophylactic vaccines, refer to the guideline
September 11, 1989) was issued to establish the
“Nonclinical safety evaluation of prophylactic
“Guidelines for Toxicity Studies of Drugs” with the
vaccines (Notification No. 0527-(1) of the Evaluation
purpose of specifying standards how to conduct
and Licensing Division, PFSB dated May 27, 2010)
safety studies for approval application of drugs and
and for anti-malignant tumor agents, refer to the
contributing proper safety evaluation of drugs.
guideline “Nonclinical safety evaluation of
Based on ICH agreements, the guidelines shown in
anti-malignant tumor agents (Notification No.
Table 7 have been revised or established, and the
0604-(1) of the Evaluation and Licensing Division,
Guidelines for Toxicity Studies of Drugs have been
PFSB dated June 4, 2010).
replaced by these guidelines.
4) Good Laboratory Practice (GLP)
Data on the following studies that are required All toxicity tests conducted to support
for the review and evaluation of a new drug applications for new drug manufacturing and
application by the Ministry should be prepared and marketing approval and reexamination must be in
submitted in accordance with the above guidelines accordance with the Good Laboratory Practice
(Table 3 Data to be Submitted with an Application Standards for Safety Studies on Drugs (GLP).
for Approval to Manufacture/Market: A New (MHW Ordinance No. 21 dated March 26, 1997,
Prescription Drug): partially revised by MHLW Ordinance No. 114 dated
June 13, 2008) (Notification No. 902 of the
(1) Single dose toxicity studies
Evaluation and Licensing Division, PMSB dated
(2) Repeated dose toxicity studies
June 21, 2001 requires safety pharmacology
(3) Genotoxicity studies studies be performed in accordance with “the
(4) Carcinogenicity studies Guidelines on Safety Pharmacology Studies” to
(5) Reproductive and developmental toxicity comply with the GLP Ordinance.). Handling of the
studies ministerial ordinance for partial revision is noticed in
"Guidance on the Implementation of the Ministerial
(6) Skin irritation studies
Ordinance on the Good Laboratory Practice for
(7) Other toxicity studies
Nonclinical Safety Studies of Drugs as Revised by
Drug dependence studies were specified the Ministerial Ordinance for Partial Revision of the
separately from the toxicity guidelines in the Scope Ministerial Ordinance on the Good Laboratory
of Application and the Guidelines for Animal Studies Practice" (PFSB Notification No. 0613007 dated
and Clinical Observations on Drug Dependence June 13, 2008).
(Notification No. 113 of the Narcotics Division, PAB
This ordinance consists of eight chapters and 19
dated March 14, 1975) and the Guidelines for
articles as below:
Animal Studies and Clinical Observations on Drug

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Pharmaceutical Regulations in Japan:

Chapter 1 (Articles 1-4) Pharmaceutical GLP and Medical Device GLP”


Purpose of this ordinance, definition of (Notification No. 0620058 of PMDA dated June 20,
terms, responsibilities of sponsors 2008, Notification No. 0815007 of PMDA dated
August 15, 2008, and Notification No. 1121005 of
Chapter 2 (Article 5-8)
PMDA dated November 21, 2014) GLP
Responsibilities of management of testing
compliance conditions are evaluated in two
facilities, study directors and Quality
categories: compliant or non-compliant, based on
Assurance Units
the results of the GLP compliance review.
Chapter 3 (Articles 9 and 10)
Compliant: The inspected testing facility has
Structures, facilities and equipment of no items that deviate from GLP for
testing facilities drugs, etc. or, if it does, appropriate
Chapter 4 (Articles 11 and 12) improvement measures have been
Standard operating procedures in testing taken with respect to such aspects
facilities (prepared by management) and or the effects of such aspects on the
animal caretakers operation and management of
Chapter 5 (Articles 13 and 14) testing facility in general are
considered tolerable.
Handling of investigational products and
comparators
Non-compliant: The effects of items that
deviate from GLP for drugs, etc. at
Chapter 6 (Articles 15 and 16)
the inspected testing facility are not
Study protocols (prepared by study
tolerable and inspected testing
director) and proper conduct of studies. facility cannot be considered
Chapter 7 (Articles 17 and 18) compliant with GLP.
Final reports (prepared by study director) When evaluated as compliant in the GLP
and retention of study data compliance reviews, the results of the tests
Chapter 8 (Article 19) performed in the facility will be accepted, in

Requirements for conducting studies at


principle, for use as review data for a period of 3
years from the date of the GLP Compliance
more than one testing facilities
Confirmation Letter. These GLP requirements
Study facilities in which studies have been
also apply to data generated in other countries
conducted under the GLP ordinance
when they are used to support applications in
(GLP-compliant studies) must be inspected for
Japan. In principal, a judgment on the GLP
compliance with the GLP ordinance by PMDA
compliance of a trial conducted at a testing facility in
under contract with MHLW for approval review in
a foreign country is made based on data submitted
principle. In addition, only when the studies are
by a government agency, etc. of the foreign country
confirmed to be conducted at GLP-compliant
evidencing that the trial is conducted in accordance
facilities, data submitted for approval review will be
with GLP (Notification No. 1121-(9) of the
accepted as proper approval review data.
Evaluation and Licensing Division, PFSB and
GLP compliance reviews conducted by the
Notification No. 1121-(13) issued by the Councillor,
PMDA are performed on the basis of “the System
PFSB dated November 21, 2014).
of Guidelines for On-site Reviews Based on the
5) Guidelines for general

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Pharmaceutical Regulations in Japan:

pharmacological studies Evaluation and Licensing Division, PMSB dated


The results of primary pharmacodynamics June 4, 2001 entitled “Methods of Investigating
studies, secondary pharmacology studies, safety Drug Interactions”.
pharmacology studies, and studies of drug 6) Guidelines for pharmacokinetic
interactions may be required if necessary. studies
The guidelines shown in Table 8 have been
The guidelines shown in Table 9 have been
issued on pharmacology studies.
issued on pharmacokinetic studies.
The general policies for selection and planning
Pharmacokinetic data is useful in determining
of test systems to prepare data on safety
doses and other conditions for toxicity and
pharmacology studies are specified in the Safety
pharmacological tests in animals. Moreover, the
Pharmacology Study Guidelines (ICH-S7A)
assessment and understanding of these data may
(Notification No. 902 of the Evaluation and
provide very useful information for the assessment
Licensing Division, PMSB dated June 21, 2001)
of efficacy and safety in humans. The Guidelines
and it is required that safety pharmacology studies
on Nonclinical Pharmacokinetic Studies
are performed in accordance with the GLP
(Notification No. 496 of the Evaluation and
Ordinance as a rule. The objectives of the Safety
Licensing Division, PMSB dated June 26, 1998)
Pharmacology Study Guidelines are as follows and
were issued requiring applicants to study the
a research protocol that complies with these
absorption, distribution, metabolism, and excretion
objectives should be prepared. (1) Undesirable
of test drugs in animal and in vitro study systems to
pharmacodynamic properties of investigational
clarify their pharmacokinetic profile. The above
products considered to be related to safety in
guidelines have instructed the applicant to evaluate
humans must be specified; (2) adverse
the distribution in a single-dose study in principle
pharmacodynamic or pathophysiological actions of
and to use the Guideline for Repeated Dose Tissue
investigational products confirmed in toxicity studies
Distribution Studies (Notification No. 442 of the
or clinical studies must be evaluated; and (3) the
Evaluation and Licensing Division, PAB dated July
mechanisms of pharmacodynamic adverse actions
2, 1996; ICH S3B) for reference in terms of
confirmed to date or posing a risk must be
circumstances requiring repeated dose studies and
investigated.
actual conduct of the studies.
Secondary pharmacology studies to understand
the type and severity of pharmacological actions
and to clarify the pharmacological profile of the 7) Guidelines for bioequivalence studies
investigational product together with primary Although no guidelines are available for
pharmacology studies are performed with reference formulation changes during development, the
to the Guidelines for General Pharmacology guidelines shown in Table 10 may be applied where
Studies (Notification No. 4 of the New Drugs necessary, depending on timing and content of a
Division, PMSB dated January 29, 1991) change. In general, investigational drug products
(Notification No. 902 of the Evaluation and for late phase II clinical studies and subsequent
Licensing Division, PMSB dated June 21, 2001). ones are required to be equivalent to the
For other preparing data related to commercial ones.
pharmacodynamic drug interactions, reference
should be made to Notification No. 813 of the

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3.2 Clinical Studies important questions and answer them with the
results of carefully controlled clinical studies. The
1) Basic requirements
primary objectives of any study should be clear and
The primary objectives of clinical studies are to
explicitly stated.
evaluate therapeutic and prophylactic efficacy of
Clinical studies can be classified by their
investigational new drugs for target diseases or
objectives. The basic logic behind serially
symptoms as well as their risks and possible ADRs
conducted studies of a drug is that the results of
in humans, and ultimately to assess their clinical
prior studies should influence the protocols of later
usefulness based on a comparison of their efficacy
studies (Table 5 Classification of Clinical Studies
and safety. In performing clinical studies,
According to Objectives).
investigators must give scientific and ethical
consideration to the subjects' human rights to Following an ICH agreement to issue common
minimize their risk relative to the expected benefits. GCP for scientific and ethical conduct of clinical
studies in three regions, the MHLW Ordinance on
Guidance concerning drug development
Standards for Implementation of Clinical Studies on
strategies and evaluation processes has been
Drugs (GCP) (MHW Ordinance No. 28 dated
issued in the three ICH regions. In 1998, General
March 27, 1997, partial revision by MHLW
Considerations for Clinical Studies (Notification No.
Ordinance No. 9 dated January 22, 2016) was
380 of the Evaluation and Licensing Division,
issued with the aims of specifying the requirements
PMSB dated April 21, 1998, ICH E8) was prepared
for the planning, conduct, monitoring, auditing,
as one aspect of MHLW’s efforts to promote
records, analysis, and reports of clinical studies
international harmonization of approval review data
performed to collect data to be submitted with
for new drugs. This notification consists of the
applications for approval to manufacture and
objective of the guidelines, general principles
market drugs; to protect the human rights, safety,
(protection of clinical trial subjects and scientific
and welfare of study subjects; and to assure the
approach in design and analysis) and development
scientific quality of the study and the reliability of its
methods (points to consider for development plans
results.
and for individual clinical studies).
The importance of precision control of laboratory
In order to protect the study subjects these
data in clinical trial to ensure the reliability of
Guidelines specify that, as a condition to start a
laboratory data and the trial is shown in “the Basic
clinical study, the safety of the drug must be shown
Concept of Precision Control of Laboratory Data in
from nonclinical studies or previous human studies.
Clinical Trial” (Office Communication of the
Throughout drug development, qualified clinicians
Evaluation and Licensing Division, PFSB dated July
and other experts should review and evaluate all
1, 2013).
newly obtained data from toxicity studies on animals
and human studies to assess their implications for 2) Considerations for the development
the safety of the subjects. plan
Clinical studies should be designed, conducted, 2.1) Nonclinical studies
and analyzed in keeping with sound scientific
Important considerations for determining
principles in order to achieve their objectives, and
the nature of nonclinical studies and their
they should be reported appropriately. The
timing with respect to clinical studies include:
essence of rational drug development is to pose
(1) Duration and total exposure (dose) in

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individual patients including pharmacological effects on


(2) Characteristics of the drug major organ systems and physiological
processes.
(3) Disease or condition targeted for
treatment (5) Absorption, distribution, metabolism, and
excretion
(4) Use in special populations
(5) Route of administration 2.2) Quality of investigational products
The actual timing of each nonclinical safety Products used in clinical studies should be well
study is specified in the Guidelines on Nonclinical characterized, with information on bioavailability
Safety Studies for the Conduct of Human Clinical wherever feasible. The product should be
Trials and Marketing Authorization for appropriate for the stage of drug development.
Pharmaceuticals (Notification No. 0219-(4) issued Ideally, the preparation should be adequate to allow
by the Evaluation and Licensing Division of PFSB testing in a series of studies that examine a range of
dated February 19, 2010: ICH M3R(R2), and Office doses.
Communication (Q&A on the guidelines) dated For investigational products, on July 9, 2008, the
August 16, 2012). Investigational Product GMP was revised to allow
the quality assurance of an investigational product
(i) Safety studies
according to the phase of a clinical trial in
For the first studies in humans, the dose
consideration of characteristics of the trial, including
used should be determined by careful
ones at an early exploratory stage (Notification No.
examination of the prerequisite nonclinical
0709002 of PFSB). Subsequently, the Q&A on the
pharmacological and toxicological
Investigational Product GMP was released (Office
evaluations. Early nonclinical studies
Communication of Compliance and Narcotics
should provide sufficient information to
Division, PFSB dated July 2, 2009).
support selection of the initial human dose
and safe duration of exposure, to provide 2.3) Phases of clinical development
information about the physiological and Clinical studies have been conventionally
toxicological effects of a new drug. classified by phase of development (I to IV).
The ICH conference proposed a new
(ii) Pharmacological studies
classification system according to the
The basis and direction of the clinical
objective of studies as described in the
exploration and development rests on the
General Considerations for Clinical Studies
nonclinical pharmacology profile, which
(Notification No. 380 of the Evaluation and
includes the following information:
Licensing Division, PMSB dated April 21,
(1) Pharmacological basis of principal 1998, ICH E8), and according to this system
effects (mechanism of action). clinical studies are classified to the following
(2) Dose-response or four types:
concentration-response relationships (1) Human pharmacology studies
and duration of action.
(2) Therapeutic exploratory studies
(3) Study of the potential clinical routes of
(3) Therapeutic confirmatory studies
administration.
(4) Therapeutic use studies
(4) Systemic general pharmacology,

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Pharmaceutical Regulations in Japan:

Objectives and types of studies in these four Clinical Pharmacokinetic Studies on Drugs
categories are listed in Table 5 (Classification of (Notification No. 796 of the Evaluation and
Clinical Studies According to Objectives) and the Licensing Division, PMSB dated June 1,
close but variable correlations between the 2001) and Guidance on Ensuring Safety of
development phase and study type are shown in Human Subjects in the Initial Clinical Trial of
Fig. 12 (Correlation between Development Phases New Investigational Medicinal Product
and Types of Study). (Notification No. 0402-(1) of the Evaluation
The distribution of the circles, open circles and and Licensing Division, PFSB dated April 2,
shaded circles, in the figure shows that the types of 2012).
study do not automatically define the phases of (ii) Phase II (typical study: therapeutic
development. exploratory)
Clinical development is ideally a step-wise Phase II is usually considered to be the
process in which information from small early phase in which studies with the primary
studies is used to support and plan later larger, objective of exploring therapeutic efficacy in
more definitive studies. To develop new drugs patients are initiated. The most typical
efficiently, it is essential to identify characteristics of Phase II study is the therapeutic exploratory
the investigational product in the early stages of study performed on a group of patients who
development and to plan appropriate development are entered into the study according to
based on this profile. The four clinical clearly defined criteria and whose condition
development phases are described below. is monitored. An important goal for this
(i) Phase I (typical study: clinical phase is to determine the dose(s) and
pharmacology) regimen for Phase III studies. Dose
response designs should be used to assess
Phase I entails the initial administration of
and confirm the dose-response relation for
an investigational new drug to humans.
the indication concerned. Additional
The most typical study is that on clinical
objectives of Phase II clinical studies include
pharmacology. Although clinical
evaluation of study endpoints, therapeutic
pharmacology studies are typically identified
regimens (including concomitant medication)
with Phase I, they may also be indicated at
or target populations for further study in
other points in the development sequence.
Phase II or III.
Studies conducted in Phase I typically
involve one or a combination of the following (iii) Phase III (typical study: therapeutic
aspects: confirmatory)
(1) Estimation of initial safety and tolerability The primary objective of Phase III studies
(2) Characterization of pharmacokinetics is to confirm the therapeutic effects.
Studies in Phase III are designed to confirm
(3) Assessment of pharmacodynamics
the preliminary evidence accumulated in
(4) Early assessment of efficacy
Phase I and II that a drug is safe and
As a reference, the basic concepts effective for use in the proposed indication
concerning the study items and conduct of all and recipient population. These studies are
clinical pharmacokinetic studies for the intended to provide data to serve as an
purpose of drug development are given in

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adequate basis for manufacturing approval. (i) Studies of drug metabolites


“Arrangements for supplying and The main metabolites must be identified
receiving of control drugs” were established and detailed pharmacokinetic studies
as voluntary arrangements among member performed. The timing for studies to evaluate
companies of the JPMA in July 1981 for the metabolism is decided in accordance with
smooth supply and receipt of control drugs the characteristics of the drug concerned.
by the companies developing new drugs and
(ii) Drug interactions
the manufacturing/marketing authorization
If a potential for drug interaction is
holders of control drugs when
suggested by the metabolism profile, by the
pharmaceutical companies developing new
results of nonclinical studies or by
drugs evaluate efficacy and safety of new
information on similar drugs, studies on drug
drugs with approved drugs already on the
interaction are highly recommended. To
market as controls. After four subsequent
explore interaction with the drugs that are
revisions, the most recent version appeared
frequently coadministered, it is usually
on November 1, 2005.
important that drug interaction studies be
(iv) Phase IV (various types of study: performed in nonclinical and, if appropriate,
therapeutic use) in clinical studies.
The Phase IV studies are conducted after
(iii) Special populations
approval to confirm therapeutic efficacy and
Some groups in the general population
safety when used for the proposed indication
may require special study because they
and targeted population in general clinical
deserve unique risk/benefit considerations,
practice. Studies include clinical
or because they may need modification of
experience surveillance to assess the
use of a drug or schedule of a drug
incidence of adverse drug reactions, special
compared to general adult use.
survey to assess efficacy and safety in
Pharmacokinetic studies in patients with
special populations, and post-marketing
renal and hepatic dysfunction are important
clinical trials to obtain additional information.
to assess the impact of the potentially altered
2.4) Studies concerning new indications, drug metabolism or excretion. Other special
new dosage regimens, etc. populations are as follows:
Development of additional indications, (1) Elderly.
dose levels, dosage regimens,
(2) Ethnic populations.
administration routes, etc. requires new
(3) Pregnant women.
protocols for both clinical and nonclinical
studies. Human pharmacology may also be (4) Nursing women.
necessary for application. (5) Children.

2.5) Special considerations (iv) Microdose studies


Consideration should be given to special Clinical studies to obtain information on
circumstances and populations when they pharmacokinetics of the investigational
are targeted as part of the development plan. product in humans and desired information
at the preclinical stage in development

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Pharmaceutical Regulations in Japan:

candidate screening studies based on (3) Number of subjects.


pharmacokinetic information. A dose not (4) Safety and efficacy variables.
exceeding 1/100 of the dose expressing
(5) Methods to minimize bias
pharmacological effects or a dose of 100
(randomization, blinding, and
µg/human, whichever is smaller, is
compliance).
administered once to healthy subjects. The
range of application is mainly low molecular 3.3) Conduct
weight compounds. Even though test The study should be conducted according
doses are extremely low, microdose studies to the principles described in the General
must also be conducted in accordance with Considerations for Clinical Studies or in
the cGCP. Basic concepts for the accordance with other pertinent elements
microdose studies, including points to outlined in the GCP or other guidelines related
consider, are given in the Guidance for to clinical studies. Adherence to the study
Conducting Microdose Clinical Studies protocol is essential.
(Notification No. 0603001 of the Evaluation 3.4) Analysis
and Licensing Division, PFSB dated June 3,
The study protocol should cite a specified
2008).
analysis plan that is appropriate for the
3) Considerations for Individual Clinical objectives and design of the study. Methods
Studies of analysis of the primary endpoints and
The following important principles should be surrogate endpoints should be included in the
followed in planning the objectives, design, protocol. The results of the clinical study
conduct, analysis and reporting of a clinical should be analyzed in accordance with the
study. Each item from the objectives to plan prospectively stated in the protocol.
reporting should be defined in a written 3.5) Reporting
protocol before the study starts.
Clinical study reports should be
3.1) Objectives appropriately prepared in accordance with the
The objective(s) of the study should be Structure and Content of Clinical Study
clearly stated. They may include exploratory Reports (Notification No.335 of the Evaluation
or confirmatory characterization of the safety and Licensing Division, PAB dated May 1,
and/or efficacy and/or assessment of 1996: ICH E3).
pharmacological, physiological or biochemical 4) Statistical analysis of clinical study
effects. results
3.2) Design The MHW (currently MHLW) published the
The appropriate study design should be Guidelines for Statistical Analysis of Clinical
chosen to provide the desired information in Study Results (Notification No. 20 of the New
consideration of the following points by Drugs Division, PAB dated March 4, 1992)
referring to relevant clinical guidelines: which list examples of misuse of statistical
(1) Selection of subjects. methods and indicate the methods which are
considered most appropriate then to prevent
(2) Selection of control group.
errors and scientifically assess drug efficacy.

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Pharmaceutical Regulations in Japan:

The ICH guidelines, Statistical studies. Therefore, these guidelines should


Considerations in the Design of Clinical Trials be applied to all phases of clinical development
(ICH E9) (Notification No. 1047 of the whenever feasible.
Evaluation and Licensing Division, PMSB
5) Guidelines for clinical evaluation
dated November 30, 1998), have been
Data on the results of clinical studies must
published to replace Notification No. 20 issued
be analyzed precisely and objectively as they
in 1992. The new guidelines are intended to
are the means of identifying the drug's
propose approaches when the sponsor
expected efficacy and ADRs, when the drug is
designs, conducts, analyzes and assesses a
used, thereby playing an important role in the
clinical study of an investigational product as
evaluation process by the regulatory authority.
part of the overall clinical development.
These guidelines should attract interest from Guidelines on the methodology for clinical
individuals in many fields of science, and they studies and the evaluation criteria have been
state as a prerequisite that the actual published as "the Guidelines for Clinical
responsibility for all statistical work related to a Evaluation." The results from ICH are also
clinical study should be borne by statisticians introduced into Japanese regulations as ICH
with appropriate qualifications and experience. guidelines.
The participation of statisticians is intended to Guidelines for clinical evaluation of drugs
verify together with other clinical study experts classified by therapeutic category, guidelines
that statistical principles have been for clinical evaluation in general, and other
appropriately applied in the study to support guidelines have been issued as shown in Table
drug development. Therefore, to implement 11.
the principles explicitly stated in these 6) GCP
guidelines, the statisticians must combine
The first GCP, Standards for Conduct of
adequate theoretical and practical education
Clinical Trials on Drugs, intended to assure
and experience. The principles stated in
that clinical studies are performed on the basis
these guidelines are meant primarily to be
of ethical considerations and from the proper
applied in the latter half of development, mainly
scientific standpoint were issued as Notification
in therapeutic confirmatory studies.
No. 874 of the PAB dated October 2, 1989, and
In confirmatory studies, the primary this GCP was applied in the form of
variables are not limited to those related to administrative guidance from October 1, 1990.
efficacy but may include those concerning Thereafter, the MHW undertook various
safety, pharmacodynamics and studies to improve the quality of clinical studies
pharmacokinetics. In addition, some of the in Japan in accordance with changes in the
confirmatory knowledge is derived from data international regulatory situation, and a new
compiled for several studies, and under such GCP was issued as an MHW ordinance (No.
conditions, some of the principles in the 28, March 27, 1997) based on a report of the
guidelines are applied. The studies in the Central Pharmaceutical Affairs Council (March
initial phases of drug development mainly 13, 1997). This new GCP, which is legally
involve therapeutic exploratory studies, but binding, went into effect from April 1, 1997.
statistical principles are also applied to these
The Ministerial Ordinance on the GCP was

2018 - 83 -
Pharmaceutical Regulations in Japan:

amended thereafter (newest revision: MHLW manufactured in factories applying appropriate


Ordinance No. 9 dated January 22, 2016), and manufacturing control and quality control methods
the current GCP Ordinance is comprised of 6 and with the buildings and facilities required to
chapters and 59 articles. The contents are assure the quality of the investigational product.
briefly divided into the 3 parts consisting of To that end, requirements for manufacturing
"Standards for sponsoring clinical trials" and investigational products have been issued in the
“Standards concerning management of clinical form of Notification No. 480 of the PAB dated March
trials” for persons intending to request or 31, 1997 entitled "Standards for Manufacturing
conduct a clinical trial, and “Standards for Control and Quality Control of Investigational
conduct of clinical trials” for medical Products and Standards for Buildings and Facilities
institutions. of Plants Manufacturing Investigational Products" in
A compassionate use system making order to assure the reliability of clinical studies by
unapproved drugs available for patients not eligible guaranteeing the quality of investigational products
for ongoing trials of these drugs was introduced and to protect subjects from poor quality
(Notification No. 0122-(7) of the Evaluation and investigational products. In light of the specificities
Licensing Division, PSEHB dated January 22, of the investigational product, such as the use in an
2016). early exploratory development phase, Standards for
Manufacturing Control and Quality Control of
The system is established on the following
Investigational Products and Standards for
premises: the applicable unapproved drugs are to
Buildings and Facilities of Plants Manufacturing
be indicated for diseases for which no effective
Investigational Products (“new” Investigational
conventional treatment is available; they are
Product GMP) were issued in the form of
clinically used in consideration of balance between
Notification No. 0709002 of the PFSB on July 9,
the relevant risk and expected therapeutic benefit;
2008 as a replacement of the old Investigational
and such use does not interfere with development
Product GMP in order to assure the quality of
of the concerned drug.
investigational products depending on development
By this system, an investigational product after
phase. In addition to the protection of human
conduct of a trial at the final development phase in
subjects and reliability assurance of clinical trials,
Japan (which is regularly intended to verify the
the new regulations aim to ensure not only the
efficacy and safety after the indications as well as
efficacy and safety of drug product but also
dosage and administration have been set through a
adequateness of clinical studies themselves in the
series of development operations, or called as a
post-marketing phase by securing pharmaceutical
pivotal trial) or while such trial is ongoing (but after
consistency between the investigational product
completion of the enrollment) is made available in a
and marketed product following the final selection of
framework of a trial in patients with the above
research compound to be developed and by
diseases.
assuring the equivalence between the two products
7) Investigational Product GMP following the establishment of manufacturing
In Article 17, Supply of the Investigational method and test methods of investigational product.
Product, in the GCP ordinance, it specifies that the Q&A on the standards for manufacturing control
sponsor shall supply to the medical institution and quality control of investigational products
performing the study investigational product (Investigational Product GMP) were published in
Office Communication dated July 2, 2009.

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Pharmaceutical Regulations in Japan:

The Investigational Product GMP is applied to all The requirements for manufacturing control and
investigational products used in clinical studies quality control methods for drug substances are
conducted in accordance with the GCP ordinance. specified in the Guidelines on GMP for Drug
The GMP is a set of requirements to be followed by Substances (ICH Q7A, currently Q7) (Notification
the study sponsor and investigators and also No. 1200 dated November 2, 2001), which includes
applied to investigational products manufactured at 20 requirements for drug substances including
foreign facilities. The system/procedure-related quality management, buildings and facilities, and
provisions of the Investigational Product GMP validation, as approved at ICH5 held in San Diego
require the sponsor to establish investigational in November 2000.
product manufacturing division and investigational Further, the adoption of the Pharmaceutical
product quality control division at each Inspection Convention and Pharmaceutical
manufacturing facility. The release of Inspection Co-operation Scheme (jointly referred to
investigational product from factory must be judged as PIC/S) Guidelines in Japan has been proposed
by personnel of the quality control division by the Ministry in light of the need for international
designated for individual investigational product harmonization and other reasons (Office
items. The provisions require the preparation and Communication dated February 1, 2012).
retention of documents pertaining to
Since requests from overseas regulatory
ingredients/quantities, specifications, test methods,
authorities to submit investigational product GMP
manufacturing procedures, etc. for each
certificates are made when a clinical study is
investigational product item and those pertaining to
performed overseas using an investigational
manufacturing hygiene control procedures,
product produced in Japan for a global clinical trial,
manufacturing control procedures, and
the issue of such certificates is specified in the
manufacturing control procedures for each
“Supply of investigational product GMP certificates”
manufacturing facility. It is also required to prepare
(Office Communication dated March 30, 2009) and
and retain documents standardizing manufacturing
the procedures for requesting the issue of
and quality control. The GMP also contains
investigational product GMP certificates are given in
provisions concerning the use of contract testing
the “Procedures for Issuing Investigational Product
facilities, validation/verification, change control,
GMP Certificates” (Notification No. 0330023 dated
deviation control, quality test results, handling of
March 30, 2009).
inferior quality products, recall, self-inspections,
education/training, document/record control,
contracted manufacture, buildings/facilities 4. OTHER
manufacturing investigational products, etc. 4.1 Biotechnological Products
The building/facility-related provisions of the The Guidelines for Manufacturing Drugs by
Investigational Product GMP specify requirements using Recombinant DNA Technology were
for individual facilities manufacturing investigational published to ensure manufacturing safety of
products other than bulk products, investigational products during the manufacture of
bulk products, investigational sterile preparations, pharmaceuticals with recombinant DNA
investigational sterile bulk product, investigational technology (Notification No. 1051 of the PAB
biological products and investigational blood dated December 11, 1986, partially revised by
products. Notification Nos. 434 and 769 of the PAB dated

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Pharmaceutical Regulations in Japan:

May 21, 1987 and August 18, 1995, respectively). Division, PAB dated June 6, 1988. After that, the
The guidelines specify methods of safety above notifications were reconsidered on the
evaluation of recombinants (live cells), classify the basis of marked advancement of gene
level of each working process into four levels, i.e. recombinant technology, cell culture technology
GILSP (Good Industrial Large Scale Practice), and other scientific technology as well as the
Category 1, Category 2, and Category 3, at the knowledge of quality, safety and efficacy of
manufacturing stage based on the degree of biological products accumulated to date, and
safety, identify the type of facilities and equipment "Approval Application Category of Biotechnology
necessary for the manufacture, and also specify Products and Procedure for Preparation of
the requirements for the establishment of an Attached Documents Necessary for Approval
institutional biosafety committee, the appointment Application" (Notification No. 0705-(5) of the
of a biological safety officer (BSO), and Pharmaceutical Evaluation Division, PSEHB
supervision by a product security pharmacist. dated July 5, 2017) was issued.
Thereafter, based on the Law for Securing Various guidelines have been issued for
Multiplicity of Living Organisms under the Use biotechnology products on the basis of discussion
Control of Genetically-Engineered Living at ICH (Table 12). There are other notifications
Organisms (so-called “Cartagena Law”) (Law No. issued in relation to medicinal products to be
97 dated June 18, 2003), the MHLW Ordinance developed and manufactured by using cells and
on Measures to Prevent Spread of Industrial Use tissues and those products for gene therapy
among Secondary Uses of (Table 12).
Genetically-Engineered Living Organisms
(Ordinance No. 1 of the Ministry of Finance, 4.2 Drugs Using Materials of Human or
MHLW, Ministry of Agriculture, Forestry and Animal Origin as Ingredients (Biological
Fisheries, Ministry of Economy, Trade and Products)
Industry and Ministry of Environment dated
It is necessary to take measures to assure
January 29, 2004; partially revised in Ordinance
quality and safety based on current scientific levels
No. 2 dated June 6, 2006) was enforced on
for drugs manufactured using materials of human or
February 19, 2004 (the preceding guidelines were
animal origin as raw materials. Therefore, the
replaced by the Ordinance).
Biotechnology Committee of the Pharmaceutical
Separately, a notification entitled “Preparation
Affairs and Food Sanitation Council established
of Data Required for Approval Applications for
“Basic Concepts for Handling and Use of Drugs
Drugs Manufactured by Using Recombinant DNA
and Devices Utilizing Cells or Tissues” (December
Technology” was issued as Notification No. 243 of
1, 2000) and “the Guidelines for Assurance of
the Evaluation and Regulation Division, PAB
Quality and Safety of Drugs and Devices
dated March 30, 1984 for the evaluation of the
Processed from Cells and Tissues of Human
quality, efficacy, and safety of drugs produced by
Origin” (December 1, 2000) (Notification No. 1314
recombinant DNA technology, and then
of the PMSB dated December 26, 2000). In
“Preparation of Data Required for Approvals
addition, various notifications have been issued,
Applications for Drugs Manufactured by Cell
manufacturers have been requested to undertake
Culture Technology” was issued as Notification
self-inspection and coordinate application
No. 10 of the First Evaluation and Regulation
documents, and safety measures have been

2018 - 86 -
Pharmaceutical Regulations in Japan:

specified. For ingredients of bovine origin in Efficacy, and Safety Evaluation Methods for
particular, notifications have been issued as Biosimilars” was established with funding from
required in accordance with worldwide risk MHLW, and the Guidelines on the Assurance of
conditions and measures to assure quality and Quality, Efficacy, and Safety of Biosimilar Products
safety have been strengthened (refer to “Safety were formulated (Notification No. 0304007 of the
Measures for Bovine Spongiform Encephalopathy Evaluation and Licensing Division, PFSB dated
[BSE]” in Section 6.4, Chapter 2). Biological March 4, 2009). Biosimilars are defined as drugs
products and specified biological products were developed by different marketing authorization
newly defined in the revised Pharmaceutical Affairs holders as drugs with the same quality, efficacy,
Law dated July 31, 2002 and measures to assure and safety as biotechnological products already
safety when there is a risk of infection have been approved as drugs with new active ingredients in
designated. The Standards for Biological Japan. “Biosimilar” does not mean that the drug
Materials were specified in May 2003 and has exactly the same quality with the original
specifications for raw materials and packaging biotechnological product, but that they are highly
materials used in the manufacture of biological similar in quality and characteristics and even if
products or raw materials and packaging materials there are differences in quality and characteristics,
manufactured from biological materials and used in the differences can be scientifically judged not
the manufacturing process for drugs, quasi-drugs, leading to any unintended effects on the efficacy
cosmetics and medical devices based on the Law and safety profiles of the final product. To prove
were designated (Notice No. 210 issued by the the comparability, appropriate studies are
MHLW in 2003). necessary based on the concepts in the ICH Q5E
In 2013, regenerative medicine products were guidelines “Comparability of Biotechnological/
characterized in the law separately from drugs or Biological Products Subject to Changes in their
medical devices, and biological materials used in Manufacturing Process.” It is also necessary to
regenerative medicine products have been evaluate the comparability of biosimilars using
discussed to be standardized. In conjunction with clinical studies.
global trends for the BSE risk in bovine-derived raw Q&A on the Guidelines on the Assurance of
materials or the like in addition to the above, the Quality, Efficacy, and Safety of Biosimilar Products
Standards for Biological Materials were partially were published (Office Communication dated July
amended (Notice No. 375, issued by MHLW in 21, 2009, Office Communication dated March 31,
2014). 2010, and Office Communication dated December
15, 2015). Views of the regulatory authorities on
4.3 Biosimilar Products timing, definitions of equivalent products,
evaluations of comparability, development of
With the advances made in biotechnological
formulations and test methods, and safety
products, the development of similar
evaluations for biosimilar applications are included.
biotechnological products (biosimilar products or
follow-on biologics) equivalent to and the same The application for a biosimilar product is
quality as existing biotechnological products is required to contain detailed procedures and
being promoted overseas. Based on such programs of postmarketing surveillance and risk
technological advances, a Health Sciences Council management as directed in Appendix 9 of the
Research Project entitled “Research on Quality, Guidelines on the Assurance of Quality, Efficacy,

2018 - 87 -
Pharmaceutical Regulations in Japan:

and Safety of Biosimilar Products (Notification No. ews/approved-information/drugs/0001.html


0304007 of the Evaluation and Licensing Division, “A Joint Position on the Disclosure of Clinical
PFSB dated March 4, 2009). However, the Trial Information via Clinical Trial Registries and
Guidelines on the Risk Management Plan (RMP) Databases” was issued on January 6, 2005 as a
issued later (Notification No. 0426-(2) of the joint communiqué by four organizations:
Evaluation and Licensing Division, PFSB dated International Federation of Pharmaceutical
April 26, 2012) requires to attach an RMP, in place Manufacturers Associations (IFPMA),
of post-marketing surveillance plan, to be included Pharmaceutical Research and Manufacturers of
in the biosimilar product application submitted on or America (PhRMA), European Federation of
after April 1, 2013. Pharmaceutical Industry Associations (EFPIA) and
Japan Pharmaceutical Manufacturers Association
4.4 Public Disclosure of Information on New (JPMA). The communiqué declared that
Drug Development registration for all clinical trials except exploratory
A notification concerning publication of studies must be disclosed and information on the
information on new drug approvals was issued results of all studies (except exploratory studies) on
(Notification No. 1651 of the Evaluation and drugs approved or marketed in at least one foreign
Licensing Division, PMSB dated November 11, country must be disclosed.
1999), and New Drug Approval Information Based on this declaration, the Ministry of
Packages containing summary reviews prepared Education, Culture, Sports, Science and
by the MHLW and nonclinical and clinical data Technology in Japan initiated the UMIN Clinical
submitted by the applicant have been published. Trial Registration System (UMIN-CTR;
Thereafter, the methods of submitting data for http://www.umin.ac.jp/ctr/index-j.htm) and the
application were changed as specified in MHLW publishes information concerning nonclinical
“Disclosure of Information Concerning Approval trials via “Clinical trial information”
Reviews of New Drugs” (Notification No. 0529003 (http://www.japic.or.jp/index.html), a database for
of the Evaluation and Licensing Division, PMDA registration and disclosure of clinical trial information
dated May 29, 2002). Basic procedures for through cooperation with the Japan Pharmaceutical
submission and disclosure have also been Information Center and JPMA.
specified (Notification No. 0422001 of the Using these systems, pharmaceutical
Evaluating and Licensing Division, PFSB dated companies disclose information on nonclinical trials
April 22, 2005, Notification No. 0422004 of the with adequate consideration given to privacy of
PMDA dated April 22, 2005, Notification No. individual subjects, intellectual property rights, and
1126005 of the Licensing and Evaluation Division of contractual rights in order to improve the
PFSB dated November 26, 2007, and Notification transparency of clinical trials.
No. 0325-(1) of the Evaluation and Licensing In a system unique to Japan, information on
Division, PFSB dated March 25, 2013). institutional review boards is made public voluntarily
Information on approval reviews for new drugs is (Notification No 1001013 of the Evaluation and
provided on the following homepages: Japanese: Licensing Division, PFSB dated October 1, 2008
http://www.pmda.go.jp/PmdaSearch/iyakuSearch/, and Office Communication dated April 2, 2009).
English (part of product items):
https://www.pmda.go.jp/english/review-services/revi 4.5 ICH (International Conference on

2018 - 88 -
Pharmaceutical Regulations in Japan:

Harmonization of Technical Step 2b: Consensus among regulatory


Requirements for Registration of authorities regarding public
Pharmaceuticals for Human Use) consultation in each ICH region
ICH was established in April 1990 by six parties, Step 3: Regulatory consultation in the three
i.e., regulatory authorities and industry groups of regions, call for public comments,
Japan, the United States, and Europe, with the aim and revision of the draft guidelines
of promptly supplying safe and effective new drugs based on comments received
to the patients who need them. The ICH Steering Step 4: Sign-off and adoption of the
Committee consists of six original parties of EU, guidelines
EFPIA, MHLW, JPMA, FDA, PhRMA as well as Step 5: Regulatory implementation of the
Swissmedic and Health Canada. In addition, guidelines according to regional
WHO and IFPMA participate as an observer and a requirements
member (without the vote), respectively. To
Currently, over 70 topics (guidelines), including
discuss issues on an individual basis, expert
revised versions, have been agreed and approved
working groups (EWGs) consisting of specialists
(Step 4 or 5) based on ICH activities. As shown in
and government officials from organizations were
Table 13 (ICH topics and guidelines - Progress of
established. Furthermore, in an attempt to cope
harmonization).
with increasingly globalized drug development and
Visit the following homepage for details of ICH
regulations, organizational reform took place in
guidelines.
October 2015, and a new ICH corporation was
established as an international nonprofit corporation Japanese:
under the SWISS ACT to enhance further https://www.pmda.go.jp/int-activities/int-harmony/ich
international harmonization of pharmaceutical /0014.html
affairs. English:
At present, it is made up of the general assembly http://www.ich.org/home.html
which consists of all members and serves as the
main body of the organization, the management
committee responsible for preparation for
discussion in the general assembly as well as for
operation of the organization, and working groups in
which specialists discuss the guidelines.
New ICH harmonization is conducted by the
following five steps.
Step 1: Selection and analysis of topics to
be addressed, analysis of issues,
establishment of EWGs, and
preparation of draft ICH guidelines
Step 2a: Consensus of regulatory authorities
and industry groups regarding
technical documents

2018 - 89 -
Pharmaceutical Regulations in Japan:

Basic investigation

Screening tests

Study of manufacturing techniques/formulation and pharmaceutical research

Nonclinical studies
1. Physicochemistry
2. Toxicity on GLP Ministry proper PMDA
3. Pharmacology & pharmacokinetics
Clinical trial consultation
Evaluation of nonclinical studies
Handling of clinical Receipt of the
Clinical trial notification to PMDA trial notification notification
Clinical studies
(Studies based on GCP)
1. Phase 1 Guidance as Review of the
2. Phase 2 investigation notification
3. Phase 3 required

Evaluation of clinical and nonclinical studies

New drug approval application

Approval
review Pharmaceutical Affairs PMDA
and Food Sanitation
Council (PAFSC) Consultation Approval Compliance review
review
Experts GMP review
Advice
Notice of
review results
Evaluation committees MHLW
Pharmaceutical Inquiry (Pharmaceutical
Affairs Sections
Minister of MHLW
Evaluation Div,
PFSB)
(final evaluation)
Response

Approval and entry in NHI Price List

Post-marketing (GVP・GPSP ordinances) PMDA


surveillance 1. Collection, documentation, and storing of PMS survey results
(PMS) 2. Postmarketing clinical studies Compliance review
3. Reexamination (PBRER, etc.)
4. Reevaluation

Fig. 8 Flowchart of New Drug Development and Approval

2018 - 90 -
Pharmaceutical Regulations in Japan:

Timeline of the standard process of new drug approval (ordinary review products)

The following timeline shows a rough indication of review timeNote 1) for individual review process,
according to the past records of approval reviews, to achieve the target total review time of 12 months
(ordinary review products) from application to approval for new drugs for which applications are made
from FY2014, assuming that no specific time-consuming situation may occur during the review.

Rough indication of review time


25 percentile~ 2.3~2.4~2.8 mo 0.5~0.6~0.7 mo 5.1~5.7~6.8 mo 1.2~1.5~2.0 mo 0.7~0.9~1.6 mo
median~75 percentile

Questions on key issuesNote 2)


Applicant

Initial interview meeting

Manufacturing/marketing authorization
Expert review

Review report
Application
PMDA

Compliance review

GMP inspection

Evaluation by
MHLW

PAFSC

Note 1) Past records of approval reviews for new drugs in FY2013 were used to determine a rough
indication of review time. The number of individual processes from application to approval used
in the calculation were as follows: Initial interview meeting: 35, Questions on key issues: 31,
Expert review: 85, Evaluation by PAFSC: 83, Manufacturing/marketing authorization: 96.
Note 2) Questions on key issues: First questions issued following the initial interview

Fig. 9 Timeline of the standard process of new drug approval

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Pharmaceutical Regulations in Japan:

Timeline of the standard process of new drug approval (priority review products)

The following timeline shows a rough indication of review timeNote 1) for individual review process,
according to the past records of approval reviews, to achieve the target total review time of 9 months
(ordinary review products) from application to approval for new drugs for which applications are made
from FY2014, assuming that no specific time-consuming situation may occur during the review.

Rough indication of review time


25 percentile~ 1.6~1.9~2.0 mo 0.2~0.3~0.7 mo 4.2~4.4~5.6 mo 1.1~1.3~1.5 mo 0.8~0.8~1.1 mo
median~75 percentile

Questions on key issuesNote 2)


Applicant

Initial interview meeting

Manufacturing/marketing authorization
Expert review

Review report
Application
PMDA

Compliance review

GMP inspection

Evaluation by
MHLW

PAFSC

Note 1) Past records of approval reviews for new drugs in FY2013 were used to determine a rough
indication of review time. The number of individual processes from application to approval used in
the calculation were as follows: Initial interview meeting: 12, Questions on key issues: 12, Expert
review: 34, Evaluation by PAFSC: 30, Manufacturing/marketing authorization: 31.
Note 2) Questions on key issues: First questions issued following the initial interview

Fig. 10 Timeline of the standard process of new drug approval

2018 - 92 -
Pharmaceutical Regulations in Japan:

Table 3 Data to be Submitted with an Application for Approval to Manufacture/Market:


A New Prescription Drug
(Attached Table 2-1 in PFSB Notification No. 1121-(2) dated November 21, 2014)
Left Column Right Column
A B C D E F G H
123 123 123 123 123456 1234567
(1) Drugs containing new active
○○○ ○○○ ○○○ ○○∆ ○○○○×∆ ○○○∆○∆∆ ○ ○
ingredients
(2) New prescription combination
○○○ ×○○ ○○○ ○∆∆ ○○○○×∆ ○○×××∆× ○ ○
drugs
(3) Drugs with new routes of
○○○ ×○○ ○○○ ○∆∆ ○○○○×∆ ○○×∆○∆∆ ○ ○
administration
(4) Drugs with new indications ○○○ ××× ××× ○×× ∆∆∆∆×∆ ××××××× ○ ○
(5) Prescription drugs with new
○○○ ×○○ ○○○ ××× ○○○○×∆ ××××××× ○ ○
dosage forms
(6) Drugs with new dosages ○○○ ××× ××× ○×× ○○○○×∆ ××××××× ○ ○
(7) Biosimilar Products ○○○ ○○○ ○∆∆ ○×× ∆∆∆∆×∆ ∆○×××∆∆ ○ ○
(8) Prescription drugs with
additional dosage forms
(during reexamination period)
○○○ ×○○ ∆∆○ ××× × × × ×○ × ××××××× × ○
(8-2) Prescription drugs with
additional dosage forms
(not during reexamination period)
(9) Prescription combination drugs
with similar formulations
(during reexamination period)
○○○ ×○○ ○○○ ∆∆× ×××××× ○∆×××∆× ○ ○
(9-2) Prescription combination
drugs with similar formulations
(not during reexamination period)
(10) Other prescription drugs
(during reexamination period)
(10-2) Other prescription drugs
(Same with (10), changes in
manufacturing method of
biological products, etc.) ○
××× ×∆○ ××○ ××× × × × ×○ × ××××××× ×
(10-3) Other prescription drugs 1)
(not during reexamination period)
(10-4) Other prescription drugs
(Same with (10-3), changes in
manufacturing method of
biological products, etc.)

Note 1) The marks and numbers in the columns on the right indicate the marks and numbers of the data
specified in Attached Table 1, and the marks have the following meanings, in principle: ○: Data
required ×: Data not required △: Data required depending on individual cases
Note 2) Note 1) in column on the right signifies as follows.

1) Only for applications that do not involve any change to information contained in the attached data, including
change to the manufacturing method or change to the testing method, the attachment of data under H is not
required, in principle.

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Pharmaceutical Regulations in Japan:

(Table 3) Drug classification system


(1) “Prescription drugs with new active ingredients” refer to drugs that have ingredients never before been used as active
ingredients in drugs that have already been approved for manufacture/marketing or are specified in the Japanese
Pharmacopoeia (“approved drugs, etc.” hereinafter).
(2) “New combination prescription drugs” refer to drugs with different active ingredients or combining ratios from those of
combination drugs specified in the Japanese Pharmacopoeia or combination drugs that have already been approved for
manufacture/marketing as prescription drugs. However, combination prescription drugs with similar formulations
specified in (8) and drugs such as digestive enzyme combination drugs and mild acting poultices that are judged not to be
new from an overall evaluation are excluded.
(3) “Prescription drugs with new administration routes” refer to drugs that have the same active ingredients as approved
drugs, etc. but have different routes of administration (oral, subcutaneous, intramuscular, intravenous, percutaneous,
per-rectal, transvaginal, eye drops, nasal drops, inhalation, etc.).
(4) “Prescription drugs with new indications” refer to drugs that have the same active ingredients and routes of
administration as approved drugs, etc. but have different indications.
(5) “Prescription drugs with new dosage forms” refer to drugs that have the same active ingredients, routes of
administration and indications as approved drugs, etc. but have new dosage forms with different administration, etc.
because of pharmaceutical changes such as sustained release. However, drugs with additional dosage forms specified
in (7) are excluded.
(6) “Prescription drugs with new doses” refer to drugs that have the same active ingredients and routes of administration
as approved drugs, etc. but have different doses.
(7) “Biosimilar products” refer to biotechnological products equivalent to existing (approved) biotechnological products in
quality
(8) “Prescription drugs with additional dosage forms” refer to drugs that have the same active ingredients, routes of
administration, indications and dosage and administration as approved drugs, etc., but have different dosage forms or
contents.
(9) “Combination prescription drugs with similar formulations” refer to prescription drugs with active ingredients and
combining ratios that are judged to be similar to those of combination drugs specified in the Japanese Pharmacopoeia or
combination drugs that have already been approved for manufacture/marketing as prescription drugs.
(10) “Other prescription drugs” refer to drugs not classified into any of the above (1) to (9). Changes of manufacturing
method of biological products are classified into 10-2 or 10-4. Biological products refer to vaccines and blood products
entered in the Biological Product Standards; recombinant DNA technological drugs, cell culture drugs and other
biotechnological drugs or drugs derived from living organisms.

A Origin or background of 1. Origin or background of discovery


discovery, conditions of 2. Conditions of use in foreign countries
use in foreign countries 3. Special characteristics, comparisons with other drugs, etc.
B Manufacturing methods, 1. Chemical structure and physicochemical properties, etc.
standards and test 2. Manufacturing methods
methods 3. Standards and test methods
C Stability 1. Long-term storage tests 3. Accelerated tests
2. Tests under severe conditions (stress tests)
D Pharmacological action 1. Tests to support efficacy
2. Secondary pharmacology, Safety pharmacology
3. Other pharmacology
E Absorption, distribution, 1. Absorption 4. Excretion
metabolism, and 2. Distribution 5. Bioequivalence
excretion 3. Metabolism 6. Other pharmacokinetics
F Acute, subacute, and 1. Single dose toxicity 5. Reproductive toxicity
chronic toxicity, 2. Repeated dose toxicity 6. Local irritation
teratogenicity, and other 3. Genotoxicity 7. Other toxicity
types of toxicity 4. Carcinogenicity
G Clinical studies Clinical trial results
H Information in the Information in the attached data, etc.
attached data, etc.
provided for in Article 52,
Paragraph 1 of the Law

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Pharmaceutical Regulations in Japan:

Table 4 Data to be Submitted with an Application for a Non-prescription Drug


(Attached Table 2-2 in PFSB Notification No. 1121-(2) dated November 21, 2014

Left Column Right Column


A B C D E F G H
123 123 123 123 123456 1234567
(1) Drugs containing new active
○○○ ○○○ ○○○ ○○∆ ○○○○×∆ ○○○∆○∆∆ ○ ○
ingredients
(2) Drugs with new routes of
○○○ ×○○ ○○○ ○∆∆ ○○○○×∆ ○○×∆○∆∆ ○ ○
administration
(3-1) Drugs with new indications ○○○ ××× ××× ○×× ∆∆∆∆×∆ ××××××× ○ ○
(3-2) Prescription drugs with new
○○○ ×○○ ○○○ ××× ○○○○×∆ ××××××× ○ ○
dosage forms
(3-3) Drugs with new dosages ○○○ ××× ××× ××× ○○○○×∆ ××××××× ○ ○
(4) Non-prescription drugs with new
○○○ ××○ ∆×∆ ∆××××× ∆∆×××∆∆ ○ ○
2)
active ingredients for ×××
non-prescription drugs
(5-1) Non-prescription drugs with
○○○ ××○ ∆×∆ ∆××××× ∆∆×××∆∆ ○ ○
2)
new administration routes for ×××
non-prescription drugs
(5-2) Non-prescription drugs with
new indications for ○○○ ××× ××× ××× ∆××××× ××××××× ○ ○
non-prescription drugs
(5-3) Non-prescription drugs with
○○○ ××○ ∆×∆ ∆××××× ○ ○
2)
new dosage forms for ××× ×××××××
non-prescription drugs
(5-4) Non- prescription drugs with
new dosage/administrations for ○○○ ××× ××× ××× ∆××××× ××××××× ○ ○
non-prescription drugs
(6) New non-prescription
○○○ ××○ ∆×∆ ∆××××× ∆∆×××∆× ○ ○
2)
×××
combination drugs
(7-1) Non-prescription combination
××○ ××○ ∆×∆ ∆××××× ∆∆××××× ○
2)
××× ×
drugs with similar formulations
(7-2) Non-prescription combination
××○ ××○ ∆×∆ ∆××××× ○
2)
××× ××××××× ×
drugs with similar dosage forms
(8) Other non-prescription drugs ××○
××○ ∆×∆
2)
1) ××× ×××××× ××××××× × ×
(drugs with approval standards, etc)
Note 1) The marks and numbers in the columns on the right indicate the marks and numbers of the data
specified in Attached Table 1, and the marks have the following meanings, in principle: ○: Data
required×: Data not required △: Data required depending on individual cases
Note 2) Notes 1) and 2) in column on the right signify as follows.
1) A drug product that conforms to approval standards may be applied by submitting a comparison table of the
standards and active ingredient(s) and its amount(s). A non-drug product must be documented with the
basis of formulation development, efficacy, safety, and other necessary characteristics.
2) Long-term stability data are necessary if stability for more than 3 years is not ensured by accelerated stability
tests. If the product is confirmed to be stable for at least 1 year based on ongoing long-term stability tests,
the application itself is acceptable. The final report of the long-term tests must be submitted until approval.

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Pharmaceutical Regulations in Japan:

(Table 4) Drug classification system


(4) “Non-prescription drugs with new active ingredients for non-prescription drugs” refer to non-prescription drugs other
than drugs with new active ingredients and contain ingredients not used as active ingredients in approved non-prescription
drugs.
(5)
(5-1) “Non-prescription drugs with new administration routes for non-prescription drugs” refer to non-prescription drugs
other than drugs with new routes of administration and contain the same active ingredients as approved non-prescription
drugs but have different routes of administration.
(5-2) “Non-prescription drugs with new indications for non-prescription drugs” refer to non-prescription drugs other than
drugs with new indications and have the same active ingredients and routes of administration as approved
non-prescription drugs but have different indications.
(5-3) “Non-prescription drugs with new dosage forms for non-prescription drugs” refer to non-prescription drugs other than
drugs with new dosage forms and have the same active ingredients, routes of administration and indications as approved
non-prescription drugs but have a new dosage form leading to changes in dosage/administration because of
pharmaceutical changes such as sustained release, which are classified into either of non-prescription drugs or
guidance-mandatory drugs.
(5-4) "Non- prescription drugs with new dosage/administrations for non-prescription drugs” refer to non-prescription drugs
other than drugs with new dosage/administrations and have the same active ingredients and routes of administration as
approved non-prescription drugs but have different dosage/administrations, which are classified into either of
non-prescription drugs or guidance-mandatory drugs.
(6) “New non-prescription combination drugs” refer to non-prescription drugs with the same ingredients as active
ingredients of approved non-prescription drugs but with a different active ingredient composition, which are classified into
either of non-prescription drugs or guidance-mandatory drugs. Those determined to have a similar active ingredient
composition to approved non-prescription drugs are excluded. Basically, the drugs in No. 1. (1)-(1) a) to f) in Notification
No. 0331053 of the PFSB dated March 31 2008 are equivalent to new non-prescription combination drugs.
(7)
(7-1) “Non-prescription combination drugs with similar formulations” refers to drugs with ingredients the same as active
ingredients of approved non-prescription drugs that are non-prescription drugs with similar combinations of active
ingredients as approved non-prescription drugs.
(7-2) “Non-prescription drugs with similar dosage forms” refer to non-prescription drugs with the same active ingredients,
routes of administration and indications as approved non-prescription drugs but with different dosage forms, but they are
not equivalent to drugs in (5)-(3) among non-prescription drugs with different dosage forms.
(8) “Other non-prescription drugs” refers to non-prescription drugs that are not equivalent to the drugs in (1) to (7).

A Origin or background of discovery, conditions of 1. Origin or background of discovery


use in foreign countries 2. Conditions of use in foreign countries
3. Special characteristics, comparisons with other drugs, etc.
B Manufacturing methods, standards and test 1. Chemical structure and physicochemical properties, etc.
methods 2. Manufacturing methods
3. Standards and test methods
C Stability 1. Long-term storage tests 3. Accelerated tests
2. Tests under severe conditions
(stress tests)
D Pharmacological action 1. Tests to support efficacy
2. Secondary pharmacology, Safety pharmacology
3. Other pharmacology
E Absorption, distribution, metabolism, and 1. Absorption 4. Excretion
excretion 2. Distribution 5. Bioequivalence
3. Metabolism 6. Other pharmacokinetics
F Acute, subacute, and chronic toxicity, 1. Single dose toxicity 5. Reproductive toxicity
teratogenicity, and other types of toxicity 2. Repeated dose toxicity 6. Local irritation
3. Genotoxicity 7. Other toxicity
4. Carcinogenicity
G Clinical studies Clinical trial results
H Information in the attached data, etc. provided Information in the attached data, etc.
for in Article 52, Paragraph 1 of the Law

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Pharmaceutical Regulations in Japan:

Table 5 Classification of Clinical Studies According to Objectives

Type of study Objective of study Study examples

Human  Assess tolerance  Dose-tolerance studies


pharmacology
 Define/describe PK and PD  Single and multiple dose PK and/or PD
studies
studies
 Explore drug metabolism and drug
interactions  Drug interaction studies
 Estimate activity  ADME studies

Therapeutic  Explore use for the targeted  Earliest studies of relatively short duration
exploratory indication in well-defined narrow patient
studies populations, using surrogate or
 Dose-response exploration studies
pharmacological endpoints or clinical
 Provide basis for confirmatory measures
study design, endpoints,
methodologies

Therapeutic  Demonstrate/confirm efficacy  Adequate, and well controlled studies to


confirmatory establish efficacy
 Establish safety profile
studies
 Safety studies
 Establish dose-response
relationship  Randomized parallel dose-response
studies
 Provide an adequate basis for
assessing the benefit/risk  Large simple studies
relationship to support licensing

Therapeutic  Refine understanding of benefit/risk  Comparative effectiveness studies


use studies relationship in general or special
 Studies of mortality/morbidity outcomes
populations and/or environments
 Large simple studies
 Identify less common adverse
reactions  Pharmacoeconomic studies
 Refine dosing recommendation

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Pharmaceutical Regulations in Japan:

Table 6 List of Major Guidelines, etc. on Physicochemical Properties, Specifications, and


Tests Methods
Title Notification number and date of issuance
Text (Items) on Analytical Validation Notification No. 755 of the Evaluation and
Licensing Division, PAB dated July 20, 1995
(ICH Q2A, currently Q2(R1))
Guidelines on Impurities in Bulk Drugs with New Active Ingredients Notification No. 877 of the Evaluation and
Licensing Division, PAB dated September 25,
1995, partially revised by Notification No.
1204001 of the Evaluation and Licensing
Division, PFSB dated December 4, 2006
(ICH Q3A, currently Q3A(R2))
Guidelines on Impurities in Drug Preparations Notification No. 539 of Evaluation and Licensing
Division, PAB, dated June 23, 1997, partially
revised by Notification No. 0703004 of the
Evaluation and Licensing Division, PFSB dated
July 3, 2006
(ICH Q3B, currently Q3B(R2))
Text (analytical procedures) on Analytical Validation Notification No. 338 of the Evaluation and
Licensing Division, PAB dated October 28, 1997
(ICH Q2B, currently Q2(R1))
Guidelines on Residual Solvents in Drug Preparations Notification No. 307 of the Evaluation and
Licensing Division, PMSB dated March 30, 1998,
partially revised by Notification No. 0211-(1) of
the Evaluation and Licensing Division, PFSB
dated February 21, 2011
(ICH Q3C, currently Q3C(R5))
Guideline for Elemental Impurities Notification No. 0930-(4) of the Evaluation and
Licensing Division, PFSB dated September 30,
2015 (ICH-Q3D)
Setting of Specifications and Test Methods of New Drugs Notification No. 568 of the Evaluation and
Licensing Division, PMSB dated May 1, 2001
(ICH Q6A)
Setting of Specifications and Test Methods of Biological Products Notification No. 571 of the Evaluation and
(Biotechnological Products/Drug Products Derived from Living Licensing Division, PMSB dated May 1, 2001
Organisms) (ICH Q6B)
Guidelines for Handling Internationally Harmonized Specifications of Notification No. 574 of the Evaluation and
Japanese Pharmacopoeia Licensing Division, PMSB dated May 1, 2001
Guidelines Related to Formulation Development Notification No. 0901001 of the Evaluation and
Licensing Division, PFSB dated September 1,
2006, partially revised by Notification No.
0628-(1) of the Evaluation and Licensing
Division, PFSB dated June 28, 2010
(ICH Q8)
Handling of Application of Drugs Containing a Substance with Different Notification No. 0616-(1) of PFSB dated June 16,
Crystalline 2011
Guidelines for development and manufacturing of active pharmaceutical Notification No. 0710-(9) of the Evaluation and
ingredients (chemicals and biotechnological products/biological products) Licensing Division, PFSB dated July 10, 2014
(ICH-Q11)
Guidelines for Assessment and Control of DNA Reactive (mutagenic) Notification No. 1110-(3) of the Evaluation and
Impurities in Pharmaceuticals to Limit Potential Carcinogenic Risk Licensing Division, PSEHB dated November 10,
2015 (ICH-M7)

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Pharmaceutical Regulations in Japan:

Table 7 List of Major Guidelines, etc. on Toxicity Tests


Title Notification number and date of issuance
Revisions of the Guidelines for Single and Repeated Dose Toxicity Notification No. 88 of the Evaluation and
Studies Licensing Division, PAB dated August 10, 1993
(ICH S4)
Guidance for Toxicokinetics (Evaluation of Systemic Exposure in Toxicity Notification No. 443 of the Evaluation and
Tests) Licensing Division, PAB dated July 2, 1996
(ICH S3A)
Guidance on Dose Selection for Carcinogenicity Tests of Drugs Notification No. 544 of the Evaluation and
Licensing Division, PAB dated August 6, 1996
(ICH S1C)
Guidance on Dose Selection for Carcinogenicity Tests of Drugs and its Notification No. 551 of the Evaluation and
supplement Licensing Division, PMSB dated July 9, 1998
(ICH S1C(R), currently S1C(R1))
Guideline on the Need for Carcinogenicity Studies of Pharmaceuticals Notification No.315 of the Evaluation and
Licensing Division, PAB dated April 14, 1997
(ICH-S1A)
Guidelines for Reproductive and Developmental Toxicity Studies Notification No. 316 of the Evaluation and
Licensing Division, PAB dated April 14, 1997
(ICH S5A/S5B), partially revised by Notification
No. 1834 of the Evaluation and Licensing
Division, PMSB dated December 27, 2000 (ICH
S5B(M), currently S5(R2))
Testing for Carcinogenicity of Pharmaceuticals Notification No. 548 of the Evaluation and
Licensing Division, PMSB dated July 9, 1998
(ICH-S1B)
Timing of Nonclinical Safety Studies in Relation to Clinical Trials Notification Nos. 1019 and 1831 of the
Evaluation and Licensing Division of PMSB
dated November 13, 1998 and December 27,
2000, respectively, partially revised by
Notification No. 0219-(4) of the Evaluation and
Licensing Division, PMSB dated February 19,
2010 (ICH M3(M), currently M3(R2))
Guidance on Nonclinical Safety Studies for the Conduct of Human Clinical Office Communication dated August 16, 2012
Trials and Marketing Authorization for Pharmaceuticals Questions &
Answers (Q&A)
Guidance on Genotoxicity Tests of Pharmaceuticals Notification No. 1604 of the Evaluation and
Licensing Division, PMSB dated November 1,
1999 (ICH-S2)
Guidance on Carcinogenicity Tests of Pharmaceuticals Notification No. 1607 of the Evaluation and
Licensing Division, PMSB dated November 11,
1999, partially revised by Notification No.
1127001 of the Evaluation and Licensing
Division, PFSB dated November 27, 2008
Guidance on Immunotoxicity Studies for Human Pharmaceuticals Notification No. 0418001 of the Evaluation and
Licensing Division, PFSB dated April 18, 2006
(ICH S8)
The Non-clinical Evaluation of the Potential for Delayed Ventricular Notification No. 1023-(4) of the Evaluation and
Repolarization (QT Interval Prolongation) by Human Pharmaceuticals Licensing Division, PFSB dated October 23,
2009 (ICH S7B)
Guidance on Genotoxicity Testing and Data Interpretation for Notification No. 0920-(2) dated September 20,
Pharmaceuticals Intended for Human Use 2012 (ICH-S2 (R1))
Guidance on Non-clinical Evaluation of Medicinal Products in Pediatric Notification No. 1002-(5) of the Evaluation and
Population Using Juvenile Animals Licensing Division, PFSB dated October 2, 2012
Guideline on Photosafety Evaluation Notification No. 0521-(1) of the Evaluation and
Licensing Division, PFSB dated May 21, 2014
(ICH-S10)

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Pharmaceutical Regulations in Japan:

Table 8 List of Major Guidelines, etc. on Pharmacological Studies


Title Notification number and date of issuance
Guidelines for General Pharmacology Studies Notification No. 4 of the New Drugs Division,
PMSB dated January 29, 1991
Safety Pharmacology Study Guidelines Notification No. 902 of the Evaluation and
Licensing Division, PMSB dated June 21, 2001
(ICH-S7A)
Methods of Investigating Drug Interactions Notification No. 813 of the Evaluation and
Licensing Division, PMSB dated June 4, 2001

Table 9 List of Major Guidelines, etc. on Pharmacokinetic Studies


Title Notification number and date of issuance
Guidelines on Pharmacokinetic Studies
Guidelines on Nonclinical Pharmacokinetic Studies Notification No. 496 of the Evaluation and
Licensing Division, PMSB dated June 26, 1998
Guideline for Repeated Dose Tissue Distribution Studies Notification No. 442 of the Evaluation and
Licensing Division, PAB dated July 2, 1996
(ICH-S3B)
Guidelines on validation of bioanalytical methods
Guidelines on Bioanalytical Methods Validation for Human Studies in New Notification No. 0711-(1) of the Evaluation and
Drug Development Licensing Division, PFSB dated July 11, 2013
Guidelines on Bioanalytical Methods Validation for Human Studies in New Office Communication dated July 11, 2013
Drug Development Questions and Answers (Q&A)
Guidelines on Bioanalytical Methods (Ligand Binding) Validation for Notification No. 0401-(1) of the Evaluation and
Human Studies in New Drug Development Licensing Division, PFSB dated April 1, 2014
Guidelines on Bioanalytical Methods (Ligand Binding) Validation for Office Communication dated April 1, 2014
Human Studies in New Drug Development Questions and Answers (Q&A)
Guidelines on investigation of drug interactions
Methods of Investigating Drug Interactions Notification No. 813 of the Evaluation and
Licensing Division, PMSB dated June 4, 2001
Guidelines for Pharmacokinetic Drug Interaction for Drug Development Office Communication dated July 8, 2014
and Proper Information Provision (Final Draft)

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Pharmaceutical Regulations in Japan:

Table 10 List of Major Guidelines, etc. on Bioequivalence Studies


Title Notification number and date of issuance
Guidelines on bioequivalence studies
Guidelines for Bioequivalence Testing of Generic Drugs Notification No. 0229-(10) of the Evaluation and
Licensing Division, PFSB dated February 29,
2012
Guidelines for Bioequivalence Testing of Oral Solid Dosage Forms with Notification No. 0229-(10) of the Evaluation and
Different Content Licensing Division, PFSB dated February 29,
2012
Guidelines for Bioequivalence Testing of Oral Solid Dosage Forms with Notification No. 0229-(10) of the Evaluation and
Formulation Modifications Licensing Division, PFSB dated February 29,
2012
Guidelines for Bioequivalence Testing of Products with Different Dosage Notification No. 0229-(10) of the Evaluation and
Forms Licensing Division, PFSB dated February 29,
2012
Guidelines for Bioequivalence Studies of Generic Products for Topical Notification No. 1124004 of the Evaluation and
Dermatological Use Licensing Division, PFSB dated November 24,
2006
Guidelines for Bioequivalence Testing of New Additional Topical Notification No. 1124001 of the Evaluation and
Dermatological Dosage Forms Licensing Division, PFSB dated November 24,
2006
Guidelines for Bioequivalence Testing of Topical Dermatological Dosage Notification No. 1101-(1) of the Evaluation and
Forms with Formulation Modifications Licensing Division, PFSB dated November 1,
2010
Guidelines for evaluation of bioequivalence of various preparations
Guidelines for Bioequivalence Studies of Solid Oral Preparations for Office Communication dated April 19, 2013
Handling Changes in Manufacturing Method (Including Q&A)
Guidelines for Bioequivalence Studies of Generic Powder Inhaler Office Communication dated March 11, 2016
Products
Guidelines for Bioequivalence Studies of Generic Aqueous Ophthalmic Office Communication dated March 11, 2016
Solution Products

Table 11 List of Major Guidelines, etc. on Clinical Evaluation


Title Notification number and date of issuance
[1] Guidelines for clinical evaluation of drugs classified by therapeutic category
Guidelines on Clinical Evaluation of Oral Contraceptives Notification No. 10 of the First Evaluation and
Registration Division, PAB dated April 21, 1987
Guidelines for Clinical Evaluation of Drugs to Improve Cerebral Notification No. 22 of the First Evaluation and
Circulation and/or Metabolism in Cerebrovascular Disorders Registration Division, PAB dated October 31,
1987
Guidelines on Clinical Evaluation of Antihyperlipidemic Drugs Notification No. 1 of the First Evaluation and
Registration Division, PAB dated January 5,
1988
Guidelines on Clinical Evaluation of Antianxiety Drugs Notification No. 7 of the First Evaluation and
Registration Division, PAB dated March 16, 1988
Guidelines for Clinical Evaluation of Antibacterial Drugs Notification No. 743 of the New Drugs Division,
PMSB dated August 25, 1998).
The draft amendment was presented on August
3, 2010.
Guidelines on Clinical Evaluation of Drugs to Treat Osteoporosis Notification No. 742 of the Evaluation and
Licensing Division, PMSB dated April 15, 1999,
partially revised by Notification of
Pharmaceutical Evaluation Division, PSEHB
0707-(1)

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Pharmaceutical Regulations in Japan:

Principles for Clinical Evaluation of New Antihypertensive Drugs Notification No. 0128001 of the Evaluation and
Licensing Division, PMSB dated January 28,
2002
(ICH E12A, currently E12)
Guidelines on Clinical Evaluation of Antiarrhythmic Drugs Notification No. 0325035 of the Evaluation and
Licensing Division, PFSB dated March 25, 2004
Guidelines on Clinical Evaluation of Antianginal Drugs Notification No. 0512001 of the Evaluation and
Licensing Division, PFSB dated May 12, 2004
Guidelines for Clinical Evaluation of Antimalignant Tumor Drugs Notification No. 1101001 of the Evaluation and
Licensing Division, PFSB dated November 1,
2005, partially revised by Office Communication
dated November 2, 2005
Guidelines for Clinical Evaluation of Antirheumatoid Drugs Notification No. 0217001 of the Evaluation and
Licensing Division, PFSB dated February 17,
2006
Guidelines for Clinical Evaluation of Drugs for Overactive Bladder or Notification No. 0628001 of the Evaluation and
Incontinence Licensing Division, PFSB dated June 28, 2006
Guidelines for Clinical Evaluation of Prophylactic Vaccines against Notification No. 0527-(5) of the Evaluation and
Infections Licensing Division, PFSB dated May 27, 2010
Guidelines for Clinical Evaluation of Oral Hypoglycemic Drug Notification No. 0709-(1) of the Evaluation and
Licensing Division, PFSB dated July 9, 2010.
The draft amendment was presented on May 19,
2014
Guidelines for Clinical Evaluation of Antidepressant Drugs Notification No. 1116-(1) of the Evaluation and
Licensing Division, PFSB dated November 16,
2010
Guidelines on Clinical Evaluation of Drugs to Treat Heart Failure Notification No. 0329-(18) of the Evaluation and
Licensing Division, PFSB dated March 29, 2011
Guidelines for Clinical Evaluation of Therapeutic Drugs for Renal Anemia Notification No. 0930-(1) of the Evaluation and
Licensing Division, PFSB dated September 30,
2011
Guidelines on Clinical Evaluation of Hypnotics Notification No. 1213-(1) of the Evaluation and
Licensing Division, PFSB dated December 13,
2011
Guidance for Clinical Evaluation Method of Anticancer Drugs in Pediatric Notification No. 0930-(1) of the Evaluation and
Patients With Malignant Cancer Licensing Division, PFSB dated September 30,
2015
Guidance on Clinical Evaluation of Travelers' Vaccine, etc. Notification No. 0407-(1) of the Evaluation and
Licensing Division, PSEHB dated April 7, 2016
[2] Common guidelines for clinical evaluation
Studies in Support of Special Populations: Geriatrics Notification No. 104 of the New Drugs Division,
PAB dated December 2, 1993 (ICH-E7) and Q&A
dated September 17, 2010
Questions and Answers for "Studies in Support of Special Populations: Office Communication dated September 17,
Geriatrics" 2010

Dose-Response Information to Support Drug Registration Notification No. 494 of the Evaluation and
Licensing Division, PAB dated July 25, 1994
(ICH-E4)
Extent of Population Exposure to Assess Clinical Safety for Drugs Notification No. 592 of the Evaluation and
Intended for Long-term Treatment of Non-Life-Threatening Conditions Licensing Division, PAB dated May 24, 1995
(ICH-E1)
Structure and Content of Clinical Study Reports Notification No. 335 of the Evaluation and
Licensing Division, PAB dated May 1, 1996
(ICH-E3)
General Considerations for Clinical Trials Notification No. 380 of the Evaluation and
Licensing Division, PMSB dated April 21, 1998
(ICH-E8)

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Pharmaceutical Regulations in Japan:

Ethnic Factors to be Considered in the Acceptance of Foreign Clinical Notification No. 672 of the Evaluation and
Trial Data Licensing Division, PMSB dated August 11, 1998
(ICH E5, currently E5(R1)) Q&A by Office
Communication dated February 25, 2004, and
Q&A-(2) by Office Communication dated October
5, 2006
Statistical Principles for Clinical Trials Notification No. 1047 of the Evaluation and
Licensing Division, PMSB dated November 30,
1998
(ICH-E9)
Clinical Investigation of Medicinal Products in the Pediatric Population Notification No. 1334 of the Evaluating and
Licensing Division, PMSB dated December 15,
2000
(ICH-E11)
Choice of Control Group and Related Issues in Conducting Clinical Notification No. 136 of the Evaluating and
Studies Licensing Division, PMSB dated February 27,
2001, partially revised by Office Communication
dated April 10, 2001
Guidance for Conducting Microdose Clinical Studies Notification No. 0603001 of the Evaluating and
Licensing Division, PFSB dated June 3, 2008
Clinical Investigation of QT/QTc Interval Prolongation and Proarrhythmic Notification No. 1023-(1) of the Evaluating and
Potential for Non-antiarrhythmic Drugs Licensing Division, PFSB dated October 23,
2009, Q&A by Office Communication dated
October 23, 2009, and Q&A-(2) by Office
Communication dated July 3, 2012
Guidance on Nonclinical Safety Studies for the Conduct of Human Clinical Notification No. 0219-(4) of the Evaluation and
Trials and Marketing Authorization for Pharmaceuticals Licensing Division, PFSB dated February 19,
2010 (ICH-M3(R2)) and Q&A by Office
Communication dated August 16, 2012
[3] Other guidelines for clinical evaluation
Research on Evaluation of Immunotherapeutic Agents for Malignant Iyakuhin Kenkyu 11(4), 1980
Tumors
Research on Evaluation of Blood Preparations, Especially Plasma Iyakuhin Kenkyu 15(2), 1984
Fraction Preparations
Research on Overall Evaluation of Interferon Preparations Iyakuhin Kenkyu 15(6), 1984
Guidelines on Clinical Evaluation of Anti-inflammatory Analgesic Drugs Iyakuhin Kenkyu 16(3), 1985
Guidelines on the Design and Evaluation of Sustained-release (Oral) Notification No. 5 of the First Evaluation and
Preparations Registration Division, PAB dated March 11, 1988
Guidance for Developing Prototype Vaccines in Preparation for Influenza Notification No. 1031-(1) of the Evaluation and
Pandemic Licensing Division, PFSB dated October 31,
2011
Guidance for Clinical Evaluation of Diagnostic Radiopharmaceuticals Notification No. 0611-(1) of the Evaluation and
Licensing Division, PFSB dated June 11, 2012
Points to Consider in Application of Companion Diagnostics and Related Notification No. 0701-(10) of the Evaluation and
Drug Products Licensing Division, PFSB dated July 1, 2013
Technical Guidance for Companion Diagnostics and Related Drug Office Communication dated December 26, 2013
Products
Guideline for PK/PD of Antibacterial Agents Notification No. 1225-(10) of the Evaluation and
Licensing Division, PSEHB dated December 25,
2015
Guideline for Development of Liposomal Preparations Notification No. 0328-(19) of the Evaluation and
Licensing Division, PSEHB dated March 28,
2016
Reflection Paper on Nucleic Acid (siRNA)-Encapsulated Nanoparticle Office Communication dated March 28, 2016
Formulations

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Pharmaceutical Regulations in Japan:

Table 12 List of Major Guidelines, etc. Related to Biotechnology


Title Notification number and date of issuance
Viral Safety Evaluation of Biotechnology Products Derived from Cell Lines Notification No. 329 of the Evaluation and
of Human or Animal Origin Licensing Division, PMSB dated February 22,
2000
(ICH-Q5A)
Quality of Biotechnological Products: Analysis of the Expression Notification No. 3 of the Evaluation and Licensing
Construct in Cells Used for Production of R-DNA Derived Protein Division, PMSB dated January 6, 1998
Products (ICH-Q5B)
Quality of Biotechnological Products: Stability Testing of Notification No. 6 of the Evaluation and Licensing
Biotechnological/Biological Products Division, PMSB dated January 6, 1998
(ICH-Q5C)
Derivation and Characterization of Cell Substrates Used for Production of Notification No. 873 of the Evaluation and
Biotechnological/Biological Products Licensing Division, PMSB dated July 14, 2000
(ICH-Q5D)
Comparability of Biotechnological/Biological Products Subject to Changes Notification No. 0426001 of the Evaluation and
in Their Manufacturing Process Licensing Division, PFSB dated April 26, 2005
(ICH-Q5E)
Specifications: Test Procedures and Acceptance Criteria for Notification No. 571 of the Evaluation and
Biotechnological/Biological Products Licensing Division, PMSB dated May 1, 2001
(ICH-Q6B)
Preclinical Safety Evaluation of Biotechnology-Derived Pharmaceuticals Notification No. 0323-(1) of the Evaluation and
Licensing Division, PFSB dated March 23, 2012
(ICH-S6(R))
Guidelines of Quality and Safety Assurance of Drugs for Gene Therapy Notification No. 0701-(4) of the Evaluation and
Licensing Division, PFSB dated July 1, 2013
Reporting of Information and Findings that May Affect the Evaluation of Notification No. 0701-(7) of the Evaluation and
Drugs for Gene Therapy Licensing Division, PFSB dated July 1, 2013

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Pharmaceutical Regulations in Japan:

N
o
n

Module 1 C
Administrative
T
information:
D
1.1: NDA TOC

2.1: TOC

2.2: Introduction

Module 2
2.4: Nonclinical 2.5: Clinical
Overview Overview
2.3: Quality
overall 2.6: Nonclinical
summary Written and
2.7:
C
Clinical
Tabulated
Summaries Summary
T

Module 3 Module 4 Module 5 D


Quality Safety Efficacy
3.1: TOC 4.1: TOC 5.1: TOC

Fig. 11 Organization of ICH Common Technical Documents

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Pharmaceutical Regulations in Japan:

Fig. 12 Correlation between Development Phases and Types of Study

This matrix graph illustrates the relationship between the phases of development
and types of study by objective that may be conducted during each clinical development
of a new medicinal product. The shaded circles show the types of study most usually
conducted in a certain phase of development, the open circles show certain types of
study that may be conducted in that phase of development but are less usual. Each
circle represents an individual study. To illustrate the development of a single study, one
circle is joined by a dotted line to an inset column that depicts the elements and
sequence of an individual study.

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Pharmaceutical Regulations in Japan:

Table 13 ICH topics and guidelines - Progress of harmonization


as of November 17, 2017 http://www.pmda.go.jp/files/000221387.pdf

Quality
Code Topics
Step 5 Q1A(R2) Stability testing: New drug substances and products
Q1B Stability testing: Photostability
Q1C Stability testing: New & partially revised dosage forms
Q1D Stability testing: Bracketing and matrixing designs
Q1E Stability testing: Evaluation of stability data
Q2(R1) Validation of analytical procedures: Text and methodology
Q3A(R2) Impurities in new drug substances
Q3B(R2) Impurities in new drug products
Q3C(R5) Impurities: Residual solvents
Q3D Guideline for metal impurities
Q4B Pharmacopoeias: Harmonized texts for use in ICH regions
Q4B(Annex1)(R1) Test for residue on ignition
Q4B(Annex2)(R1) Test for extractable volume of parenteral preparations
Q4B(Annex3)(R1) Test for particulate contamination of parenteral preparations
Q4B(Annex4A, 4B, 4C) (R1) Microbial limit tests of non-sterile products
Q4B(Annex6)(R1) Uniformity of dosage units
Q4B(Annex5)(R1) Disintegration test
Q4B(Annex7)(R2) Dissolution test
Q4B(Annex8)(R1) Sterility test
Q4B(Annex9)(R1) Tablet friability test
Q4B(Annex10)(R1) Polyacrylamide gel electrophoresis
Q4B(Annex11) Capillary electrophoresis
Q4B(Annex12) Analytical sieving
Q4B(Annex13) Bulk density and tapped density of powders
Q4B(Annex14) Bacterial endotoxins test
Q5A(R1) Quality of biotechnology products: Viral bioburden
Q5B Quality of biotechnology products: Genetic stability
Q5C Quality of biotechnology products: Stability Testing of products
Q5D Quality of biotechnology products: Cell bank control (cell substrates)
Q5E Quality of Biotechnology Products: Comparability of products
Q6A Specifications/test methods: Chemicals/pharmacopoeial harmonization
Q6B Specifications/test methods: Biological products
Q7 GMP for active pharmaceutical ingredients
Q8(R2) Pharmaceutical development
Q9 Quality risk management
Q10 Pharmaceutical quality system
Q11 Manufacturing and development of active pharmaceutical ingredients
Step 4 Q3C(R6) Impurities: Residual solvents (Revision)

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Quality
Code Topics
Step 3
Step 2a/2b Q12 Technical and regulatory considerations for pharmaceutical product lifecycle management
Step 1
Pre-Step 1 Q3C(R7) Impurities: Residual solvents (Revision)

Safety
Code Topics
Step 5 S1A Need for carcinogenicity studies
S1B Testing of carcinogenicity of pharmaceuticals
S1C(R2) Dose selection for carcinogenicity studies
S2(R1) Genotoxicity
S3A Toxicokinetics: Assessment of systemic exposure in toxicity studies
S3B Pharmacokinetics: Repeated-dose tissue distribution
S4 Single- and repeated-dose toxicity studies
S5(R2) Reproduction studies of medicinal products
S6(R1) Safety evaluation of biological products
S7A Safety pharmacology studies
S7B The non-clinical evaluation of QT interval prolongation potential
S8 Immunotoxicology studies
S9 Non-clinical evaluation of anticancer drugs
S10 Guidance on photosafety testing
Step 4
Step 3 S5(R3) Reproduction studies of medicinal products (Revision)
Step 2a/2b
Step 1
Pre-Step 1 S1 Testing of carcinogenicity of pharmaceuticals (review of guideline)
S11 Nonclinical safety testing in support of development of pediatric medicines

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Efficacy
Code Topics
Step 5 E1 The extent of population exposure to assess clinical safety for drugs intended for long-term treatment of non-life
threatening condition
E2A Clinical safety data management: Definitions and standards for expedited reporting in the clinical phase
Data elements for transmission of individual case safety reports
E2B(R2) Implementation guide – data elements and message specification in individual case safety reports (ICSR)
E2B(R3) Periodic Benefit-Risk Evaluation Report(PBRER)
Post-approval safety data management
E2C(R2) E2D Pharmacovigilance planning (PVP)
E2E E2F Development of safety update report (DSUR)
E3 Structure and content of clinical study reports
E4 Dose-response information to support drug registration
E5(R1) Ethnic factors in the acceptability of foreign clinical data
E6(R1) Guidance for good clinical practice
E7 Studies in support of special populations: Geriatrics
E8 General considerations for clinical trials
E9 Statistical principles for clinical trials
E10 Choice of control group and related issues in clinical trials
E11 Clinical investigation of medicinal products in the pediatric population
E12 Principles for clinical evaluation of new antihypertensive drugs
E14 The clinical evaluation of QT interval prolongation and proarrhythmic potential for non-antiarrhythmic drugs
E15 Definitions for genomic biomarkers, pharmacogenomics, pharmaco- genetics, genomic data, and sample coding
categories
E16 Genomic biomarkers related to drug response: Context, structure and format of qualification submissions
Step 4 E6(R2) Guideline for good clinical practice (Supplement)
E11(R1) Clinical investigation of medicinal products in the pediatric population
E17 General principle on planning/designing multi-regional clinical trials
E18 Gnomic sampling methodologies for future use
Step 3 E9(R1) Statistical principles for clinical trials (Supplement)
Step 2a/2b
Step 1
Pre- E19 Optimisation of safety data collection
Step 1 E8(R1) General considerations for clinical trials (Revision)
E11A Pediatric extrapolation

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Multidisciplinary
Code Topics
Step 5 M1 Medical dictionary for regulatory activities (MedDRA)
M2 Electronic standards for transmission of regulatory information
M3(R2) Non-clinical safety studies for the conduct of human clinical trials
M4 Common Technical Document
M4E(R2) Guideline on enhancing the format and structure of benefit-risk information in CTD
M7 Assessment and control of DNA reactive (mutagenic) impurities in pharmaceuticals to reduce potential carcinogenic
risk
M8 e-CTD specification (v. 3.2.2)
M8 e-CTD specification (v.4.0)
Step 4 M7(R1) Assessment and control of DNA reactive (mutagenic) impurities in pharmaceuticals to reduce potential carcinogenic
risk (Supplement)
Step 3
Step 2a/2b
Step 1
Pre- M9 BCS-based biowaivers
Step 1 M10 Bioanalytical Method Validation

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data.
CHAPTER 4
Periodic reporting of safety information on new
POST-MARKETING drugs, etc. was agreed at the ICH in January 1996,
and the periodic safety update report (PSUR)
SURVEILLANCE OF DRUGS system was introduced by Notification No. 32 of the
Safety Division, PMSB dated March 27, 1997 to
replace the previous annual reporting system with
the PSUR (MHW Ordinance No. 29 dated March
Post-marketing surveillance (PMS) to assure the
27, 1997) and the Guidelines on Methods for
quality, efficacy and safety of drugs after they go on
Surveillance of Results of Use of Prescription Drugs
the market and to establish proper methods of use
(Notification No. 34 of the Safety Division, PMSB
of drugs consists of three systems: the ADRs and
dated March 27, 1997) were specified for drug
infections collection and reporting system, the
use-result surveys to be intensively implemented
reexamination system, and the reevaluation system
after marketing. However, because of an increase
(Fig. 13 Pharmaceutical Post-marketing
in post-marketing ADRs not observed in the clinical
Surveillance System).
trial stage of drug development and implementation
The re-examination system for new drugs was of safety measures, regulations on safety measured
introduced in the October 1979 amendment of the for drugs (Notification No. 25 of the Safety Division,
Pharmaceutical Affairs Law, and Good PMSB) and entries in case report forms for ADRs
Post-marketing Surveillance Practice (GPMSP) and infections (Office Communication) were
came into effect from April 1993 to assure proper specified in March 11, 1998. Furthermore,
implementation of PMS and also to assure the additional guidelines, “Periodic Infection Reporting
reliability of such PMS data. Thereafter, major System for Biological Products” (Notification No.
revisions were made in the Pharmaceutical Affairs 0515008 of the PMSB dated May 15, 2003) and
Law and its Enforcement Regulations in 1996 to “Implementation of Early Post-marketing Phase
1997 to further strengthen post-marketing safety Vigilance for Prescription Drugs” (Notification No.
measures, and the GPMSP, which had formerly 0324001, the Safety Division, PFSB dated March
been considered as an administrative notification, 24, 2006) were issued to further strengthen the
became law in “MHW Ordinance for Good safety monitoring of medical products (Fig. 14
Post-Marketing Surveillance Practice of Drugs Post-marketing Collection and Reporting of
(Drug GPMSP)” and came into effect in April 1997 Pharmaceutical Safety Information).
(MHW Ordinance No. 10 dated March 10, 1997).
In the revised Pharmaceutical Affairs Law
The Drug GPMSP was partially revised by MHW
enforced on April 1, 2005, the historical
Ordinance No. 151 dated December 27, 2000, and
manufacturing approval system was changed to the
“Early Post-marketing Phase Vigilance” for new
marketing (as well as manufacturing) authorization
drugs was newly established to reinforce safety
system to internationally harmonize the concept of
measures in an early phase of marketing (enforced
approval system, and the part that deals with the
from October 1, 2001).
collection, evaluation, and assessment of
The GPMSP is applied as standards requiring information for appropriate use of post-marketing
compliance by manufacturers or importers when safety measures of the MHLW Ordinance on
performing post-marketing surveillance or studies, GPMSP related to the implementation of safety
and also as compliance criteria for preparation of

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assurance measures was separated from the part Revising Ministerial Ordinance Related to
that deals with tests and surveillance conducted to Standards for Conducting Post-Marketing Surveys
collect and assess materials for reexamination and and Studies on Drugs (Related to MHLW Ordinance
reevaluation. The former has been specified in the Related to Standards for Conducting
MHLW Ordinance on GVP (MHLW Ordinance Post-Marketing Surveys and Studies on Drugs)"
Related to Standards for Post-Marketing Safety (Notification No. 1026-(1) of the Evaluation and
Management of Drugs, quasi-drugs, Cosmetics and Licensing Division, PSEHB dated October 26, 2017)
Medical Devices, MHLW Ordinance No. 135 dated was issued. In this revision, "general drug
September 22, 2004), and the latter in the MHLW use-results survey" and "use-results comparison
Ordinance on GPSP (MHLW Ordinance Related to survey" were added and defined to "specific drug
Standards for Conducting Post-Marketing Surveys use-results survey" for the purpose of further
and Studies on Drugs; MHLW Ordinance No. 171 clarification of "drug use-results survey." The
issued by MHLW on December 20, 2004). The revised GPSP Ministerial Ordinance will take effect
MHLW Ordinance on GPMSP was abolished. on April 1, 2018.
The Guidelines on Pharmacovigilance Planning In 2012, the Risk Management (RMP) Guidance
(ICH E2E guidelines) (Notification No. 0916001 of (Notification No. 0411-(1) of the Safety Division,
the Evaluation and Licensing Division, PFSB and PFSB and No. 0411-(2) of the Evaluation and
Notification No. 0916001 of the Safety Division, Licensing Division, PFSB both dated April 11, 2012)
PFSB both dated September 16, 2005) were issued was issued to support the manufacturing/marketing
with an objective of guiding and assisting the authorization holder in developing the RMP
applicant in planning pharmacovigilance activities for including risk minimization plans for the reduction of
new drug in the early post-marketing phase. Since treatment-related risks in addition to conventional
the operation of the Medical Information Database pharmacovigilance plans following drug approval.
System (MID-NET) developed by PMDA is These Notifications are applicable to
expected to start on a full scale, and the manufacturing/marketing approval application for
environment for utilizing the medical information new drugs and biosimilar products submitted on or
database in pharmacovigilance is being established, after April 1, 2013 and August 26, 2014,
"Basic Concept of the Use of Medical Information respectively. Further, the MHLW Ordinances on
Database in Post-marketing Pharmacovigilance " GVP and GPSP were revised on March 11, 2013 to
(Notification No. 0609-(8) of the Pharmaceutical ensure the development and subsequent
Evaluation Division, PSEHB / Notification No. implementation of risk management plan (RMP). In
0609-(4) of the Safety Division, PSEHB dated June March 2016, “Preparation and publication of drug
9, 2017) was issued in June 2017. Thus, the basic risk management plan” (Notification No. 0331-(13)
concept to be applied when a marketing of the Evaluation and Licensing Division, PSEHB
authorization holder for drugs use the medical and Notification No. 0331-(13) of the Safety Division,
information database in post-marketing PSEHB both dated March 31, 2016) and “Points to
pharmacovigilance was presented. Subsequently, be considered in submission of publication
the GPSP Ministerial Ordinance was revised on documents of drug risk management plan”
October 26, 2017 to add "post-marketing database (Notification No. 0331001 of the Office of Safety,
survey" as a type of post-marketing survey. PMDA dated March 31, 2016) were issued. To
"Announcement of Ministerial Ordinance Partially promote use of RMPs in clinical practices, these

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notifications presented points to be considered in post-marketing clinical study of a regenerative


preparation and publication of RMP synopsis as well medicine product, applicable documents have to be
as submission of publication documents to prepared under this ordinance. More specific
PMDA."Description on Materials Prepared and handling procedures were shown in the notification
Distributed for Additional Risk Minimization Activities “Description methods of basic plan for evaluation of
in Risk Management Plan (RMP)" (Office post-marketing approval conditions and basic plan
Communication dated June 8, 2017) was issued. of post-marketing surveys for regenerative medicine
It was decided to display RMP marks on the products” (Notification No. 0826-(1) of the Medical
materials for health professionals and the materials Devices Division, PFSB dated August 26, 2015).
for patients in order to enable health professionals to Based on the Guidelines, Periodic Safety
be aware that the materials such as the guide to Update Reports (PSUR) for Marketed Drugs which
proper use are based on the drug risk minimization objective was the standardization of the format and
activities in RMP. time of safety reporting, the new Guidelines, the
The Law for Partial Amendment of the Periodic Benefit-Risk Evaluation Report (PBRER:
Pharmaceutical Affairs Law (Law No. 84, 2013) was ICH E2C (R2)) with the objective of assessing not
issued on November 27, 2013, in which only risks but also integrated risk-benefit balance
regenerative medicine products were newly defined. and a guidance for assisting safety report writing
In line with the provisions in Article 23-21, Item 2 in was issued (Notification No. 0517-(1) of the
the revised Law, the “Law for Ensuring the Quality, Evaluation and Licensing Division, PFSB both dated
Efficacy, and Safety of Drugs and Medical Devices” May 17, 2013). In August 2014, Q&A on PBRER
(Pharmaceutical and Medical Device Act), the was also issued (Office Communication, August 25,
MHLW Ordinance on GVP (MHLW Ordinance for 2014).
the standards for post-marketing safety The use of the Medical Dictionary for Regulatory
management of drugs, quasi-drugs, cosmetics, Activities (MedDRA) as agreed by ICH is
medical devices and regenerative medicine recommended to standardize international
products) was partially revised to be the standards regulatory-related medical terminology (M1) use at
for licensing manufacturing/marketing business of all regulatory levels before and after marketing for
regenerative medicine product and to include the regulatory communication in registration, records,
provisions for subcontract of post-marketing safety and safety monitoring of drugs. Efforts are being
management tasks specified in Article 18, made to achieve international coordination of
Paragraph 3, etc. in the Law (Article 98 in the terminology related to pharmaceutical regulations
Enforcement Regulations). (adverse reactions, signs and symptoms, diagnosis,
Furthermore, the GPSP Ordinance for indications, laboratory tests, surgical and
regenerative medicine products was newly issued in conservative interventions and patient
response to the new approval system established in characteristics). Since the end of March 2000, it
consideration of characteristics of regenerative has been possible to use MedDRA for clinical trial
medicine products (the MHLW Ordinance for data, reexamination and reevaluation data and
standards for conducting post-marketing surveys package inserts. It is used in data input, retrieval,
and studies on regenerative medicine products; evaluation, and presentation at both the pre- and
2014 MHLW Ordinance No. 90, dated July 30, post-marketing regulatory stages for drugs. From
2014). To conduct use-results survey or October 27, 2003, it became obligatory to use

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MedDRA in individual case safety reports to be [2] Quality assurance activities refers to any
submitted to the PMDA in accordance with the activity related to post-marketing quality
ADRs and Infections Reporting System. MedDRA control concerned with requisite
is maintained by the Maintenance and Support measures based on the collection and
Service Organization (MSSO) and two new study of safety management information,
versions are generally published each year. or on the results.
[3] The RMP refers to safety assurance
1. GVP activities including clinical information
collection, post-marketing surveys,
Good Vigilance Practice (GVP) establishes
clinical studies, and other activities for
standards for post-marketing safety management
minimizing potential risks inherent in the
related to the collection, evaluation, and assessment
use of new drugs, etc. with an objective
of proper use information on the establishment of
of adequate risk control of new drugs, etc.
appropriate safety-related organizations and
by analyzing safety and efficacy
systems as one of licensing requirements for the
information to be thus obtained and
manufacturing/marketing authorization holder,
implementing necessary safety
development and implementation of relevant SOPs,
assurance measures. These activities
marketed drugs, etc., and to the implementation of
are undertaken by the
measures for safety assurance. On March 11,
manufacturing/marketing authorization
2013, the GVP was revised to incorporate the RMP
holder following commencement of
in the GVP guidelines.
marketing of new drugs, etc. that poses
The extent of duties of the manufacturing/market specific safety and/or efficacy concerns.
authorization holder in post-marketing safety The RMP is specified as a condition of
management to be entrusted to third parties is approval.
defined in the Ordinance for Enforcement of the
[4] Person in charge of drug information and
Pharmaceutical and Medical Device Act.
person in charge of medical device
This GVP consists of 17 articles. A summary is information refer to persons whose main
provided below. duties consist of collecting and providing
(1) Purpose (Article 1) safety assurance information through
visits to health care professionals in
This Ministerial Ordinance establishes the
order to contribute to the proper use of
standards established by the MHLW Ordinance
drugs or medical devices.
related to post-marketing safety management
set forth in Article 12-2, Paragraph 2 of the
Pharmaceutical and Medical Device Act. Articles 3 to 12 are specified for the first type of
manufacturing/marketing authorization holder
(2) Definitions of terms (Article 2)
(manufacturing/marketing authorization holders of
[1] Safety management information refers to prescription drugs, highly controlled medical devices
material relating to the quality, efficacy or or regenerative medicine product).
safety of drugs etc. and any other
information required for the proper use of
drugs, etc.

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(3) Duties of general marketing compliance the supervisor of the safety management
officer (Article 3) department.
The general marketing compliance officer must  This supervisor must have been
undertake the following duties. engaged for at least 3 years in safety
[1] To supervise the safety management assurance work or related work.
supervisor.  This supervisor must have the ability to
[2] To respect the opinions of the safety properly and smoothly undertake safety
management supervisor. assurance activities.

[3] To assure close coordination with the  This supervisor must not belong to any
safety management supervisor, quality division responsible for marketing drugs,
assurance supervisor, and other persons etc.
involved in safety management. [3] When whole or part of the safety
[4] To closely collaborate with the supervisor assurance activities are undertaken by
of post-marketing surveys, etc. in persons other than the safety
implementing the RMP. management supervisor, a supervisor of
the work concerned (safety management
(4) Organizations and personnel involved
implementation supervisor) must be
in safety assurance (Article 4)
appointed.
[1] A department (safety management
(5) Standard operating procedures for
department) meeting the following
post-marketing surveillance (Article 5)
requirements must be established to
handle all duties related to safety [1] The following standard operating
assurance. procedures for post-marketing safety
management must be prepared.
 This department is under the supervision
of the general manufacturing/marketing  Procedures for collection of safety
supervisor management information

 This department must employ  Procedures for drafting of safety


adequately qualified and competent assurance measures based on
personnel who are able to undertake examination of safety management
safety assurance activities properly and information and the results thereof
smoothly.  Procedures for implementation of safety
 This department should be independent assurance measures
of all divisions responsible for marketing  Procedures for reporting from safety
drugs and other departments that would management supervisors to general
hinder proper and smooth safety marketing compliance officer
assurance activities.  Procedures for reporting from safety
[2] A safety management supervisor management implementation supervisor
meeting the following requirements must to safety management supervisors
be appointed.  Procedures for implementing the RMP
 The safety management supervisor is (including procedures for early

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post-marketing phase vigilance) when (6) Duties of the safety management


the RMP is required in practice supervisor (Article 6)
 Procedures for in-house inspections [1] The safety management supervisor shall
 Procedures for education and training perform the following duties:

 Procedures for retention of records  Overall supervision of safety assurance


work
 Procedures for contacts with quality
assurance supervisors and other  Confirmation that safety assurance work
supervisors engaged in work related to is being performed properly and
marketing of prescription drugs and smoothly and preparation and retention
highly controlled medical devices of records of such confirmation

 Procedures for collaborating with the  Offering of opinions in writing to general


supervisors on post-marketing marketing compliance supervisor when
surveillance and other post-marketing safety assurance work is required and
obligations when the RMP is required in retention of copies of such opinions
practice  To closely collaborate with the supervisor
 Other procedures necessary for properly of post-marketing surveys, etc. in
and smoothly implementing safety implementing the RMP.
assurance measures of post-marketing (7) Collection of safety management
surveillance information (Article 7)
[2] The duties and management system for [1] The following safety management
persons employed for work related to information shall be collected by the
post-marketing safety management must safety management supervisor and
be specified in writing. safety management implementation
[3] Items required for proper and smooth supervisor and records thereof shall be
implementation of safety assurance prepared.
activities must be specified in writing.  Information from health professionals
[4] When the procedures in [1] or the  Information on reports presented at
documents in [2] and [3] are prepared or scientific meetings, reports from the
revised, they must be dated and literature and other research reports
retained.
 Information from the Ministry of Health,
[5] The general marketing compliance Labour and Welfare, other government
officer shall make available the institutions, prefectural governments and
procedures in [1], the documents in [2] PMDA
and [3] and other documents required for
 Information from foreign governments
safety assurance work in the office
and overseas organizations
performing the work and also must make
 Information from other pharmaceutical
available copies of procedures and other
manufacturing/marketing authorization
related documents in other offices
holders
performing safety assurance work.
 Other safety management information

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[2] The safety management implementation retain a copy. Records of the


supervisor shall report the records in [1] examination performed by the safety
in writing to the safety management management implementation supervisor
supervisor. shall be prepared and reported in writing.
[3] The safety management supervisor shall The safety management supervisor shall
preserve the records in [1] and reports in retain these results.
[2]. (9) Implementation of safety assurance
(8) Drafting of safety assurance measures measures (Article 9)
based on examination of safety [1] The general marketing compliance
management information and the officer must undertake the following
results thereof (Article 8) duties:
[1] The safety management supervisor shall  Appropriately evaluate drafts of safety
perform the following duties: assurance measures, decide the safety
 Examine the collected safety assurance measures to be taken and
management information without delay prepare and retain records thereof.
and record the results thereof.  When safety management supervisors
 Supply all safety information that the undertake safety assurance measures,
quality assurance supervisor must be instructions shall be issued in writing and
familiar with in writing without delay to retained
the quality assurance supervisor.  When safety management
 When it is confirmed necessary from an implementation supervisors undertake
examination of safety management safety assurance measures, instructions
information, measures shall be drafted to shall be issued in writing and the safety
discard, recall or suspend marketing of management supervisor shall retain
the product, revise package inserts, copies. The safety management
supply information to health implementation supervisor shall prepare
professionals by persons in charge of records and make reports in writing.
drug or medical device information, The copies shall be given to the safety
reports to the Minister of Health, Labour management supervisor.
and Welfare and other safety assurance [2] The safety management supervisor shall
measures. perform the following duties:
 Drafts of safety assurance measures  Safety assurance measures shall be
shall be reported in writing to the general undertaken based on instructions from
marketing compliance officer and copies the general marketing compliance officer
shall be retained. and records thereof shall be prepared
[2] When the safety management supervisor and retained.
has the safety management  When safety assurance measures are
implementation supervisor examine undertaken by safety management
safety management information, he or implementation supervisors, instructions
she shall issue instructions in writing and shall be issued in writing and copies shall

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be retained. Records shall be prepared,  Other necessary items


reported in writing and retained.  Revision of the RMP protocol as
 The results of implementation of safety situations may require
assurance measures shall be reported in  When the RMP protocol is prepared or
writing to the general marketing revised, the protocol shall be dated and
compliance officer, and copies shall be retained.
retained.
[2] The general marketing compliance
 Copies of reports from the safety officer must make available the RMP
management implementation supervisor protocol in his/her office and also must
shall be retained. make available copies of the RMP
[3] Evaluation of drafts of safety assurance protocol specifying assigned activities
measures for which post-marketing and procedures in other offices
safety management standard operating performing the compliance activities.
procedures have been specified [3] The safety management supervisor must
beforehand, deciding on safety confirm that the RMP is being adequately
assurance measures to be taken, and and smoothly implemented, and shall
preparation and retention of records can retain records of such confirmation.
be undertaken by the safety
[4] Whenever performing RMP-related
management supervisor in place of the
activities, the safety management
general manufacturing/marketing
implementation supervisor must records
supervisor.
the activities performed and report the
(10) Risk management plan (RMP) (Article activities in writing to the safety
9-(2)) management supervisor, and the safety
[1] The general marketing compliance management supervisor must retain the
officer or the safety management reports.
supervisor must undertake the following (11) Early post-marketing phase vigilance
duties in implementing the RMP: (Article 10)
 Preparation of protocol for individual [1] The general marketing compliance
RMPs (“RMP protocol”) that contain the officer and the safety management
following information: supervisor must undertake the following
 Specific safety and efficacy issues to be duties in implementing early
addressed post-marketing phase vigilance (a survey
 Outline of plans and procedures for performed for risk management of new
information collection, survey, and study drugs, etc. over a 6-month period
of safety and efficacy issues to be following launch to promote optimal use
resolved in practice and closely monitor serious
ADRs of new drugs, etc.).
 Outline of risk minimization activities
 Preparation of a protocol based on the
 Time schedules of the RMP
RMP for individual post-marketing phase
implementation status and evaluation
vigilances (early post-marketing phase

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vigilance protocol) containing the be performed on a regular schedule by a


following information: person appointed beforehand.
 Objective of early post-marketing phase [2] When the person appointed beforehand
vigilance in [1] is the safety management
 Method of early post-marketing phase supervisor, the safety management
vigilance supervisor shall prepare and retain
records of in-house inspections.
 Period of early post-marketing phase
vigilance [3] When the person appointed beforehand
in [1] is a person other than the safety
 Other necessary items
management supervisor, that person
 Revision of the early post-marketing
shall prepare records of in-house
phase vigilance protocol, as situations
inspections and report in writing to the
may require
safety management supervisor. The
 When the early post-marketing phase safety management supervisor shall
vigilance protocol is prepared or revised, retain these reports.
the protocol shall be dated and retained.
[4] The safety management supervisor shall
[2] The general marketing compliance report the results of the in-house
officer shall make available early inspection in writing to the general
post-marketing phase vigilance protocol marketing compliance officer and shall
in the office performing the work and also retain a copy of the report.
must make available copies in other
[5] The general marketing compliance
offices performing surveillance work.
officer shall examine the necessity of
[3] The safety management supervisor shall improvements in post-marketing safety
confirm that early post-marketing phase management based on the results of
vigilance is being performed in-house inspections and when
appropriately and smoothly and records improvements are necessary, the
of such confirmation shall be prepared general marketing compliance officer
and retained. shall undertake the specified measures
[4] When early post-marketing phase and prepare records thereof. The
vigilance is performed by the safety safety management supervisor shall
management implementation supervisor, retain these records.
the safety management implementation
(13) Education and training (Article 12)
supervisor shall prepare records and
[1] The general marketing compliance
report in writing to the safety
officer shall prepare and retain education
management supervisor, and the safety
and training protocols for employees
management supervisor shall retain such
engaged in duties related to
reports.
post-marketing safety management
(12) In-House inspections (Article 11)
[2] Education and training shall be
[1] In-house inspections of duties related to performed as planned by a person
post-marketing safety management shall appointed beforehand.

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[3] When the person appointed beforehand cosmetics and ordinary medical
in [2] is the safety management devices) (Articles 15)
supervisor, the safety management The standards for type 1 marketing
supervisor shall prepare and retain authorization holders shall apply mutatis
records of education and training. mutandis with the exception of the following:
[4] When the person appointed beforehand [1] [1] to [3] in Article (14) above.
in [2] is a person other than the safety
[2] Standard operating procedures for
management supervisor, that person
post-marketing safety management are
shall prepare records of education and
not specified.
training and report in writing to the safety
[3] Collection of safety information in (7) for
management supervisor. The safety
quasi-drugs and cosmetics is limited to
management supervisor shall retain
research reports and other safety
these reports.
management information.
[5] The safety management supervisor shall
[4] In-house inspections and education and
report the results of the education and
training are not specified.
training in writing to the general
marketing compliance officer and shall (16) Retention of records related to safety
retain a copy of the report. assurance (Article 16)

(14) Standards for post-marketing safety [1] The period of retention of 5 years from
management of type 2 marketing the date when the records are no longer
authorization holders (marketing utilized. However, the period shall be
authorization holders of drugs other 10 years for biological products, 30 years
than prescription drugs and controlled for specified biological products, and 15
medical devices, including marketing years for designated controlled medical
authorization holders of in vitro devices and highly controlled medical
diagnostics) (Articles 13 and 14) devices. Records related to in-house
inspections and education and training
The standards for type 1 marketing
shall be kept for 5 years from the date of
authorization holders shall apply mutatis
preparation
mutandis with the exception of the following:
[2] Records specified by Ministerial
[1] Establishment of a safety management
Ordinance can be retained by persons
division is not specified.
designated by the marketing
[2] No qualifications for safety management
authorization holder based on the
supervisors are specified.
standard operating procedures for
[3] Appointment of a safety management post-marketing safety management.
implementation supervisor is not
specified.
2. GPSP
(15) Standards for post-marketing safety
management of type 3 marketing The GPSP (Good Post-marketing Study
authorization holders (Marketing Practice) specifies items that are to be strictly
authorization holders of quasi-drugs, complied with in order to achieve appropriate

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post-marketing surveillance and studies conducted [3] Among drug use result surveys, specified
by manufacturing/marketing authorization holders, drug-use survey refers to a survey by the
and to assure the reliability of data submitted when manufacturing/marketing authorization
applying for reexamination or re-evaluation. On holder to screen or confirm information
March 11, 2013, the GPSP was revised to relating to the incidence of each disease
harmonize its provisions with those of GVP in view due to adverse drug reactions, together
of the incorporation of the RMP in the GVP. with the quality, efficacy and safety of
The GPSP consists of 12 articles, which are drugs, in specified populations of
summarized below. patients, such as pediatric patients,
elderly patients, pregnant women,
(1) Purpose (Article 1)
patients with renal and/or hepatic
This Ministerial Ordinance sets forth the disorders, and patients using the drug for
items that must be strictly complied with by long periods.
manufacturing/marketing authorization holders
[4] Among post-marketing surveys,
of drugs in conducting post-marketing
post-marketing clinical study refers to a
surveillance and studies.
clinical study performed to verify
This GPSP applies to inspections, etc. of assumptions arrived at as a result of
documents and data related to reexamination studies undertaken with regard to results
and reevaluation of prescription drugs. For of clinical studies or drug-use surveys, or
post-marketing clinical studies forming part of studies conducted in accordance with
post-marketing surveillance, GCP is also approved dosage and administration,
applicable, in addition to GPSP. and indications to collect information on
(2) Definitions of terms (Article 2) quality, efficacy and safety unobtainable
[1] Post-marketing surveys, etc. refers to in routine medical practice.
drug use-results surveys or (3) Standard operating procedures for
post-marketing clinical studies that the post-marketing surveillance (Article 3)
manufacturing/marketing authorization The following standard operating
holder of drugs conducts in order to procedures for post-marketing surveillance
collect, screen, confirm or verify shall be prepared and retained by the
information relating to the quality, manufacturing/marketing authorization holder
efficacy and safety of drugs. for the proper and smooth conduct of
[2] Among post-marketing surveys, drug post-marketing surveillance. The date must
use-results survey refers to a survey by be entered in the SOP manual when SOP are
the manufacturing/marketing prepared or revised.
authorization holder to screen or confirm [1] Procedures related to drug use-results
information related to the incidence of surveys
each disease due to adverse drug
[2] Procedures related to post-marketing
reactions, together with the quality,
clinical studies
efficacy and safety of drugs, without
[3] Standards related to in-house
specifying the condition of the patients
inspections
that use the drugs.

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[4] Procedures related to education and  In cases in which a basic protocol for
training of personnel involved in post-marketing surveys, etc. is prepared or
post-marketing surveys, etc. revised, to date and preserve it.
[5] Procedures related to the outsourcing of  When it is considered necessary for the
duties in post-marketing surveys, etc. conduct of post-marketing surveys, etc., to
[6] Procedures related to the preservation of provide written opinions to the
records involving duties in manufacturing/marketing authorization
post-marketing surveys, etc. holder, and to preserve these documents
or copies thereof.
[7] Any other procedures necessary for
appropriate and smooth implementation [4] A basic protocol for post-marketing
of post-marketing surveys, etc. surveys, etc. is not required to be
prepared or retained when the RMP is
(4) Supervisor of post-marketing surveys,
available and retained.
etc. (Article 4)
[5] The manufacturing/marketing
[1] A supervisor of the
authorization holder must respect the
manufacturing/marketing authorization
opinions provided by the supervisor of
holder must be appointed to coordinate
post-marketing surveys, etc.
the duties involved in post-marketing
[6] The manufacturing/marketing
surveys, etc. (supervisor of
authorization holder must not make any
post-marketing surveys, etc.).
statements that would interfere with the
[2] The supervisor of post-marketing
supervisor of post-marketing surveys, etc.
surveys, etc. must not be a member of a
in the performance of his or her duties.
department involved in marketing.
(5) Post-marketing surveys, etc. (Article 5)
[3] Duties to be performed by the supervisor
of post-marketing surveys, etc.: [1] Duties to be performed by the supervisor
of post-marketing surveys, etc.:
 To prepare and preserve a basic protocol
for post-marketing surveys, etc. for each  To prepare plans, proposals and surveys
drug individually. for implementation of post-marketing
surveys, etc.
 To set forth in writing protocols for the
implementation of drug use-results surveys,  To confirm that post-marketing surveys, etc.
protocol for post-marketing clinical studies, are conducted properly and smoothly in
and any other matters necessary for accordance with the standard operating
conducting post-marketing surveys, etc. in procedures for duties for post-marketing
accordance with the standard operating surveys, etc. and the basic protocol on
procedures for post-marketing surveys, etc. post-marketing surveys, etc. (instead the
and the basic protocol on post-marketing RMP, if available)
surveys, etc. (instead, the RMP, if  To provide notification in writing of the
available) results of post-marketing surveys, etc. to
 To revise the basic protocol for the manufacturing/marketing authorization
post-marketing surveys, etc. as required. holder (instead the
manufacturing/marketing authorization

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holder and the safety management 7)


supervisor, if the RMP is available) [1] The manufacturing/marketing
[2] The manufacturing/marketing authorization holder must perform
authorization holder must arrange that, post-marketing studies by the
for both drug use-results surveys and post-marketing surveillance supervisor or
post-marketing clinical trials, records are other person designated by the
prepared and preserved in order that the manufacturing/marketing authorization
supervisor of post-marketing surveys, etc. holder based on the post-marketing
understands the conditions under which surveillance, etc.
the surveys or tests were conducted. [2] The studies must be conducted in
[3] The manufacturing/marketing compliance with GCP
authorization holder must instruct the
(8) In-House inspections (Article 8)
supervisors on post-marketing
[1] The manufacturing/marketing
surveillance and other post-marketing
authorization holder must conduct
obligations to report in writing the
in-house inspections on a regular
conduct and outcomes of each drug-use
schedule. Items that have been audited
results survey and post-marketing clinical
based on GCP do not require in-house
studies to the safety management
inspections.
supervisor when the RMP is available for
In cases in which a person other than the
practice.
supervisor of post-marketing surveys, etc.
(6) Drug use-results surveys (Article 6) conducts an in-house inspection, the
[1] The manufacturing/marketing supervisor of post-marketing surveys, etc.
authorization holder must instruct the is to be notified in writing of the results of
supervisor or other designated person to the inspection.
conduct drug use-results surveys Records of the results of the in-house
according to the post-marketing inspection are prepared and preserved.
surveillance SOP, etc. [2] Post-marketing surveillance supervisors
[2] Contracts in writing must be concluded must report in writing the results of the
with the medical institutions competent in self-inspections to the
conducting the drug use-results survey manufacturing/marketing authorization
and preserved. holder.
[3] Contract may be handled by [3] When it is found that improvements must
electronically. be made in the work based on the results
[4] In protocols for drug use-results surveys, of the self-inspection, the necessary
the purpose of the survey, scheduled measures must be taken, and records of
number of cases, controls, survey these measures must be prepared and
method, survey period, items surveyed, retained.
analytical items and method and other (9) Education and training (Article 9)
necessary matters must be established.
[1] Planned education and training related to
(7) Post-marketing clinical studies (Article post-marketing surveillance must be

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performed by the post-marketing post-marketing surveys, etc.


surveillance supervisors or other persons
designated by the
3. PAPER COMPLIANCE REVIEW AND
manufacturing/marketing authorization
ON-SITE GPSP SURVEYS OF DATA FOR
holder for persons employed in
REEXAMINATION AND REEVALUATION
post-marketing surveillance work.
Documents and data submitted for
[2] In cases in which education and training
reexamination and reevaluation of a drug are
are performed by a person other than the
subject to paper compliance review and on-site
supervisor of post-marketing surveys,
GPSP surveys in order to examine whether the
etc., the supervisor of post-marketing
materials for evaluation have been collected in
surveys, etc., is notified in writing of the
accordance with the standards specified by the
conditions of its implementation.
MHLW minister. Detailed procedures for the
[3] Records of education and training are
compliance review and on-site surveys are available
prepared and preserved.
as “the Guidelines on Compliance Paper Reviews
(10) Delegation of duties of post-marketing on Approval Application Data for New Drugs”
surveys, etc, (Article 10) (Notification No. 1121-(5) of the Evaluation and
The manufacturing/marketing authorization Licensing Division, PFSB dated November 21,
holder may assign some of the duties of 2014), and “the Guidelines for Implementation of
post-marketing surveys, etc. to persons who GPSP On-site Surveys” (Notification No. 0330003
are capable of properly and effectively carrying of the Evaluation and Licensing Division, PFSB
out these activities. dated March 30, 2005). Procedures for applying
paper review and on-site surveys are specified in
(11) Preservation of records in connection
the “Application Procedures for Paper
with post-marketing surveys, etc.
Review-Conformity Inspection and On-site GCP
(Article 11)
Inspection of Data for the Reexamination and
Records of reexamination and reevaluation Reevaluation of Drugs” (Notification No. 1121007 of
data must be retained for 5 years from the date the PMDA dated November 21, 2014). On July 21,
that reexamination or reevaluation is completed. 2016, a service of consultation on compliance
Other records must be preserved for 5 years review for drug reexamination was introduced.
from the date they are no longer in actual use This service has allowed an applicant to consult
or date of the final entry. about compliance of the following documents with
(12) Standards for Compliance of the reliability standards: applicable documents are
Reexamination and Reevaluation Data planned to be attached in the application for drug
in Connection with Post-marketing reexamination and are related to the previously
Surveillance (Article 12) completed post-marketing clinical studies and
In addition to provisions of the GCP MHLW use-results surveys.
Ordinance, the provisions of Article 3 through
Article 8, Article 10, and Article 11 of this GPSP 4. ADVERSE DRUG REACTIONS AND
MHLW apply mutatis mutandis to the collection INFECTIONS REPORTING SYSTEM
and preparation of data for reexamination and
Programs for collecting and reporting safety
reevaluation applications in connection with

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information on drugs such as adverse drug post-marketing safety management (GVP).


reactions include an adverse drug reaction reporting The provisions in Article 228-20 of the
system undertaken by pharmaceutical companies, Enforcement Regulations for reporting adverse drug
the drug and medical device safety information reactions specify reporting within 15 days and within
reporting system undertaken by medical personnel, 30 days. The type of cases requiring reporting
and the WHO International Drug Monitoring within 15 days was specified in Notification No.
Program whereby drug safety information is 0317006 of the PFSB dated March 17, 2005 for
exchanged among various countries (Fig. 15 enforcement of MHLW Ordinance for Partial
Collection and Reporting of Pharmaceutical Safety Amendment of the Enforcement Regulations of
Information). Pharmaceutical Affairs Law (Reporting of Adverse
Drug Reactions. etc). This change was intended to
4.1 Adverse Drug Reaction and Infectious assure focused supervision of serious cases caused
Disease Reporting System by by adverse reactions of drugs with little
Pharmaceutical Companies post-marketing clinical experience and to coordinate
This system, based on the Pharmaceutical and reporting criteria for adverse drug reactions with
Medical Device Act (Article 68-10), requires the international standards. A summary of these
reporting of safety findings by pharmaceutical provisions is presented below.
companies to the PMDA for information processing. (1) Reporting within 15 days
In light of the medical problems such as the The following must be reported within 15
development of AIDS associated with the use of days from the time they are first known:
HIV-contaminated, unheated blood products,
a) The cases described below include
provisions were established in the revised
suspected adverse reactions to the drug
Pharmaceutical Affairs Law, which came into effect
concerned reported both in Japan and
in April 1997, to mandate reporting of "adverse drug
overseas. These also include cases
reactions" and the "occurrence of infections
where the occurrence of an adverse
suspected to be caused by the use of the drug
reaction, its incidence, and/or the
concerned."
conditions of onset was unexpected
Revisions in the Enforcement Regulations of the based on the precautions in the package
Pharmaceutical Affairs Law, which became effective
insert of the drug concerned (previously
at the same time, based on items agreed to at the unknown serious cases).
International Conference on Harmonization (ICH),
(1) Death
also have defined the scope of "serious cases"
subject to reporting. In addition, regulatory (2) Disability
information such as measures adopted in overseas (3) Any events possibly leading to death or
to discontinue marketing of a drug due to safety disability
concerns must now be reported. (4) Any case that requires hospitalization
The collection and examination of Japanese and for treatment or prolongs the duration
overseas drug safety information, as well as the of hospitalization.
adoption of specific measures based on this (5) Any other serious cases involving
information, must be carried out in accordance with items (1) through (4) above
the standard operating procedures for (6) Any congenital disease or anomaly in

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Pharmaceutical Regulations in Japan:

the offspring of a treated patient. Pharmaceutical and Medical Device Act, a provision
b) Any case involving items (1) through (6) was added on malfunction reports involving a part of
above resulting from any unknown or device or equipment in drug products approved to
known infections due to use of the drug be manufactured/marketed with other components
concerned, including cases both in including devices or equipment in an integrated form
Japan and overseas. (combination products). It specifies that such
reports shall be handled in accordance with
c) Any implementation of measures by
provisions for reporting criteria and deadline of
regulatory authorities in foreign countries
malfunction reports of medical devices. In addition,
such as suspension of marketing of the
as the Pharmaceutical and Medical Device Act
drug.
specifies reporting requirements for adverse drug
d) Known deaths
reactions of regenerative medicine products, the
e) Changes in onset trends of known Enforcement Regulations included provisions for
serious adverse drug reactions that reporting criteria and deadline of malfunction reports
would result in or increase public health of regenerative medicine products. (Notification No.
hazards. 1002-(20) of PFSB dated October 2, 2014
f) Serious cases considered to be caused “Reporting of adverse drug reactions”)
by adverse reactions of drugs with new This notification imposes manufacturers and
active ingredients within 2 years from the marketing authorization holders on the following
date of approval (known or unknown). reporting obligations: if a reportable malfunction
g) Serious cases discovered in early occurs on the device part without reportable
post-marketing phase vigilance among adverse drug reactions, they must submit
adverse reactions of drugs other than malfunction report only; and if a reportable
drugs with new active ingredients for malfunction occurs with adverse drug reaction, they
which early post-marketing phase must submit both malfunction report and adverse
vigilance is an approval condition (known drug reaction report.
or unknown). In June 2017, "Amendment to "Q&As on
(2) Reporting within 30 days Reports of Adverse Reactions to Combination
Products" (Office Communication dated June 9,
The following must be reported within 30
2017) was issued.
days from the time they are first known:
a) Any cases involving items (2) through (6) (3) Periodic reports of unknown
in subsection (a) of the previous section non-serious adverse reactions of drugs
attributed to a known adverse reaction of The degree of seriousness of cases of
the drug concerned occurring in Japan adverse drug reactions was conventionally
(known serious cases). classified into three grades: serious, moderate
b) Research reports about the drug and mild, but the classification has been
concerned, which demonstrate that it changed to the two-stage serious and
does not have an approved indication in non-serious system used internationally.
Japan and overseas. Cases suspected of being caused by adverse
To the Enforcement Regulations of the drug reactions that are unknown and
non-serious must be reported periodically.

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To further expedite assessments of adverse (ICSRs) (E2B (R3))” (Notification No. 0917-(1)
drug reactions by pharmaceutical companies, of the Evaluation and Licensing Division and
and to promote reporting of these adverse Notification No. 0917-(2) of the Safety Division,
reactions in a more timely and proper manner, PFSB both dated September 17, 2013) was
specific criteria for assessment of cases issued for guiding principles on how to handle
subject to reporting have been established by safety reporting and recommends reporting via
the Standards for Classification of Serious internet to further promote electronic data
Adverse Drug Reactions (Notification No. 80 of processing and electronic database
the Safety Division, PAB dated June 29, 1992). compilation. In March 2017, this notification was
This seriousness classification of adverse revised completely (Notification No. 0331-(6) of the
drug reactions includes the following nine Evaluation and Licensing Division, PSEHB /
categories: liver, kidneys, blood, Notification No. 0331-(1) of the Safety Division,
hypersensitivity, respiratory tract, PSEHB dated March 31, 2017). Handling of
gastrointestinal tract, cardiovascular system, reports of post-marketing adverse reactions before
neuropsychiatry, and metabolic and electrolyte unblinding in post-marketing blinded clinical trials,
abnormalities. etc., was stipulated. Handling of electronic
transmission of the reports of adverse reactions to
The scope of “seriousness” was defined in
quasi drugs and cosmetic products was also
April 1997 based on agreements at the ICH
stipulated. Furthermore, "Q&As on ADR Reporting
conference and details of the agreement on the
in Post-marketing Surveillance and Clinical Trials in
ICH E2D guideline were announced as “the
accordance with the Implementation Guide for
Standards for expediting reporting of
Electronic Transmission of Individual Case Safety
post-approval safety data” (Notification No.
Reports (ICSRs) (E2B (R3))" (Office
0328007 of the Safety Division, PFSB dated
Communication dated March 31, 2017) was
March 28, 2005).
published.
From October 27, 2003, three submission
Furthermore, the procedures including
methods have been specified for E2B/M2: (1)
precautions for reception and reporting of the
via the Internet, (2) mainly FD (disk) reports
reports of post-marketing adverse reactions and
together with paper reports, and (3) mainly
adverse reactions in clinical studies were partially
paper reports with FD reports attached. In
revised, and "Points to Consider in ADR Reporting
July 2013, the Implementation Guide for
in Post-marketing Surveillance and Clinical Trials in
Electronic Transmission of Individual Case
accordance with the Implementation Guide for
Safety Reports (ICSRs) (ICH E2B [R3]) was
Electronic Transmission of Individual Case Safety
summarized and then its Japanese version was
Reports (ICSRs) (E2B (R3))" (Notification No.
issued (Notification No. 0708-(5) of the
0331001 of the Office of Review Management of
Evaluation and Licensing Division and
PMDA / Notification No. 0331001 of the Office of
Notification No. 0708-(1) of the Safety Division,
Safety I of PMDA / Notification No. 0331002 of the
PFSB both dated July 8, 2013). Then, “ADR
Office of Safety II of PMDA dated March 31, 2017)
Reporting in Post-marketing Surveillance and
was issued. As related notifications, "Corrections
Clinical Trials in accordance with the
on Implementation Guide for electronic
Implementation Guide for Electronic
Transmission of Individual Case Safety Reports"
Transmission of Individual Case Safety Reports

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Pharmaceutical Regulations in Japan:

(Notification No. 0315-(6) of the Pharmaceutical medical devices, etc. with the exception of mild,
Evaluation Division, PSEHB / Notification No. well-known adverse events, even though a causal
0315-(1) of the Safety Division, PSEHB dated relationship with the drug concerned is unclear.
March 15, 2017) and "Q&A on Electronic When drugs and related products require
Transmission of Individual Case Safety Reports" especially intensive investigation and collection of
(Office Communication dated August 8, 2017) were information, the MHLW selects medical
published. institutions and, if necessary, performs "early
From January 2006, access to all cases of post-marketing phase safety information collection
suspected adverse drug reactions reported by program (fixed-point survey)" in collaboration with
companies has been possible on the them.
homepage of the PMDA.
http://www.pmda.go.jp/safety/info-services/drugs/ 4.3 WHO International Drug Monitoring
adr-info/suspected-adr/0005.html Program
Because of the necessity of safety measures to
4.2 Drug and Medical Device Safety be implemented for drugs on an international level in
Information Reporting System by Medical view of the deformation scandal caused by
Personnel thalidomide in 1961, the World Health Organization
This is a MHLW reporting system that directly (WHO) first implemented an international
collects safety information from health drug-monitoring program in 1968. Adverse drug
professionals. Because of the need for collection reaction data is collected from all participating
of further information required for post-marketing member states, and a summary of the results of
product safety strategies, the limitation on evaluation of this information is sent back to each
reporting facilities was eliminated in July 1997. country. Japan became a member of this program
This system has been expanded and revised to in 1972. Information about adverse drug reactions
include all medical institutions and pharmacies, that occur in Japan has been reported to WHO, and
and the reporting format has been simplified in likewise, WHO has provided any necessary
order to further increase the number of reports information to Japan. There is also information
from physicians, dentists, and pharmacists. exchange with countries including the United States,
Furthermore, the need of report as the duty of Great Britain, and Germany.
medical personnel was specified in the
Pharmaceutical Affairs Law in July 2003 (Article 5. PERIODIC INFECTION REPORTS FOR
77-(4)-2-2). BIOLOGICAL PRODUCTS (ARTICLE 68-14
* The Pharmaceutical Affairs Law revised AND 68-24 IN THE LAW)
on June 14, 2006 (Law No. 69 enforced in
With the revision of the Pharmaceutical Affairs
2009) also requests the registered
Law in July 2002, drugs manufactured from
manufacturing/marketing authorization
materials derived from humans or other living
holder to report safety information.
organisms (excluding plants) that require caution in
The information subject to reporting includes terms of public health and hygiene are designated
adverse reactions associated with the use of as biological products by the MHLW, as a lesion
prescription medicines, over-the-counter drugs, from incidents of AIDS infection and

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Creutzfeldt-Jacob disease due to contaminated There are limitations on confirmation of all of these
blood coagulation factors. From July 30, 2003, the aspects before approval.
system of periodic infection reports was introduced It is, therefore, obligatory for
by which manufacturers of such biological products manufacturing/marketing companies to perform
must evaluate their products based on findings postmarketing surveillance of their drugs after
obtained from the latest reports on infections caused approval in order to determine if any problems have
by raw materials of the products and report the arisen with efficacy when the drug is used in actual
results every 6 months to the Minister. practice, or to see if the level of efficacy has not
In April 2017, "Notification on the System of been changed by factors such as dosage, duration
Periodic Infection Reports for Regenerative of administration, complications or concomitant
Medicine Products and Biological Products" medication. In terms of safety, any marked
(Notification No. 00428-(1) of the PSEHB dated April increase in the incidence of ADRs and changes in
28, 2017) was issued to change the format of the incidence of ADRs due to factors such as
reports, and to require submission of the reports by dosage, duration of administration, complications, or
electronic media. Moreover, "Q&A on the System concomitant medication should be detected and
of Periodic Infection Reports for Regenerative assessed.
Medicine Products and Biological Products" (Office When the revised Pharmaceutical Affairs Law
Communication dated July 29, 2017) was issued in was enforced from April 1997, the surveillance and
July 2017. studies required for reexamination applications must
be performed in compliance with the GPMSP, GCP
6. REEXAMINATION SYSTEM (ARTICLE 14-4 or GLP depending on their objective. It is also
AND 23-29 OF THE PHARMACEUTICAL obligatory to prepare application data in accordance
AFFAIRS LAW) with these standards. Based on the revision of the
Law in April 2005, the GPMSP has been abolished
The reexamination system is aimed at and replaced with the GPSP and GVP.
reconfirmation of the clinical usefulness of drugs by
performing GPSP or GVP as one aspect of PMS,
6.1 Designation for Reexamination of Drugs
through collecting information on the efficacy and
safety of the drug during a specified period of time The drugs subject to reexamination include
after approval. This system was commenced in products designated by the MHLW at the time of
April 1980. Based on the revision of October 1993, marketing approval as drugs with, for example,
the reexamination period for orphan drugs was active ingredients, quantities of ingredients, dosage
extended to a maximum of 10 years. and administration, and/or indications that are
distinctly different from drugs that have already been
There are limitations on the quantity and quality
approved (Article 14-4 of the Law).
of data submitted for review at the time of approval
of a new drug. Examples of such limitations The timing when these drugs should be
include relatively small numbers of subjects in reexamined is designated by the MHLW at the time
clinical studies performed prior to approval, relatively of their approval as new drugs. The times that
short use data of the drug, and lack of experience reexaminations should generally be conducted for
using the drug under diverse conditions such as specific products are given below.
concomitant medication, complications, and age. (1) Reexamination 10 years after the date of

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approval: of an orphan drug: 10 years


 Orphan drugs
 Products covered by the SAKIGAKE 6.2 Periodic Safety Reports (Article 63 of the
Designation System (to be judged Enforcement Regulations of the Law)
individually during the review process) On the basis of agreements at the ICH
(2) Reexamination 8 years after the date of concerning the periodic safety update report
approval: (PSUR) system, however, a "periodic safety report

 Drugs containing new active ingredients system" was enacted into law at the time of revision
to the Pharmaceutical Affairs Law in April 1997. In
(3) Reexamination 6 years after the date of
May 2013, the PSUR system was replaced with the
approval:
periodic benefit-risk evaluation report (PBRER)
 New prescription combination drugs system following the release of ICH E2C (R2)
 Drugs with new routes of administration guidelines.
(4) Reexamination from 4 to within 6 years As the base date for the reporting period of these
after the date of approval: reports, the concept of the international birth date in
 Drugs with new indications the PBRER system was introduced. Based on this
 Drugs with new dosages concept, the date designated by the MHLW at the
time of approval is established as the base date.
When pharmacoepidemiological surveys or
The frequency of reports is every 6 months during
clinical studies for setting pediatric doses performed,
the first 2 years from this base date. Thereafter,
the study period can be prolonged before
reports are to be submitted once each year during
completion of the reexamination period as required
the remaining period of reexamination. The drugs
(maximum reexamination period: 10 years).
for which these reports are applicable include
When an additional indication is obtained during
prescription medicines designated for reexamination
the reexamination period, the reexamination period
(medical devices are subject to annual reporting as
for the additional indication will be as described
previously). In the event that a drug is marketed in
below.
a foreign country, reports must specify any adverse
• When the existing indication is a usual drug reactions that appeared in that country and
indication information about any regulatory measures
When the additional indication is a usual adopted. In addition, when PBRER prepared by
indication: 4 years or the residual period of the foreign companies should be appended to the
reexamination period for the existing Japanese Periodic Safety Report together with the
indication information obtained in drug use-results survey in
When the additional indication is an indication the section "Future Safety Measures Planned on
of an orphan drug: 10 years the Basis of Surveillance Results" in the Periodic
Safety Report, and submitted, or the contents of the
• When the existing indication is an indication of
PBRER should be compiled and incorporated into
an orphan drug
the Japanese Periodic Safety Report and submitted.
When the additional indication is a usual
Either method is acceptable. A summary of the
indication: 5 years and 10 months
report items to be submitted includes the following:
When the additional indication is an indication
 Period of the survey

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Pharmaceutical Regulations in Japan:

 Number of cases surveyed (1) Summary of data for reexamination


 Quantity of product shipped applications
 Status of implementation of drug The data should include a summary of the drug
use-results survey specified in the application; specific details up to the
 Summary of the surveillance results and time of reexamination application including the
analysis of the data changes in quantity and value of product shipped
 Incidence of adverse drug reactions and the estimated number of patients who used the
classified by type drug, the status of approval and sales overseas;
 A list of cases in which adverse drug summary of post-marketing surveillance;
reactions occurred information about safety and efficacy; conclusion;
 Measures adopted to ensure proper and references.
product use such as revisions of the
(2) Data Attached to Reexamination
precautions
Applications
 Package inserts
This data should include summary of drug
 Future safety measures planned on the
use-results surveys; specified drug-use survey
basis of surveillance results
reports; post-marketing clinical trial reports; data
from patients who have developed adverse drug
6.3 Data Required for Reexamination
reactions or infections; data from research reports;
Applications and Reexamination
reports of specific measures adopted in Japan and
Procedures
overseas; and reports of serious adverse drug
Post-marketing surveillance to acquire data reactions.
required for reexamination applications, including (3) Compliance survey data
drug use-results surveys, specified drug-use
This includes data from GPSP compliance
surveys, and post-marketing clinical trials, must be
reviews as well as data from GCP and/or GLP
implemented in accordance with the GPSP. The
compliance reviews as required.
data must also be collected and prepared in
accordance with these standards (post-marketing (4) Reference data
clinical trials must be conducted also in compliance This includes, for example, case report forms
with the GCP). used in drug use-results surveys, package inserts at
the time of reexamination application, summaries of
Applications for reexamination must be
replies, review reports, a summary of the data at the
completed within 3 months from the time of the
time of product approval application (for Evaluation
designated base date. The data submitted and
Committees), copies of approval forms, and a copy
organization of this data should generally be as
of periodic safety report submitted closest to the
described below, with a focus on data from specified
reexamination application.
drug-use surveys and post-marketing clinical trials of
the drug concerned in the application. In addition, Reexamination is based on submission of the
for any other research data acquired after drug above application data. Fig. 16 Reexamination
approval related to indications and/or safety of the System is a flow diagram of this reexamination
drug concerned, a Periodic Safety Report submitted process. After the application is received, the
near the date of the reexamination application PMDA evaluates compliance with standards such
should be attached. as GPSP and conducts surveys on quality, efficacy,

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Pharmaceutical Regulations in Japan:

and safety. The application is next reviewed by the reevaluations of the efficacy and safety of all
Department on Drugs of the PAFSC. Then, the prescription drugs was started in May 1988.
MHLW issues an official report of the results of the These reevaluations are at first performed by
examination. The results of these examinations means of a review by the PAFSC. When the
are classified into one of the three approval Council's decision requires further literature
categories shown below, and any required specific surveys by the manufacturers, they are required
measures are adopted. Article 14 Paragraph 2-3 to perform such surveys according to the
of the Pharmaceutical Affairs Law specifies three provisions of the Pharmaceutical Affairs Law (Fig.
reasons for refusal of approval. These include 17 Reevaluation System).
cases where (1) the indications of the drug stated in
the application have not been demonstrated; (2) the
The new reevaluations were designated from
drug exhibits prominent harmful effects that
February 1990.
outweigh any target indications, thus rendering the
The MHLW has implemented various measures
product not useful; and (3) the drug is judged to be
related to generic drugs. In the final report of the
markedly inappropriate with respect to public health
Council on the Pharmaceutical Sector in the 21st
and hygiene because of its characteristics or quality.
Century issued on May 28, 1993, it was suggested
* Designated Classifications that manufacturing control and quality control must
be thoroughly implemented for all products including
[I] Approval refused (manufacturing and
original drugs. For this purpose the dissolution test
marketing suspended, approval revoked)
was proposed as a routine verification method. In
[II] Changes in approval (modifications in February 1997, "quality reevaluation" was started,
approved items as directed) and dissolution test conditions and specifications
[III] Approved (as per application for were set for original drugs that had no specified
reexamination) dissolution test. This step was intended to assure
the quality of generic drugs by confirming their
equivalence to the original products.
7. REEVALUATION SYSTEM (ARTICLES
14-6 AND 23-31 OF THE LAW) Thereafter, a notification entitled the "Guidelines
for Bioequivalence Studies on Generic Drugs" was
The reevaluation of drugs is a system whereby
issued in December 22, 1997 and partially revised
the efficacy and safety of a drug, which has already
on May 31, 2001 (Notification No. 786 of the
been approved, is reconsidered on the basis of the
Evaluation and Licensing Division, PMSB) and on
current status of medical and pharmaceutical
November 24, 2006 (Notification No. 1124004 of the
sciences. This system was initiated in December
Evaluation and Licensing Division, PFSB) and
1971 on the basis of administrative guidance in
February 29, 2012 (Notification No. 0229-(10) of the
Notification No. 610 of the PMSB dated July 7,
Evaluation and Licensing Division, PFSB) to
1971. From January 1985, reevaluations were
guarantee the therapeutic equivalence of generic
based on the Pharmaceutical Affairs Law, and the
drugs to the original drugs.
new reevaluation system came into effect from May
For products with dissolution tests established
1988.
after completion of quality reevaluation, "official
New Reevaluation System: dissolution tests" were included in the third section
This new reevaluation system aimed at of the Japanese Pharmaceutical Codex, which was

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Pharmaceutical Regulations in Japan:

published on March 23, 1999.

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Pharmaceutical Regulations in Japan:

Post-marketing
surveillance GVP, GPSP (GCP)
(PMS) system

Adverse reaction and


infectious disease
reporting (ADR) system
Drug / medical device safety information reporting
system by medical personnel

ADR and infectious disease reporting system by


company

WHO international pharmaceutical monitoring system

Reexamination system

Reexamination application

Periodic safety reports – ICH / PBRER

Reevaluation system

Fig. 13 Pharmaceutical Post-marketing Surveillance System

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Pharmaceutical Regulations in Japan:

Drug use-results surveys, special survey, and


post-marketing clinical trials

Planning of early Marketing 6 months


post-marketing
phase vigilance

Visits of MRs to
physicians to provide
safety information
and to ask
cooperation

Early post-marketing
phase vigilance

Promotion of proper use of drugs by means of periodic visits, sending


letters, faxes, and E-mails to physicians by marketing authorization
holders and wholesalers

ADR and other


safety
information

Pharmaceutical safety information reporting system

Safety reporting system by pharmaceutical companies

Fig. 14 Post-marketing Collection and Reporting of Pharmaceutical Safety Information

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Pharmaceutical Regulations in Japan:

• WHO international pharmaceutical


monitoring system
• Foreign regulatory authorities, such as
FDA

Information exchange

Ministry of Health,
Labour, and Welfare
• Medical assoc. Information (MHLW) Evaluation
Dissemination Pharmaceutical Affairs
• Dental assoc. and Food Sanitation
Pharmaceutical and
• Pharmaceutical assoc. Examination Council (PAFSC)
Medical Device Agency
(PMDA)
(Collection, analysis and
evaluation of reports
from industries)

Pharmaceutical safety
information reports
ADR & infection reports
Periodic safety reports
Reexamination
Administrative Reevaluation
measures/
guidance

Information Information
• Hospitals collection exchange
• Manufacturer/ Foreign
• Clinics
Marketing companies
• Dental clinics Dissemination ADR
authorization holder
• Pharmacies PBRER
Regulatory
information

Fig. 15 Collection and Reporting of Pharmaceutical Safety Information

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Pharmaceutical Regulations in Japan:

( MHLW ) ( PMDA)

Receipt of reexamination application

Reliability review of application data


・GPSP review
・Verification from source data

Review on quality, efficacy, and


safety

Checking of review report Preparation of review report

Submission

Report to, review (or report), and


discussions with PAFSC Committees

Publication of reexamination results

Fig. 16 Reexamination System

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Pharmaceutical Regulations in Japan:

(MHLW) (PMDA)

Selection of reevaluation ingredients


and items

Review by PMDA

Report to, review, and discussions


with PAFSC Committees

Reevaluation designation Receipt of reevaluation application

Reliability review of application data


・GPMSP review
・Verification from source data

Review on quality, efficacy, and safety

Checking of review report Preparation of review report

Submission

Report to, review and discussions


with PAFSC Committees

Publication of reevaluation results

Fig. 17 Reevaluation System

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Pharmaceutical Regulations in Japan:

CHAPTER 5 and information obtained in latest literatures, etc. and


that brand names and precautions for usage and
SUPPLY AND DISSEMINATION handling should be noticed prior to initiation of
manufacturing/marketing or amendment followed by
OF DRUG SAFETY prompt publication. It also specifies penalties for not
complying with these provisions and for including
MANAGEMENT INFORMATION
false or exaggerated information in package inserts.
The MHLW has also issued notifications that provide
guidelines on the actual items to be included, order of
Manufacturing/marketing authorization holders of
their inclusion, and preparation of package inserts, as
drugs must collect and examine information on proper
well as guidelines on the preparation of Precautions
use of drugs such as information on drug efficacy,
for package inserts. Important information on
safety and quality, and supply this information to
adverse reactions, etc. obtained and evaluated in
medical institutions as specified in the Law. For this
post-marketing surveillance on product safety must
purpose, drug marketing authorization holders should
be reflected in package inserts. Because of the
prepare standard operating procedures based on the
limitations on space and the amount of information
provisions in the GVP ordinance and endeavor to
that can be presented in package inserts,
establish a comprehensive system for the supply and
manufacturers and marketing authorization holders
dissemination of information on proper and safe use
may prepare various types of information to
of drugs.
supplement the package inserts.
Concerning the format and the contents of the
1. PACKAGE INSERTS
package inserts and precautions for use, the
The most basic tool for supplying information on necessity of a complete reconsideration of package
drugs to health professionals is package inserts, and inserts was pointed out in the final report of the
the contents of package inserts for prescription drugs Council on 21st Century Pharmaceuticals entitled
have been specified by the Pharmaceutical Affairs "Proper Use of Drugs in Future Health Care and the
Law. These package inserts are public documents Role of the Regulatory Authorities" in May 1993, and
that pharmaceutical marketing authorization holders in the interim report of the Study Committee on
are obliged to prepare for the purpose of supplying to Measures to Promote Appropriate Use of Drugs in
health professionals including physicians, dentists and July 1995. At about the same time, the Sorivudine
pharmacists the information necessary to assure the incident involving a very severe adverse reaction
safety of patients administered the drug and to caused by the interaction of this antiviral agent and an
promote the proper use of the drug concerned based anticancer drug occurred, and the MHW (currently
on the provisions of the Law. The Law specifies MHLW), health professionals and pharmaceutical
items which must be included in package inserts or companies considered emergency measures to
containers/wrappers (package insert information), assure proper supply of information on drug safety,
points to consider in preparing package inserts and mainly related to interactions (Notification No. 999 of
items which are not allowed to be included in package PAB dated November 24, 1993 and Notice No. 1445
inserts. The revised Law enacted on November 25, of the Japan Pharmaceutical Manufacturers
2014 included the provisions that package insert Association dated November 21, 1994).
information should be based on scientific knowledge To cope with this problem, the MHW (currently

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Pharmaceutical Regulations in Japan:

MHLW) established three special committees on the were issued to make the package inserts easier to
revision of pharmaceutical package inserts, which understand and easier to use on the basis of a
completed their work and submitted reports in May proposal in Health and Labour Sciences Research
1996. Based on these reports, guidelines for and subsequent examination, reflecting the dramatic
package inserts and for Precautions were completely changes in the situation surrounding medicine,
revised, and the following three notifications were including advancement of medical care, aging of the
issued in April 1997: society, and advancement of IT technology.
(1) Guidelines for Package Inserts for (1) Guidelines on Preparation of Package Inserts
Prescription Drugs (Notification No. 606 of for Prescription Drugs (Notification No. 0608-(1)
PAB dated April 25, 1997). of the PSEHB dated June 8, 2017)
(2) Guidelines for Package Inserts for (2) Points to Consider Regarding Guidelines on
Prescription Drugs (Notification No. 59 of the Preparation of Package Inserts for Prescription
Safety Division, PAB dated April 25, 1997). Drugs (Notification No. 0608-(1) of the Safety
(3) Guidelines for Precautions for Prescription Division, PSEHB dated June 8, 2017)
Drugs (Notification No. 607 of PAB dated The major points of improvement are
April 25, 1997). reconsideration of the items and structure, including
The main points in these notifications are as abolishment of the sections of “Relative
follows: contraindications” and “Careful administration,” and
addition of a section of “Use in patients with special
 Package inserts have been revised to make
backgrounds," and overall improvement of the
them easier to understand and to use by health
information to be entered. The guidelines will be
professionals.
applied from April 2019 (the transitional measure
 The purpose is to supply scientifically accurate
period will be 5 years.).
information.
The notification entitled “Enforcement of The Law
Two notifications concerning package inserts for
for Partial Amendment of the Pharmaceutical Affairs
biological products were issued in May 2003: “Entries
Law”(Notification No. 0806-(3) of PFSB dated August
in Package Inserts for Biological Products”
6, 2014) specified that precautions for usage and
(Notification No. 0515005 of the PMSB dated May 15,
handling based on the latest scientific knowledge
2003) and “the Guidelines for Entries in Package
and information should be prepared to promptly
Inserts of Biological Products” (Notification No.
reflect essential cautions, etc. based on outcome from
0520004 of the Safety Division, PMSB dated May 20,
evaluation of safety information including adverse
2003). These notifications came into effect from July
drug reactions collected according to the provisions in
2003.
the Law and the MHLW Ordinance on GVP.
To improve the supply of information on generic Package inserts must include the package insert
drugs, Notification No. 0324006 of the Safety Division, information based on latest findings, nonetheless
PFSB dated March 24, 2006 was issued. This package inserts prior to amendment may be attached
notification specifies the entry of bioequivalence study in the following exceptional amendment case:
data in the “Pharmacokinetics” section of the package
(1) When the products had already been
insert.
manufactured and distributed prior to
After that, the guidelines on preparation of package amendment of package insert information
inserts were revised and the following notifications (post-marketing products),

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Pharmaceutical Regulations in Japan:

(2) When the package insert includes all of the date of package insert information, publication may be
information before amendment (that is, old made in line with the scheduled amendment date.
package insert printed at the time of Of note, it is possible that information provision of
amendment), and all of the following the amended package insert information may be
requirements are met: initiated upon submission of the notification to the
i. The products are manufactured and distributed PMDA, however it is recommended that such
within 6 months after the amendment date information is provided upon confirmation of PMDA’s
(within 1 year in cases of amendment of acceptance, because some modification may be
package insert information of products requiring needed when any inadequacy was found at
testing or multiple products, which cannot be confirmation from the PMDA (Office Communication
manufactured and marketed promptly with the of the Safety Division, PFSB dated September 1,
amended package insert information), 2014).
ii. The amended package insert information are
published on the PMDA homepage, and 1.1 Guidance on the Style and Format of
iii. The manufacturing/marketing authorization Package Inserts
holder of the product may promptly notify users 1) Coordination of formats
including physicians or pharmacists of
(1) Items considered important must be
information on amendment of package insert
entered close to the beginning of the
information.
package inserts.
For submission of notifications, it was specified in
(2) "Warnings" and "Contraindications"
the “Points to consider for notification of package
must be entered at the beginning of the
insert information” (Notification No. 0901-(1) of the
package inserts. Package inserts with
Safety Division, PFSB dated September 1, 2014) that
"Warnings" have a red bracket-shaped
notifications should be submitted on the web page for
band printed in the right margin. The
notification via the PMDA homepage before initiation
"Warnings" must be in red letters
of manufacturing/marketing in cases of notifications
encased in red and "Contraindications"
for products to be newly manufactured/marketed
must be encased in red.
including new drugs (nonetheless, when information
(3) Overlapping entries under two or more
provision to medical institutions, etc. is started prior to
headings should be avoided, in principle.
initiation of manufacturing/marketing, the notification
should be submitted in advance preferably), or before (4) The size of the package insert should be
the initiation date of information provision of the within four A4 size pages, in principle.
amendment or the initiation date of 2) Improved contents
manufacturing/marketing of products with the
(1) The "Precautions" must follow
amended package insert, whichever is earlier, in "Indications" and "Dosage and
cases of amendment of package insert information. Administration" in that order.
It was also specified that package insert information
(2) The incidence of adverse reactions must
should be published on the PMDA homepage
be given in numerical values with
promptly upon submission of the notification to the
appropriate classifications whenever
PMDA. Nonetheless, when there is a certain time
possible.
between the notification date and the amendment

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Pharmaceutical Regulations in Japan:

(3) "Adverse Reactions," "Interactions" etc. the PAB and Notification No. 59 of the Safety Division,
must be as clearly visible as possible PAB) and notifications related to biological products
using tables, etc. (Notification No. 0515005 of the PMSB and
(4) The former headings "Drug Notification No. 0520004 of the Safety Division,
Characteristics and Development PMSB). For changes in entries in package inserts
Process" and "Nonclinical Studies" have with the enforcement of the amended Pharmaceutical
been abolished, and the required Affairs Law in April 2005, refer to Notification No. 133
information must be supplied in a of the Japan Pharmaceutical Manufacturers
scientifically accurate manner by Association (JPMA) dated March 4, 2005 and
improvement of the information given Notification No. 0324006 of the Safety Division, PFSB
under such headings as "Clinical dated March 24, 2006 concerning supply of
Pharmacology" and "Pharmacokinetics." information on generic drugs.
* Headings and Their Sequence in Package
3) Addition of new headings
Inserts
(1) The new heading "Conditions for
1) Date of preparation and/or revision(s) of the
Approval" has been added.
package insert
(2) This heading consists of a list of the
2) Standard Commodity Classification No. of
dates of entry in the NHI
Japan, etc.
Reimbursement Price List, initial
marketing in Japan, publication of the  Standard Commodity Classification No. of Japan
latest reexamination and/or reevaluation (SCCJ)
results, latest approval of (additional)  Approval number
indications, the international birth date,  Date of listing in the National Health Insurance
etc. (NHI) Reimbursement Price List
 Date of initial marketing in Japan
1.2 Headings and Their Sequence in Package
 Date(s) of latest reexamination
Inserts
 Date(s) of latest reevaluation
The actual headings and the sequence in which
 Date(s) of latest approval of additional
they are entered in package inserts for prescription
indication(s)
drugs are shown below. Refer to Fig. 18 Layout of a
 International birth date
Package Insert for a Prescription Drug (with
“Warning”) for the layout. Refer to Fig. 19 Layout of  Storage, etc. (storage, expiration date, shelf-life,
a Package Insert Based on Revised Guidelines for etc.)
Preparation (Image) for the layout of a package insert 3) Therapeutic category
(image) after revision of the guidelines for preparation. 4) Regulatory classification (specified biological
All of the headings should be included whenever product, biological product, poisonous
possible, but when no appropriate information is substance, deleterious substance,
available, the heading may be omitted. habit-forming drug, prescription drug, etc.)
For details of the contents of the headings in 5) Name(s) [brand name, non-proprietary name,
package inserts, refer to the three MHW notifications Japanese Accepted Name (JAN), etc.]
mentioned above (Notifications No. 606 and 607 of ♦ At the beginning of the package insert

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Pharmaceutical Regulations in Japan:

Precautions concerning specified biological 1.3 Precautions


products (encased in black)
Reference: Age classification for pediatric use
6) Warning(s) (in red letters encased in red)
(basic standards)
7) Contraindications (in black letters encased in
• Children: under 15 years of age
red)
• Small children: under 7 years of age
(1) Contraindications
• Infants: under 1 year of age
(2) Relative contraindications
• Newborns (neonates): under 4 weeks of
8) Composition and description
age
(1) Composition
• Low birth weight infants (premature
(2) Product description infants): body weight of less than 2,500 g
9) Indication(s) (according to the WHO recommendation)
(1) Indication(s) The Precautions are prepared voluntarily by the
(2) Precautions related to Indications manufacturer of the drug concerned or under the
10) Dosage and administration guidance of the MHLW based on the guidelines in the
MHLW notifications listed previously. Information
(1) Dosage and administration
obtained from post-marketing drug use results (clinical
(2) Precautions related to dosage and
experience) surveys, and foreign and domestic case
administration
reports and research reports is collected and
11) Precautions (refer to Notifications No. 606 of evaluated, and the Precautions are revised to
PAB, No. 59 of the Safety Division, PAB, No. incorporate the latest data as required. Revisions
607 of PAB, No. 0515005 of PFSB, and No. based on the results of reexaminations and/or
0520004 of the Safety Division, PMSB) reevaluations are undertaken as required.
(refer to Sections 1.3 and 1.5)
The headings* used in the Precautions are as
12) Pharmacokinetics follows. Refer to the following MHW notifications: (1)
13) Clinical studies No. 606 of PAB, (2) No. 59 of the Safety Division,
14) Clinical pharmacology PAB and (3) No. 607 of PAB, and notifications related

15) Physicochemistry (active ingredient) to biological products (Notification No. 0515005 of the
PMSB and Notification No. 0520004 of the Safety
16) Precautions for handling
Division, PMSB) for details concerning the contents of
17) Conditions for approval Precautions.
18) Packaging
* Headings used with precautions
19) References and reference requests
1) "Warning" (in red letters and encased in red
♦ Information of drugs with limited at the beginning of "Precautions")
administration periods
2) "Contraindications" (in black letters and
20) Manufactured and/or marketed by: (name encased in red following "Warning" in
and address) principle. However, at the beginning of the
Precautions when there is no "Warning")
(1) Contraindications ("This product is
contraindicated in the following patients.")

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Pharmaceutical Regulations in Japan:

(2) Relative contraindications ("As a general 10) Use during pregnancy, delivery, or lactation
rule, this product is contraindicated in the 11) Pediatric use (low birth weight infants,
following patients. If the use of this newborns, infants, small children, children)
product is considered essential, it should
12) Effects on laboratory tests
be administered with care.")
13) Overdosage
3) Precautions related to indications (In the
14) Precautions concerning use
event of such precautions, they are entered
under the heading "Precautions" following 15) Other precautions (toxicity obtained in animal
"Indications" in the package insert.) studies requiring particular caution, etc.)

4) Precautions related to dosage and


1.4 Labeling of Excipients
administration (In the event of such
precautions, they are entered under the When excipients such as stabilizers,
heading "Precautions" following "Dosage preservatives, and vehicles are used in products listed
and Administration" in the package insert.) in the Japan Pharmacopoeia (JP), in the Minimum
5) Careful administration ("This product should Requirements for Biological Products or in the
be administered with care to the following Radiopharmaceutical Standards, the names and
patients.") quantities of these excipients must be included in the
relevant package inserts or on the containers or
6) Important precautions
wrappers.
7) Drug interactions
Since safety problems considered to be caused by
(1) Contraindications for coadministration
excipients have appeared, the names and quantities
("This product should not be
of excipients specified in Notification No. 853 of the
coadministered with the following drugs.")
PAB dated October 1, 1988 must be included in the
(in black letters and encased in red, with
relevant package inserts or, if necessary, on the
simple explanation provided under
containers or wrappers of all prescription drugs since
"Contraindications" above.)
October 1988.
(2) Precautions for coadministration
All ingredients are included in the package insert
• The MHW issued an office communication based on a voluntary agreement of the Federation of
stressing that the Drug Interaction section Pharmaceutical Manufacturers' Associations of Japan
must be based on the most recent scientific (FPMAJ) (FPMAJ Notification No. 170 dated March
findings [office communication dated 13, 2002) because of the social responsibility to
December 25, 2000 as a supplement of disclose as much information as possible related to
Notification No. 607 of PAB, MHW]. drugs as life-related products.
8) Adverse reactions (incidence shown in
numerical values whenever possible) 1.5 Entries for Biological Products
• A key to the frequency of adverse reactions
Specified biological products
should be provided at the beginning.
1) Regulatory classification
(1) Clinically significant adverse reactions
Specified biological products
(2) Other adverse reactions
2) Name
9) Use in the elderly
For genetic recombinants, “recombinant” is

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Pharmaceutical Regulations in Japan:

included immediately after the 2) Name


non-proprietary name For genetic recombinants, “recombinant” is
3) Beginning of the package insert (before the included immediately after the
“Warning”) non-proprietary name
(1) Risk of spread of infections derived from 3) Composition and description
raw materials can not be completely (1) Names of ingredients among raw
eliminated. materials and packaging materials
(2) Summary of safety measures derived from humans or other organisms
undertaken to prevent spread of (2) Names of parts of humans or other
infection. organisms among raw materials
(3) Use must be kept to a minimum after (3) Name of country where blood was
careful investigation of necessity in collected as a raw material and
treatment of disease. collection methods (donor blood or
4) Composition and description non-donor blood)
(1) Names of ingredients among raw 4) Other items required for proper use
materials and packaging materials
derived from humans or other organisms 1.6 Brand Names of Prescriptions Drugs
(2) Names of parts of humans or other For prevention of medication accidents related to
organisms among raw materials prescription drugs, Notification No. 935 of the PMSB
(3) Name of country where blood was was issued on September 19, 2000 to specify that
collected as a raw material and brand name should include information of the dosage
collection methods (donor blood or form and specification or content in addition to brand
non-donor blood) name (example, XXXX Capsules 25 mg) in principle.
5) Precautions, Important Precautions By Notification No. 0602009 of the PFSB dated June
Health professionals such as physicians 2, 2004, relevant companies were requested to take

must explain to persons using the drug the active measures. The notifications issued jointly by

efficacy and safety and other measures directors of the Evaluation and Licensing Division and
required for proper use of the drug the Safety Division, PFSB specified handling of brand

concerned. names of prescription combination drugs and heparin


preparations (injection) and labeling of solutions
6) Precautions for handling
attached to injection (Notification No. 0922002 of the
Health professionals such as physicians Evaluation and Licensing Division, PFSB and No.
must record the names and addresses of 0922002 of the Safety Division, PFSB dated
persons using the drug and preserve such September 22, 2008) and handling of brand names of
records in medical institutions, etc. insulin preparations (Notification No. 0331001 of the
7) Other items required for proper use Evaluation and Licensing Division, PFSB and No.
Biological products (excluding specified biological 0331001 of the Safety Division, PFSB dated March
products) 31, 2012). Handling of brand names of prescription
1) Regulatory classification combination drugs and insulin preparations was
partially amended in Notification No. 0710-(7) of the
Biological product

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Pharmaceutical Regulations in Japan:

Evaluation and Licensing Division, PFSB and No. Product Information


0710-(5) of the Safety Division, PFSB dated July 10,
The Outline of Prescription Pharmaceutical
2014). The brand name of generic drugs is required
Product Information is prepared by the
to be a name based on the Japanese Accepted
manufacturing/marketing authorization holders with
Name as directed in Notification No. 0922001 of the
the objective of providing accurate and appropriate
Evaluation and Licensing Division, PFSB dated
information to health professionals to promote proper
September 22, 2005 and the brand name of
use of their drugs. The material is available in two
biosimilar products as directed in Notification No.
types: the general outline version explaining the entire
0214-(1) of the Evaluation and Licensing Division,
description of the product (containing information
PFSB dated February 14, 2013.
under all headings of package insert) and
For generic drugs of combination drugs, unified property-specific version (containing information
brand names had been discussed, and since August under certain headings of package insert such as
2013, these have been managed in accordance with clinical studies and clinical pharmacology).
voluntary consensus that unified brand names may
The Outline of Prescription Pharmaceutical
be retained by Japanese Society of Generic and
Product Information is prepared on the basis of the
Biosimilar Medicines as trade names and used by
“Guidelines for Preparation of Outlines of Prescription
companies on a license basis.
Pharmaceutical Product Information” (prepared by the
The application fee for revising brand name was Japan Pharmaceutical Manufacturers Association
lowered in April 2005. The timing of brand name [JPMA], developed in September 2015). To ensure
revision for prevention of medical accident is the time consistency of the content with that of the package
for NHI price listing twice a year. As a result, insert, attention should be paid to the JPMA Code of
measures have been completed for a total of about Practice.
5,400 products as of the NHI price listing in
In addition, the Outline of Prescription
September 2009.
Pharmaceutical Product Information is internally
reviewed by the pharmaceutical company and
1.7 Information on Package Inserts in English voluntarily reviewed by JPMA. Because
Information on package inserts in English of drugs administrative disciplinary actions were taken in 2014
prepared by manufacturing/marketing authorization and 2015 against the advertisement violating the law
holders in Japan is available on the following JPMA (Article 66) that prohibits false or exaggerated
homepage. advertisements, the system to strengthen the internal
http://www.e-search.ne.jp/~jpr/ review system of pharmaceutical companies was
introduced in 2016, such as placement of the
responsible organization of the internal review outside
2. INFORMATION TO SUPPLEMENT of the sales division and involvement of a third party in
PACKAGE INSERTS the internal review in principle. For the voluntarily
Because of space limitations in Japanese review of JPMA, expansion of the scope and
package inserts, the following main media are also of introduction of the electronic review system were
use to provide more detailed information about conducted in 2017.
pharmaceutical products. On the other hand, the Ministry of Health, Labour
and Welfare started a system to monitor advertising
2.1 Outline of Prescription Pharmaceutical activities in 2016. In this system, medical institutions

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Pharmaceutical Regulations in Japan:

are extracted and selected from the institutions academic material to be used in explanations and
throughout Japan as monitor medical institutions. If discussions concerning the product.
they find problematic issues (such as inappropriate or The Japanese Association of Hospital
unscientific expressions, information which is not Pharmacists published new preparation guidelines in
supported by review reports, etc.) in the materials or April 2013, and interview forms (IF) are being
explanations provided to them by pharmaceutical prepared in the new format for new drugs approved
companies or any journals for health professionals, from October 2013.
they will report the issues to the secretariat. The "Guidelines for preparation of interview forms for
issues are examined in the case conferences held generic products" was issued by the Japan Generic
approximately once a month with participation of medicines Association for generic products. The
specialists. Administrative directions will be given guidelines mainly introduce the examples of the
through the prefectural government in malicious sections describing the data which are deemed to be
cases. At the same time, reconsideration of the unique to generic products, such as the results of
voluntary codes of industry groups will be requested bioequivalence studies, elution studies, and stability
in unfavourable cases. studies, as well as the procedures for describing
New drugs that are approved after October 2001 these issues. The guidelines are used as the
are marked with a logo commonly adopted by the standards for preparation of IF together with the
pharmaceutical industry indicating that the drug is guidelines of the Japanese Association of Hospital
subject to early post-marketing phase vigilance for Pharmacists.
such a period of time as specified in labeling. It has
Basically, IFs are provided in electronic media of
also been decided that the RMP mark commonly
PDF files, which are available on HP of PMDA.
adopted by the pharmaceutical industry is attached
on the materials prepared and distributed for the
purpose of additional risk minimization activities in the 3. SUPPLY AND DISSEMINATION OF SAFETY
risk management plan (RMP) for drugs with the aim MANAGEMENT INFORMATION
of improving the awareness of health professionals (to For the proper use of drugs, it is important that the
be applied to the materials prepared or revised on necessary information be supplied and disseminated
June 5, 2017 or thereafter) (refer to Chapter 4, 1. in an appropriate and timely manner to health
GVP). professionals.
Safety management information reported to the
2.2 Pharmaceutical Interview Forms (IF) MHLW, etc. is evaluated by the PMDA after hearing
Pharmaceutical Interview Forms also serve to opinions of experts. After the Committee on Safety
supplement package inserts. The IF basically of Drugs of the Council on Drugs and Food Sanitation
specifies questions to be asked by pharmacists to approves the results, the necessary administrative
obtain detailed information on pharmaceutical measures based on the evaluation results are taken.
products in interviews with pharmaceutical company These administrative measures include the following:
medical representatives (MRs). However, in order to • Discontinuation of manufacturing or
reduce the burden on physicians and MR, the replies marketing of drugs, and instructions for
(detailed information) to the questions are already recall of products
entered, and the IF are supplied to health
• Cancellation of approval
professionals from pharmaceutical company as

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Pharmaceutical Regulations in Japan:

• Partial changes in approved items related to PMDA, a basic time schedule in weekly units is
indications, dosage and administration, etc. prepared in which the PMDA first sends an inquiry to
• Instructions for distribution of emergency the company, the company submits its opinions, an
safety information interview advice meeting is held, a meeting of experts
is convened (convened about every 5 weeks), and
• Instructions for distribution of safety flash
measures (issuing of notifications, etc.) are taken.
reports (so-called blue letters)
When the company considers that it is necessary to
• Instructions for revision of Precautions
investigate safety measures, the same type of
• Changes in designation as controlled schedule is shown starting with a revision consultation
substances such as poisons, narcotics, or from the company, holding an interview (face-to-face)
prescription drugs, or changes of regulatory advice meeting, convening a meeting of experts, and
category taking measures (refer to Fig. 20 and Fig. 21) .
• Instructions to companies to perform The PMDA receives applications for consultation
surveillance or research from companies for not only revision of package
Among these measures, extremely urgent and inserts of individual drugs but also for promotion of
important safety-related information to warn the public proper use to prevent serious adverse drug reactions,
and healthcare professionals of safety concerns or to treatment safety, and other measures to improve
restrict the use of products will be distributed as safety of drugs. Accurate advice and guidance are
emergency safety information, and information given to the companies, and this contributes not only
necessary for improving their precautions on safety to the improvement of the safety of individual drugs
concerns earlier than the conventional approach but also to improvement of the system for safety
through package inserts revision will be distributed as measures of the company.
safety flash reports. Refer to the following PMDA homepage for
In addition to emergency safety information and consultations on revision, etc. of package inserts
safety flash reports, other information including applied for by companies and procedures for
notices of revision of Precautions is also distributed, applications for other consultations.
but these are the most frequently used administrative http://www.pmda.go.jp/safety/consultation-for-mah/00
measure. 01.html
In order to facilitate efficient revision of package Media and procedures for provision and
inserts of drugs, revision of precautions for use, etc., a dissemination of safety management information
“Flowchart of standard procedures related to work on include the obligation to prepare SOPs by drug
package inserts of drugs” has been specified in Office marketing authorization holders based on the
Communication of the Safety Division, PFSB dated specifications in the GVP Ordinance, and provision
November 25, 2014. This flowchart is posted on the and dissemination of information based on these
PMDA homepage "Consultation regarding SOPs.
examination/implementation of safety measures (for
The main information media and information
companies)."
dissemination procedures are described below.
http://www.pmda.go.jp/files/000144200.pdf
When the PMDA considers that an investigation of
safety measures is necessary as a result of screening
(primary and secondary) of data collected by the

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Pharmaceutical Regulations in Japan:

3.1 Distribution of Emergency Safety ● Changes in indications, dosage, method of


Information (Yellow Letters) administration, or method of use, etc. for
safety-related reasons
1) Preparation criteria
Emergency safety information (“yellow letter”) is ● Regulatory measures (discontinuation or
prepared by the marketing authorization holder on the suspension of marketing or cancellation of
basis of discussion with the MHLW and PMDA approval) for safety-related reasons,
following an order or instruction of the MHLW, accompanying a recall of a drug
voluntary decision by the marketing authorization ● Other measures for the prevention or early
holder, or other requirements in cases where it is detection of ADRs concerned
judged necessary to take the measures (2) below in 2) Format and content
for drawing people (patients) or physician’s emergent
Emergency safety information must be prepared
and specialized attention to safety-related matters and
in the style and format specified in the guidelines,
drug-use restriction in situations (1) as listed below.
using yellow paper, etc. for easy identification of
Practices for disseminating such information are
important information by the public (patients) and
specified in Notification No. 1031-(1) of the Safety
medical personnel.
Division, PFSB dated October 31, 2014.
3) Methods of information dissemination
(1) Situations
(1) The staff (MRs) in charge of drug information
● Situations where cases of deaths, disabilities,
of the marketing authorization holder directly
events that may lead to death or disability,
distributes the information to physicians,
and difficult-to-treat conditions are reported
pharmacists, and other health professionals in
by ADR reporting systems
medical institutions. The dissemination is
● New safety-related problems such as the
required to be efficiently carried out by using
occurrence of unknown serious ADRs that
multiple communication tools such as direct
apparently outweigh expected therapeutic
handout, direct mail, fax, and e-mail to achieve
benefits
prompt and widespread alert for safety
● Regulatory measures taken overseas to concerns. PMDA distributes urgent safety
resolve and prevent emergency and information, revisions to package inserts, etc.
significant safety issues to medical personnel who have registered their
● Safety issues considered to remain e-mail address with the Agency via PMDA
unresolved despite the dissemination of medi-navi.
urgent safety information (“yellow letter”) or (2) The marketing authorization holder must
safety flash reports (“blue letter”) transfer safety information to medical or
(2) Measures to be implemented pharmaceutical organizations and requests
● Creation of “warning” box or addition of them to cooperate in collecting and
“warning notice” disseminating information through efficient
communication tools such as their homepages.
● Creation or addition of contraindications
If the marketing authorization holder knows
● Revision of precautions accompanying the
patient groups that use the products
implementation of new safety measures (e.g.,
concerned, the safety information should be
laboratory tests)
distributed to such groups.

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Pharmaceutical Regulations in Japan:

Of note, for drugs of which package insert Safety flash reports must be prepared in the style
information are subjected to be notified, and format specified in the guidelines, using blue
manufacturing/marketing authorization holders must paper, etc. Information contained in the reports may
notify the PMDA of details of amendment in package be required to be arranged for the public (patients)
inserts prior to publication on the homepage of depending on the usage in practice.
companies or the like.
3) Methods of information dissemination
4) Distribution (1) The staff (MRs) in charge of the drug
The distribution of emergency safety information to information of the marketing authorization
medical institutions must be completed within 1 month holder are to efficiently distribute the
of receipt of the government order, according to the information to physicians, pharmacists,
plan and method of distribution. The marketing and other health professionals in medical
authorization holder must submit a safety information institutions by using multiple
dissemination report to the Director of the communication tools such as direct
Pharmaceutical Safety Division of Pharmaceutical handout, direct mail, fax, and e-mail to
Safety and Environmental Health Bureau when achieve prompt and widespread alert for
distribution has been completed as specified by the safety concerns. PMDA distributes safety
office. flash reports, revisions of package inserts,
etc. to medical personnel who have
3.2 Safety Flash Report (Blue Letters) registered their e-mail address with the
Agency via PMDA medi-navi.
1) Preparation criteria
(2) The marketing authorization holder must
The safety flash report (“blue letter”) is prepared by
transfer safety information to medical or
the marketing authorization holder on the basis of
pharmaceutical organizations, as
discussion with the MHLW and PMDA following an
appropriate, and requests them to
order or instruction from the MHLW, voluntary
cooperate in collecting and disseminating
decision by the marketing authorization holder, or
information through efficient
other requirements in cases where it is judged
communication tools such as their
necessary to take the measures specified in Section
homepages. If the marketing
3.1: 1-(2) above for drawing physician’s urgent and
authorization holder knows patient groups
specialized attention to safety-related matters and
that use products concerned, safety
measures necessary for optimal drug use (e.g.,
information should be distributed to such
efficient method of notification, laboratory tests, etc.)
groups, as appropriate.
similarly to the procedures for handling important
safety information as noted above but more promptly Of note, for drugs of which package insert
than routine revisions of “precautions for use” with an information are subjected to be notified,
intent to prevent the recurrence and spread of manufacturing/marketing authorization holders must
health-related harm or injury to the public. Practices notify the PMDA of details of amendment in package
for disseminating such information are specified in inserts prior to publication on the homepage of
Notification No. 1031-(1) of the Safety Division, PFSB companies or the like.
dated October 31, 2014. 4) Distribution
2) Format and content The distribution of emergency safety information to

2018 - 150 -
Pharmaceutical Regulations in Japan:

medical institutions must be completed within 1 month with the Agency via PMDA medi-navi.
of receipt of the government order, according to the In the case of 1)-(2) above, the notices are to be
plan and method of distribution. The marketing distributed to health professionals, as required, as
authorization holder must submit a safety information directed in 1)-(1) above.
dissemination report to the Director of the
4) Distribution
Pharmaceutical Safety Division of Pharmaceutical
Safety and Environmental Health Bureau when The dissemination of the notices to medical
distribution has been completed as specified by the institutions must be completed as soon as possible
office. after receipt of the notification of the Director of the
Safety Division of PFSB or the decision to make a
voluntary revision.
3.3 Distribution of Information by 'Notices of
Revision of Precautions'
3.4 Dissemination of Information for Drugs
The marketing authorization holder must prepare That Have Completed Reexamination or
Notices of Revision of Precautions specifying the Reevaluation
contents of revision after any revision of the
precautions for use, and distribute it to medical Once the reevaluation results and reexamination
institutions (Notification No. 1031-(1) of the Safety results are available, the marketing authorization
Division, PFSB dated October 31, 2014, and holder of the drug concerned disseminated
Notification No. 129 of the JPMA dated February 26, information by preparing a “Notice of Reevaluation
2015). Results” and “Notice of Reexamination Results” as
required, which they distribute to medical institutions.
1) Preparation criteria The FPMAJ compiles all of the reevaluation results
(1) Cases where the Director of the Safety and publishes a “Notice of Prescription Drug
Division of PFSB orders or recommends Reevaluation Results” in the journals of the Japan
revision of the Precautions or other Medical Association, Japan Dental Association, and
sections of package insert based on the Japan Pharmaceutical Association.
results of an investigation by the PMDA.
(2) Cases where the manufacturer and 3.5 Dissemination of ADR Information by the
marketing authorization holder voluntarily Pharmaceuticals and Medical Devices
revises the Precautions (revisions are to Safety Information (Information on Adverse
be notified to the PMDA beforehand). Reactions to Drugs)
2) Format and content Among the case reports and scientific reports on
The paper must be not yellow or blue. adverse reactions collected from the
manufacturer/marketing authorization holder, and
3) Methods of information dissemination
ADR reports collected from or submitted by health
In the case of 1)-(1) above, MRs of the marketing
professionals, the MHLW compiles commentaries
authorization holder are to promptly distribute the
and Notices of Revisions of Precautions concerning
notices to physicians, pharmacists, and other health
important ADRs. They are supplied in digest form
professionals. PMDA distributes the notices of the
as "Pharmaceuticals and Medical Devices Safety
Director of the Safety Division, PFSB, etc. to medical
Information" to health professionals who submitted
personnel who have registered their e-mail address
ADR reports, and also published in the media, on the

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Pharmaceutical Regulations in Japan:

PMDA homepage for information on drugs , and in publication at the following the PMDA homepage for
various publications such as the Journal of the Japan information on drugs.
Medical Association and the Journal of the Japanese (http://www.pmda.go.jp/safety/info-services/drugs/calli
Association of Hospital Pharmacists. An English ng-attention/dsu/0001.html)
version is sent to WHO.
The digest was published bimonthly from June 3.7 Commentaries on "Precautions" in
1973 and then monthly from June 2001 (from Issue Package Inserts of New Drugs
No. 167) (recently, 10 issues annually). The digest is
Commentaries on "Precautions" in package
available and regularly updated at the following the
Inserts of new drugs are prepared by the
PMDA homepage for information on drugs.
manufacturer/marketing authorization holder of drugs
http://www.pmda.go.jp/safety/info-services/drugs/calli to provide the most basic safety information on new
ng-attention/safety-info/0043.html drugs. The manufacturer/marketing authorization
holder must prepare easy-to-understand
3.6 Dissemination of Information by Drug “commentaries” concerning the basis and contents of
Safety Update Precautions, and their MRs distribute the
Drug Safety Update (DSU) is published for commentaries to medical institutions before new
prescription drugs and the DSU of the OTC version drugs are used in medical practice in order to assure
(Information of revisions of precautions for use for proper use of new drugs.
OTC drugs) is published for non-prescription drugs With the revisions of the guidelines for the
under the supervision of the Ministry of Health, Labour preparation of package inserts and Precautions in
and Welfare as the information journals which April 1997, a guide for preparation of these
summarize and comprehensively and promptly commentaries was issued (Notification No. 88 of the
convey information on revisions of the Precautions Safety Division, PAB dated June 27, 1997).
evaluated by the Ministry of Health, Labour and Thereafter, companies started to prepare
Welfare. commentaries on their new drugs. New drugs that
The Society of Japanese Pharmacopoeia and the are approved after October 2001 are marked with a
Federation of Pharmaceutical Manufacturers' logo commonly adopted by the pharmaceutical
Associations of Japan (FPMAJ) have been jointly industry indicating that the drug is subject to early
editing and publishing the DSU, since September post-marketing phase vigilance for such a period of
1992 (10 times per year) (published by the FPMAJ time as specified in labeling (refer to Chapter 4, 1.
since Issue No. 128 dated April 2004). The journal is GVP).
distributed by mail to medical institutions nationwide
including approximately 10,000 hospitals, 90,000 4. ELECTRONIC INFORMATION
clinics and 60,000 dental clinics, as well as about and DISSEMINATION
50,000 pharmacies and dispensing facilities within
one month after printing. The MHLW received a report from its special
committee on policies to supply drug information to
The DSU of the OTC version has been edited and
health professionals, etc. using the Internet, which
published by the Japan Federation of Self-Medication
was established in 1997, and started operation of a
Industries since November 2015.
"Drug Information System” to supply such information
These journals are available immediately after via the Internet at the end of May 1999 (currently

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Pharmaceutical Regulations in Japan:

PMDA homepage for information on drugs, The PMDA is providing services free (via PMDA
http://www.pmda.go.jp/safety/info-services/drugs/000 medi-navi) to distribute safety-related information
1.html). such as revisions to precautions in use of drugs,
The information supplied includes information which has been placed on the Agency’s homepage
regarding the proper use of drugs, information on for information on drugs, to medical personnel who
package inserts of prescription drugs, safety have registered their e-mail address with the Agency.
information disseminated by the MHLW, cases of http://www.pmda.go.jp/safety/info-services/medi-navi/
suspected adverse reactions collected by the MHLW, 0006.html
as well as risk management plan (RMP), information
on Yellow Letters (formally-called Dear Doctor
5. PACKAGE INSERTS OF
Letters)/Blue Letters, drug guide for patients, the
NON-PRESCRIPTION DRUGS
manual for handling disorders due to adverse drug
reactions, drug approval applications, drug recalls, The MHW established a special committee to
etc. improve package inserts of non-prescriptions drugs in
The marketing authorization holder is required to August 1996 following the revision of the guidelines
discuss the necessity for issuance and publication of for package inserts of prescription drugs, and this
“PMDA requests on the proper use of drugs” among group issued its report in September 1998.
official notices on the proper use of drugs, if ADRs The PMSB of the MHLW issued notifications on
due to drug use or those due to improper drug use do August 12, 1999 on the type and format for
not decrease despite major revisions to labeling such non-prescriptions drugs to define items of information
as an issue or revisions of warnings and precautions. to be included in the package insert, entry methods
The marketing authorization holder is also required to for Precautions, and information that should be
determine the necessity of disseminating such included on the outer containers. The style and
information through print media, as appropriate. format of the description on the outer containers or
With this system, package insert information for wrappers were revised to assist the purchase of
prescription drugs is provided in SGML (Standard suitable drugs based on labeling and issued as a
Generalized Markup Language) format to facilitate notification of PFSB on October 14, 2011. The old
downloading and processing of the information for notification of PMSB dated August 12, 1999 was
various purposes. In addition, the MHLW provides abolished accordingly. For non-prescription Chinese
all information in PDF (Portable Document File) herbal preparations with the established approval
format in view of the inherent convenience. The criteria, items to be included in Precautions in
basic format corresponds with the revised guidelines package inserts, etc. were presented in Notification
on preparation of package inserts. A change from No. 1014-(7) of the Safety Division, PFSB and No.
SGML to XML (Extensible Markup Language) is 1014-(8) of the Evaluation and Licensing Division,
expected to be made by April 2019 to improve the PFSB dated October 14, 2011, and partially amended
convenience of the package insert search system of in Notification No. 0327-(1) of the Safety Division,
PMDA's HP. PFSB and No. 0327-(1) of the Evaluation and
Licensing Division, PFSB dated March 27, 2013.
The supply of package insert information for
non-prescription drugs was started from March 2007 Labeling requirements of excipients of
and supply of information on drug interview forms non-prescription drugs are the same as those for
from May 2009. prescription drugs according to a voluntary agreement

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Pharmaceutical Regulations in Japan:

of the JPMA (Notification No. 165 of the JPMA dated information (copy) attached (Notification No. 0901-(1)
March 27, 1991) and Office Communication of the of the Safety Division, PFSB dated September 1,
Safety Division, PAB dated June 3, 1991. Based on 2014).
a voluntary agreement of the JPMA (Notification No. Nonetheless, the exceptions for package inserts to
170 of the JPMA dated March 13, 2002), all be attached to products may be applicable also as is
ingredients must be included in package inserts by the case in prescription drugs (refer to 1. PACKAGE
March 31, 2004 and the names of excipients including INSERTS).
voluntarily designated ingredients must be included
on the outer container (or its equivalent).
Based on this voluntary agreement, Notification
No. 165 of the JPMA was canceled and the Office
Communication of the Safety Division, PAB dated
June 3, 1991 was canceled by Notification No.
0409001 of the Safety Division, PMSB dated April 9,
2002.
For the background of labeling of excipients for
prescription drugs, refer to Section 1.4 on excipients.
The revised Law enacted on November 25, 2014
specified that package insert information should be
based on scientific knowledge and information
obtained in latest literatures, etc. as is the case for
prescription drugs. Nonetheless, the exceptions for
package insert information to be attached to products
may be applicable also as is the case in prescription
drugs (refer to 1. PACKAGE INSERTS).

6. PACKAGE INSERTS OF
GUIDANCE-MANDATORY DRUGS
For guidance-mandatory drugs (refer to
CHAPTER 2, 3.2 Classification of Drugs), as is the
case for prescription drugs, package inserts should be
based on scientific knowledge and information
obtained in latest literatures, etc., and brand names
and precautions for usage and handling should be
noticed prior to initiation of manufacturing/marketing
or amendment followed by prompt publication on the
PMDA homepage (Notification No. 0806-(3) of PFSB
dated August 6, 2014).
For notification, the specified notification format
should be submitted to the PMDA with package insert

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Pharmaceutical Regulations in Japan:

Fig. 18 Layout of a Package Insert for a Prescription Drug (with “Warning”)


Package inserts consist of specified headings in a specified order (Refer to Chapter 5: Section 1.2). Efforts
are made to carefully analyze collected information and include all headings whenever possible, but some
headings are omitted when appropriate information is not available. The layout may differ to some extent.
Note: A case with “Warnings” (with a red bracket in the right margin)

Date of preparation and/or


revision(s) of the package Therapeutic category Standard Commodity Classification No. of
insert Japan
Brand name
Approval number
Storage, handling, etc.
Name in the Japanese Date of listing in the NHI reimbursement
Pharmacopoeia, etc. Date of initial marketing in Japan
Regulatory classification Date of latest reexamination or
Non-proprietary name reevaluation
Date of latest approval of indication(s), etc.
Name in Roman letters

information on specified biological products


Warning(s) Use in the Elderly

Contraindications Use During Pregnancy, Delivery, or


Lactation
(Relative Contraindications) Pediatric Use
Composition and Description Effects on Laboratory Tests
Indication(s) Over dosage
Precautions (Related to Indications) Precautions Concerning Use
Dosage and Administration Other Precautions
Precautions (Related to Dosage and Pharmacokinetics
Precautions Clinical Studies
Careful Administration Clinical Pharmacology
Important Precaution(s) Physicochemistry of active ingredient
Drug Interactions Precautions Concerning Use
Contraindications for Coadministration Conditions for Approval
Precautions for Coadministration Packaging
Adverse Reactions References and Reference Request
Clinically Significant Adverse Information on Long-term Administration
Other Adverse Reactions Name and address of marketing

(PMS Subcommittee, Drug Evaluation Committee, JPMA) Note: Sections in refer to Precautions

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Pharmaceutical Regulations in Japan:

Fig. 19 Layout of Package Insert Based on Revised Guidelines for Preparation


(Image)

**
Revised: Month, 20XX (Version XX, ○ ○) Standard Commodity
Classification No. of Japan
Name of therapeutic category
Storage: Nonproprietary name, standard name, ●mg ▲mg
Expiration date: or name designated on Japanese Pharmacopoeia Approval No.
Date of initial
marketing in Japan XX, 20XX XX, 20XX
Regulatory classification

Prescription drug Note) Brand Name


Name of Product
Note) Caution : Use under prescription from a physician, etc.

Signs, symptoms and Mechanism and risk


1. Warning Drug name
treatment factors

2. Contraindications (This product is contraindicated in the 10.2 Precautions for coadministration (XX should be administered
following patients.) with care when coadministered with the following drugs.)
Signs, symptoms and Mechanism and risk
Drug name
treatment factors

3. Composition and description


3.1 Composition
<Table format >
3.2 Description of drug product 11. Adverse reactions
<Table format > 11.1 Clinically significant adverse reactions
4. Indications 11.1.1○○

11.2 Other adverse reactions


5. Precautions related to indications
≥○% 0.1 to ≤○% ≤ 0.1% Unknown frequency

6. Dosage and administration

7. Precautions related to dosage and administration


12. Effects on laboratory tests
8. Important precautions
13. Overdosage
9. Precautions related to patients with special backgrounds
9.1 Patients with complications or disease history
14. Precautions concerning use
9.2 Patients with renal dysfunction
15. Other precautions
9.3 Patients with hepatic dysfunction
15.1 Information based on clinical use

9.4 Persons with reproductive ability


15.2 Information based on nonclinical studies

9.5 Pregnant women


16. Pharmacokinetics
16.1 Blood concentration
9.6 Lactating women

16.2 Absorption
9.7 Pediatric use
16.3 Distribution
9.8 Elderly use

16.4 Metabolism
10. Drug interactions
10.1 Contraindications for coadministration (This product 16.5 Excretion
should not be coadministered with the following
drugs.)

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Pharmaceutical Regulations in Japan:

16.6 Patients with special backgrounds

16.7 Drug interactions

16.8 Others

17. Clinical studies


17.1 Studies on efficacy and safety

17.2 Post-marketing surveillance, etc.

17.3 Others

18. Pharmacology
18.1 Mechanism of action

18.2 ○○ action

19. Physicochemistry

20. Precautions in handling

21. Approval conditions

22. Packaging

23. References

24. Request for literature should be made to:

25. Precautions related to insurance benefits

26. Manufactured and distributed by:

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Pharmaceutical Regulations in Japan:

(Report of adverse reactions, etc.)

Individual teams (5 teams)

Primary screening Weekly


works

Utilization of data mining

Extraction of
noteworthy adverse
reactions

Secondary screening (team meeting)


Whether or not safety measures are necessary

Sharing information
with the Ministry

Inquiries to
companies

Fig. 20 Standard Procedures for Revision of Package Insert (1)

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Pharmaceutical Regulations in Japan:

Inquiry to the Company

emergency
cases (1 week)
Emergency Company’s
Safety
Revision
Opinion
Information Consultation by the
Company

No (measurement to be suspended) Yes (measurement to be implemented)

(1 week) (1 week)

Remarkable cases for


Screening 1 Interview Advice Meeting
(Topics Review)
(require expert review?)
No Yes
(within 2 weeks after
completion of preparation of
necessary documents) (about 10-40 days)

Revise the
Package Insert
urgent Expert Review
cases (every 5 weeks in
Safety Information principle)
(1 week)

Notify MHLW of Drafted Measurements

(1 week)

Notification for Revision Order of the Package Insert


(every 5 weeks in principle)

Fig. 21 Standard Procedures for Revision of Package Insert (2)

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Pharmaceutical Regulations in Japan:

CHAPTER 6 temporary financial measures but also radical


measures have been successively introduced to
HEALTH INSURANCE counteract the deficit.
As medical services for the elderly had been
PROGRAMS AND DRUG concentrated on financial support and provided free,
PRICING IN JAPAN the cost of their medical treatment sharply increased
every year, seriously affecting the financial status of
the NHI program.
In addition, the financial support for the elderly
1. HISTORY OF HEALTH INSURANCE created an imbalance in the amount of medical costs
PROGRAMS of the elderly and hence burden of insured persons
Health insurance programs in Japan began in between the different industry-managed and
1922 with enactment of the Health Insurance Law locally-based health insurance programs due to
which was aimed only at workers for the purpose of differences in the proportion of elderly persons
ensuring sound development of national industries covered under each program. This made it
through increases in labor efficiency and close necessary to radically review the health insurance
cooperation between workers and employers by system in Japan, and as a result, the Health and
eliminating workers' anxiety about their daily life. Medical Services Law for the Aged was enacted and
This law was implemented in 1927. The National enforced in 1983.
Health Insurance Law (NHI) enacted in 1938, and the This law encourages general health related
Employees’ Health Insurance Law and the Seamen's projects for the elderly, including the prevention and
Health Insurance Law both enacted in 1939 were treatment of diseases and rehabilitation training. The
subsequently enforced. In 1961, it was ruled that law also introduced a new system in which medical
every citizen was required to join either one of costs for the elderly are shared by public expenditure
industry-managed employees' health insurance and by contributions from individual health insurance
programs or locally-based health insurance programs in order to distribute the costs more fairly.
programs. At this point, "health insurance covering Thereafter, anxiety increased among the people
the entire population" was established. concerning home care of elderly people because of
Increasing efforts were made thereafter to improve the aging of society and changes in family function,
the structure/scope of medical benefits given under and the excessive burden of home care on families
various health insurance programs. In addition, has become a social problem. Another problem is
under the Welfare Law for the Elderly, all medical stringency on health insurance finances by social
costs for the elderly have been provided free of hospitalization, i.e., long-term hospitalization of the
charge since 1973, and additional health care elderly for nursing care. There are limits on solving
services became available for patients with intractable the home care problem under the current health
diseases to alleviate their economic burden. These, insurance system, and a reform of the health-care
special health insurance programs have been insurance system together with the introduction of a
implemented to reduce high medical costs for special new social security system was debated. The
populations. Long-Term Care Insurance Law was passed together
On the other hand, because of the long-term with the third revision of the Medical Care Law on
deficit in the health insurance system, not only December 19, 1997 and it was enforced from April

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Pharmaceutical Regulations in Japan:

1998. It is amended every 5 years. introduced with children less than 6 years of age and
The health-care insurance reform concurrently low-income elderly patients excluded.
studied in 1997 brought a change in the coverage on Thereafter, problems related to the burden on the
benefits by employee's health insurance to 80% and elderly were pointed out and the government adopted
to introduce a partial cost-sharing for medication. a policy of exemption of the elderly from outpatient
Thereafter, in 2002 the revision of the Health partial cost sharing for medication as an extraordinary
Insurance Law containing the 30% copayment for the measure in July 1999. In December 2000, the
insured was passed by the Diet. The 30% burden Health Insurance Law was promulgated and from
for the insured was enforced from April 2003. January 1, 2001, it became possible to select a
The law to reform the health insurance system copayment system with 10% of the medical expenses
was discussed from 2005 and was enacted in June as the upper limit or a fixed copayment for the elderly.
2006. From October 2006, persons aged 70 years From October 2002, the burden on elderly patients
or older with similar regular income as during their aged 70 years or older was set at 10% and at 20% for
working years were subject to a copayment of 30% those with a certain level of income, latter of which
and limits on copayments and food/housing costs for was revised to 30% from October 2006.
inpatients of nursing home increased. From April For family members of insured persons,
2008, a healthcare system for very old people was regardless of type of health insurance program, at
initiated. least 70% of actual costs are covered by the
programs. Furthermore, when a patient's medical
payment reaches a certain limit, the patient is
2. MEDICAL BENEFITS OFFERED UNDER
refunded the excess. Supplementary programs are
HEALTH INSURANCE PROGRAMS
also available to cover the costs of special treatments
As mentioned above, there are various types of including highly advanced medical treatments and to
health insurance programs in Japan and medical support specified medical care coverage system that
benefits available vary from one program to another. permits selection of treatment by patients. These all
Medical benefits available for the insured person can contribute to overall improvement in medical care.
also differ depending on the type of insurer, type of Under these health insurance programs, medical
insurance program, and presence of family members benefits are almost always provided to insured
(non-working dependents). Under persons in the form of actual treatment rather than as
industry-managed health insurance programs, 90% of a cash reimbursement. In exceptional cases where
medical costs of insured persons is covered by health this rule is difficult to apply, money is provided to cover
insurance programs according to the revision of the treatment costs.
Health Insurance Law in 1984 (the original coverage
was stipulated to be 80% in the law but it was 90%
until a notification of the Minister of Health and 3. REIMBURSEMENT OF MEDICAL FEES
Welfare issued on a day after April 1986 after Medical institutions where patients are treated
approval by the Diet). From September 1997, the under health insurance programs apply to respective
coverage was changed to 80% of medical costs to health insurance associations, after treatment has
medical institutions where patients are treated under been rendered, for reimbursement of actual treatment
health insurance programs. A copayment by costs after subtracting the amount paid directly by
patients for outpatient medication fees was also patients. Medical fees listed in the NHI system are

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Pharmaceutical Regulations in Japan:

set by the MHLW, which consults with the Central The coefficient by medical institution is set by the
Social Insurance Medical Council ("Chuikyo"). The function and past performance records of the hospital.
fees are calculated on the basis of Article 76, Item 2 of No. of points per day is set higher for cases of earlier
the Health Insurance Act (Act No. 70, 1918) and discharge than the mean number of hospitalization
Article 71, Item 1 of the Act on Assurance of Medical days of the DPC.
Care for Elderly People (Act No. 80, 1982), and The number of DPC classifications was changed
according to the Calculation Method of Medical Fees to 4,918 (number of payment classification: 2,410) in
(Public Notice No. 59 of the Ministry of Health, Labour April 2016 and forecast of the application of this billing
and Welfare in 2008) and Calculation Method of system has been extended to 1,667 hospitals
Treatment Expenses under the Health Insurance Act (495,227 beds) in April 2016.
(Public Notice No. 177 of the Ministry of Health and
Medical procedures, such as medication and
Welfare dated June 1958) (partially revised on March
injection, require the use of drugs, and the list of
4, 2016 by Public Notice No. 52 of the Ministry of
reimbursement prices of drugs permitted under health
Health, Labour and Welfare).. Under these rules, a
insurance programs is called the National Health
point value is assigned for each of the thousands of
Insurance (NHI) Price List.
medical procedures listed.
Fees (in Yen) are then calculated by multiplying
the number of points by 10. This system, in which 4. NATIONAL HEALTH INSURANCE PRICE
medical fees are paid to medical institutions for the LIST
procedures performed, is called the “payment for The National Health Insurance (NHI) Price List is a
services system” as the basis of the medical cost list of drugs for which medical providers can be
reimbursement system in Japan. There are many reimbursed under the health insurance programs as
types of points set for “lump sum” payment for specified in the regulations for hospitals and nursing
hospitalized treatment, etc. of patients with chronic homes covered by health insurance. The rules used
disease. From April 2003, the Diagnosis Procedure to calculate healthcare fees in accordance with the
Combination (DPC) system was introduced by Health Insurance Law state that the reimbursement
university and other large hospitals (university price of drugs for medical institutions is to be
hospitals, National Cancer center, and National determined separately by the Minister of the MHLW.
Cardiovascular Center: 82 hospitals in total) for Thereby, the prices to be invoiced for drugs used in
diagnosis-based assessment of lump sum payments hospitals are set by the Minister and shown in the NHI
for emergency admissions and treatments. With this Price List.
system, medical bills per day per patient are
determined using 1,860 DPC classifications. The
5. PRICING FORMULA FOR
medical bill includes basic admission fees, laboratory
REIMBURSEMENT PRICE REVISIONS OF
test fees, imaging diagnosis fees, drug dispensing
DRUGS LISTED IN THE NHI PRICE LIST
fees, injection fees, and treatment fees of less than
1,000 points. The medical bill is calculated by the The difference in the purchase price by medical
following formula. institutions and the NHI reimbursement price (price
Number of points per day for each DPC x discrepancy), which provides extra income for
coefficient by medical institution x number (days) of medical institutions, has been a problem since the
admissions x ¥10 latter half of the 1980s, and various pricing formulas

2018 - 162 -
Pharmaceutical Regulations in Japan:

have been used to reduce this price discrepancy and April 1996, repricing was undertaken for products that
correct the fluctuations in purchase prices, but showed a much greater market scale (at least double)
improvements have not been adequate. than originally expected at the time of listing and for
Under these conditions, taking an opportunity of which annual sales (converted to reimbursement
an attempt to improve the distribution of drugs from prices) exceeded 15 billion yen. Repricing was also
April 1, 1991, the former bulk line method was undertaken for drugs for which indications were
abolished and a pricing formula based on the added after the original listing. Later in 2014, a new
weighted average market price was adopted in rule for an additional indication of an orphan drug was
anticipation that the NHI Price List would more added to ensure that repricing shall be considered
accurately reflect market prices, unnatural fluctuations when the sales of the orphan drug increases at least
in prices would be corrected, and pricing would be 10 times than originally expected and exceeds 10
simplified. Based on a recommendation submitted billion yen. In 2016, while conflicting topics of
by Chuikyo to the MHLW on May 31, 1991, the evaluation of innovative drugs and maintenance of
pricing formula used for drugs listed in the NHI Price nationwide comprehensive health insurance system
List at the time of reimbursement price revisions was were being discussed, repricing was implemented on
revised, and the first overall price revision using the drugs: the annual sales of one drug exceeded 100
new formula was conducted in 1992. billion yen but not 150 billion yen, and increased at
least 1.5 times than originally expected; and the
In brief, the revised reimbursement prices are
annual sales of the other drug exceeded 150 billion
determined by calculating weighted means of sales
yen, and increased at least 1.3 times than originally
prices of all existing package sizes by brand and
expected. In addition, cost-effectiveness evaluation
adding a certain percentage of the current
for drugs and medical devices is to be introduced as a
reimbursement prices (within a “specified price
pilot operation in April 2016.
range”) to the weighted mean prices obtained
(however, the new reimbursement prices must never Furthermore, to ensure stable supply of drugs with
be higher than the current prices). high medical needs covered by health insurance, the
drug price maintenance system for basic drugs was to
Chuikyo believes that the “specified price range”,
be implemented as a pilot operation. This system
which was intended to take into account the
may be applied to drugs meeting all of the following
differences in market prices according to differences
requirements (except for sufficiently profitable drugs):
in terms of sales conditions, should be 10%.
However, since stable supply of all necessary drug [1] The drug has an established position in clinical
products could not be ensured if the price range was settings and is clearly known to be widely used
set at 10% from the beginning, Chuikyo in clinical practices.
recommended that it be set at 15% initially so as not [2] Of the concerned already listed drug as well as
to have too strong an effect on business conditions at all similar drugs with the same composition
the time, and that it be reduced to 13%, 11%, and and dosage form category as those of the
finally 10% on a step-by-step basis each time the former, at least one drug has been on a NHI
reimbursement prices were revised in the future. Price List for 25 years or longer.
Thereafter, price increases of some products [3] If there are similar drugs with the same
presented problems, and a Chuikyo recommendation composition and dosage form category as
was issued to deal with the problems on November those of the concerned already listed drug, the
22, 1995. In addition to the usual price revision in mean discrepancy of the similar drugs

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Pharmaceutical Regulations in Japan:

including the concerned already listed drug first-class wholesalers, and about 3,400 purchasers
between the NHI price and current market consisting of hospitals, clinics and pharmacies
price does not exceed that of all the listed selected at random using specified sampling fractions
drugs. in each case. Supplemental price surveys including
[4] The discrepancy of the concerned already those on changes with time are performed six times.
listed drug between the NHI price and current The new reimbursement price is calculated by adding
market price does not exceed the mean a reasonable adjustment zone (R) to the weighted
discrepancy of all the already listed drugs. average marketing price obtained from these surveys
in consideration of the consumption tax (refer to the
The revision of the NHI price list in 2016
calculation formula).
implemented selection of products previously
subjected to repricing due to unprofitable sales as well < Formula >
as drugs against pathogens serving the medical New drug price = weighted average value of
platform for years and medical narcotics. market price in survey x (1 + consumption tax
The price range decreased gradually from 15% in rate) + current reimbursement price x R/100
1992 to 13% in 1994, 11% in 1996, 10% (8% for (however, the new price shall not exceed the
products listed for a long time) in 1997, and 5% (2% current reimbursement price).
for high price products with relatively large margin) in This pricing formula is applied to products that are
1998. In 2000, the range was set at 2% to secure sold in large quantities, and the prices for drugs sold
stable drug supply involved over the need of in lower quantities are adjusted using the revision rate
reimbursement system reform. The pricing formula for drugs of the same class and same indication.
was changed to the weighted average market price From 1992, prices were revised at about every 2
and range adjustment method. years, but an adjustment was made for the increase
The pricing formulas for drugs included in the list of the consumption tax rate in 1997, and as a result,
were specified in March 2000 to assure transparency reimbursement prices were reduced for 3 consecutive
of drug pricing. The most recent revision is given in years: 1996, 1997, and 1998. The reimbursement
Notification No. 0210-(1) of the Health Insurance prices were reduced 2% further by the
Bureau dated February 10, 2016, “Drug Pricing range-adjustment method in 2000. In 2002, the
Standards.” adjustment range was kept at 2%, and an additional
reduction of an average of 5% was made for original
drugs of generic drugs (excluding those in the JP) in
6. RECENT REVISIONS OF THE NHI PRICE
the case of drugs entered in the NHI Price List for a
LIST
long time. In 2004, a price range of 2% and
Based on the 1991 Chuikyo recommendation, the exceptions for long-listed products were applied.
MHW undertook a complete revision of the Among JP products entered by brand name, original
reimbursement prices of all products already in the products for which generic products are available on
NHI Price List using the weighted average pricing the market were subjected to an additional price
formula from 1992. reduction of one half of the rate for non-JP products.
The actual reimbursement price revisions covers In 2006, a further reduction of 2% was applied as an
the drugs sold in the month of September of a exception for long-listed products.
previous year. A survey of all products in the NHI In order to deal with of the pending “drug lag” issue
Price List is conducted on about 4,000 sellers, all (unavailability for use or longer approval time of new

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Pharmaceutical Regulations in Japan:

drugs), the Central Chuikyo discussed the issue and drugs (excluding drugs within 3 years from the launch
proposed a new “premium for promoting new drug of the first drug or within three drugs with the same
research and resolving problems of treatment not pharmacological action) was set at a lower price for a
covered by insurance. In 2010, the premium was daily dose. The rule for coordinating prices with
applied for prescription drugs that have been in the foreign reimbursement prices was also clarified
reimbursement list within 15 years and not followed (maximally twice the foreign price).
by generic drugs (for negative price divergence from The seven premium rates as of February 2014
average price of all drugs in class confirmed by price were set at 70-120%, 35-60%, 5-30%, 5-20%,
surveys). This premium pricing system on trial still 10-20%, 5%, and 10% for innovation, usefulness I
continues to be implemented in 2014. and II, pediatric use, market size I and II, and world’s
Drug prices listed in the NHI Price List were first registration in Japan, respectively.
revised to include additional 3% consumption tax in Requirements for applying premiums are listed in
April 2014 as the tax rate was raised from 5% to 8% Table 16 (Requirements for Applying Premiums).
in the month. A special calculation formula was introduced for
The results of reimbursement price revisions from new combination drugs (oral preparations): as a rule,
1992 through 2016 are shown in Table 14 (Methods the price is set at 80% of the total of prices of
of Previous Reimbursement Price Revisions) and individual drugs.
Table15 (Revision Rates of Reimbursement Prices). To assure transparency of the pricing system,
drug pricing formulas were made public in March
7. DETERMINATION OF REIMBURSEMENT 2000 (the most recent revision is given in Notification
PRICES FOR NEW DRUGS No. 0210-(1) of the Health Insurance Bureau dated
February 10, 2016, “Drug Pricing Standards”).
In view of trends in the new drug development Procedures for calculation of drug prices were issued
environment in recent years, Chuikyo stated in their in detail in September 2000 (the most recent revision
May 1991 recommendation concerning the is given in Notification No. 0210-(1) of the Health
reimbursement price of new drugs that a more Policy Bureau dated February 10, 2016, “Handling of
appropriate premium system should be introduced Entries of Prescription Drugs in the NHI Price List”).
with a new premium for innovation that would be Methods for submission of requests for inclusion of
applicable to only truly innovative new drugs. new drugs in the price list were most recently revised
Specifically, it was recommended that the in Notification No. 0210-(2) of the Economic Affairs
reimbursement price of new drugs should be Division, Health Policy Bureau dated February 10,
determined on the basis of comparison with existing 2016.
drugs from the same category as before but marked
A drug pricing organization was established to
up using premiums for innovation, usefulness, and
undertake scientific surveys concerning selection of
market size; and that requirements for each premium
products for price comparison and the applicability of
be clearly defined. The price of a daily dose of a
premiums by experts in the medical and
new but non-innovative drug approved on or after
pharmaceutical fields. This organization deals
April 1, 1996, for which several drugs with similar
especially with pricing and repricing of new drugs in
pharmacological action and indications are already
the NHI Price List.
listed and for which the efficacy and safety are
objectively evaluated to be about the same as these With the establishment of the pricing organization,
flowcharts of the process from new drug approval until

2018 - 165 -
Pharmaceutical Regulations in Japan:

entry in the NHI Price List are shown in Fig. 22 biosimilar products. A premium (maximally
(Reimbursement Pricing Flow-sheet for New Drugs). 10/100 of the standard) is added to the
(Entries of new drugs in the NHI Price List are standard price (the factors are 0.7 and 0.6,
made as a rule four times a year.) respectively) depending on qualitative and
quantitative data obtained from clinical trials.

8. ENTRY OF GENERIC DRUGS IN THE NHI


PRICE LIST 9. ISSUES RELATED TO THE USE OF
DETERMINATION OF UNAPPROVED
In the past, generic drugs have been entered in
DRUGS AND OFF-LABEL USE
the NHI Price List once every 2 years, but the entry
has been made once a year from 1994 and twice a There have been major issues related to the use
year since 2008 (entries in May and November from of unapproved drugs and the “time-lag” in new drug
2009). The reimbursement prices for the drugs approval. The Ministry of Health, Labour and
listed since 1996 are calculated as follows in principle. Welfare formed the Review Conference on
Unapproved Drugs in 2005 to address these issues.
As in the case of new drugs, the drug pricing
In view of an increasing need for regulatory and
formulas were issued in March 2000 with the aim of
industry measures to lend greater support to the use
assuring transparency of the generic drug pricing
of unapproved drugs and new indications, the Ministry
system. (The most recent revision is given in
and member companies of the JPMA worked
Notification No. 0210-(1) of the Health Insurance
together and established the Pharmaceutical
Bureau dated February 10, 2016, “Drug Pricing
Development Support Center in May 2009 to improve
Standards.”) Procedures for calculation of
regulatory systems and structures to support the
reimbursement prices were specified in detail in
development of such drugs and new indications by
September 2000 (most recent revisions: Notification
pharmaceutical companies. The Chuikyo also
No. 0210-(1) of the Health Policy Bureau dated
joined the support: they discussed potential
February 10, 2016, “Handling of Entries of
approaches and introduced the New Premium
Prescription Drugs in the NHI Price List” and
System for the Promotion of Innovative Drug
Notification No. 0210-(2) of the Economic Affairs
Discovery and Resolution of Off-Label Use in April
Division, Health Policy Bureau dated February 10,
2010 on a trial basis.
2016 “Method for Submission of Requests for Entry in
the NHI Price List for Prescription Drugs”). In addition, the Ministry established the Review
Conference on Unapproved Drugs and Off-label Use
1) When a generic drug identical to the brand
of Drugs of High Therapeutic Need in February 2010
drug is entered in the price list for the first
and, since that time, it has been working to realize the
time, the price of the generic drug is obtained
early approval of unapproved drugs and new
by multiplying the brand drug price by a factor
indications of high medical need that are available in
of 0.5. The factor is 0.4 for “oral” preparations,
foreign countries, by requesting pharmaceutical
in the case that more than 10 brands are
companies to develop such drugs and indications.
already on the market. When both the brand
Since August 2010, the Conference has been
and generic drugs are already entered, the
evaluating individual drugs and indications to
price of a newly entered generic drug is the
determine if they are worthy to be reimbursed by the
same as the lowest of the generic prices.
National Health Insurance System without license
2) A special formula was introduced for
approval, provided that the Social Insurance Council,

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Pharmaceutical Regulations in Japan:

Pharmaceutical Affairs and Food Sanitation Council


(PAFSC) accept the use of unapproved indications
(off-label use) without domestic clinical trial data.

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Pharmaceutical Regulations in Japan:

Marketing approval based on Pharmaceutical Affairs Law

Request by manufacturer/marketing authorization holder for entry in


NHI Price List

Hearing for manufacturer/marketing authorization holder


(Economic Affairs Division)

Examination of data submitted at hearing by authorities (Medical


Economics Division); preparation of pricing draft)

First meeting of drug pricing organization


• Direct expression of opinion by manufacturers/marketing
authorization holder (upon request)
• Hearing of opinions of experts on pricing draft and examination of
the following points:
- Presence of similar drugs
- Suitability of similar or optimally similar drugs
- Necessity of applying premiums
- Evaluation of cost price, etc.
Note) Requests by manufacturer/marketing authorization holder
are distributed.
• Decision concerning pricing draft based on majority opinion of
members

Notification of pricing draft to manufacturer/marketing authorization


holder

<No problems arise> <Problems arise>

Submission of dissenting opinion by manufacturer/marketing


authorization holder

Within 60 Second meeting of drug pricing organization


days as a • Direct expression of opinion by manufacturer/marketing
rule or 90 authorization holder
days at • After manufacturer/marketing authorization holder leaves,
the investigation of necessity of draft revision and revised pricing
longest draft; decision on pricing draft based on majority opinion of
members.

Notification of results after hearing opinions to


manufacturer/marketing authorization holder

Report of pricing draft to Chuikyo and its approval

Entry in NHI Price List

Fig. 22 Reimbursement Pricing Flow-sheet for New Drugs


The parts in the double box show parts involving the drug pricing
(Note 1)
organization
(Note 2) Time clock (agreed on at MOSS conferences)
Entry in price list 4 times per year. Listing within 60 days as a rule or 90 days
at the longest provided that there are no further problems with the pricing
draft.

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Pharmaceutical Regulations in Japan:

(Month) 1 2 3 4 5 6 7 8 9 10 11 12 1
1st/2nd Committees on New Drugs        

Pharmaceutical Affairs and Food


   
Sanitation Council
#
Approval         

Entry into the NHI Price List (new drug


#
    
substance)

Entry into the NHI Price List (products

reported to the Committees / new kit  

products)

Approval (drugs approved until 2/15 or  

8/15) 2/15 8/15

Entry in the NHI Price List (generic


 
drugs)
#
NHI price revision (every 2 years) 

● Rule on the entry into the NHI Price List: Generally, within 60 days (or within 90 days at the latest) after approval
● New formulations of drugs approved after the reexamination period: Classified as generic drugs (time of entry: twice a
year)
● Drugs reported to but not reviewed by the Committee (PAFSC) are handled by the principle of “change on late notice.”
Approvals indicated with  means those that do not require price listing (Approval indicated with  means 4 times/year
of approval of drugs that requires price listing procedures).
# #
 / : Special entry in the year of NHI price revision (every 2 years)
#
: The entry in February in the year of NHI price revision (year of “special entry”) is actually made in April (based on
the 90-day rule).

Fig. 23 Correlation between the Time of Marketing Approval Based on Pharmaceutical


Affairs Law and the Time of Entry in the NHI Price List

2018 - 169 -
Pharmaceutical Regulations in Japan:

Table 14 Methods of Previous Reimbursement Price Revisions


Year Survey R zone Special items
1992 June 1991 15%
1994 June 1993 13% Repricing
1996 June 1995 11% Repricing
10%
Repricing
1997 Sept. 1996 8% (Long listed
Long listed products
products)
5%
Repricing
1998 Sept. 1997 2% (Long listed
Long listed products
products)

Range adjusted, Repricing


2000 Sept. 1999
2% Range adjusted: 2%

Range adjusted, Repricing


2002 Sept. 2001
2% Long listed products (Special adjustment: 4, 5, 6%)

Repricing
Range adjusted,
2004 Sept. 2003 Long listed products (Special adjustment: 4, 5, 6%)
2%
1/2: JP products entered by brand name
Repricing
Range adjusted,
2006 Sept. 2005 Long listed products (Special adjustment: additional 2%,
2%
new 8%) 5%: JP products entered by brand name
Repricing
Range adjusted,
2008 Sept. 2007 Long listed products (Special adjustment: 4, 5, 6%) 1/2: JP
2%
products entered by brand name
Repricing
Range adjusted,
2010 Sept. 2009 Long listed products (Special adjustment: additional
2%
2.2%, new 6%) 1/2: JP products entered by brand name
Repricing
Range adjusted, Long listed products (Special adjustment: additional
2012 Sept. 2011
2% 0.86%, new 6%) 1/2: JP products entered by brand name
Long listed generic products: 0.33%
Repricing
Long listed products (Special adjustment for original
Range adjusted,
2014 Sept. 2013 product which replacement rate with generic products is
2%
less than 60% at 5 years after their entry is permitted: 2%
to 1.5%) 1/2: JP products entered by brand name
Repricing (separately, special repricing)
Long listed products (Special adjustment for original
Range adjusted, product which replacement rate with generic products is
2016 Sept. 2015
2% less than 70% at 5 years after their entry is permitted: 2%
to 1.5%) 1/2: JP products entered by brand name
Unchanged for basic drugs

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Pharmaceutical Regulations in Japan:

Table 15 Revision Rates of Reimbursement Prices


Number of products Number of products Number of products
Year Total Revision rate
with price decrease with price increase with price unchanged

1992 7,681 2,121 3,771 13,573 -8.1%

-8.5% 0.4% -

1994 8,613 2,083 2,679 13,375 -6.6%

-6.8% 0.2% -

1996 9,568 1,697 1,604 12,869 -6.8%

-7.0% 0.2% -

1997 7,718 3,394 862 11,974 *-3.0%

1998 9,921 6 1,765 11,692 -9.7%


-9.7% 0.0% -

2000 8,935 61 2,291 11,287 -7.0%

-7.5% 0.5% -

2002 9,096 98 1,997 11,191 -6.3%

2004 9,645 39 2,309 11,993 -4.2%

2006 10,113 75 3,123 13,311 -6.7%

2008 12,740 77 1,542 14,359 -5.2%

* In 1997, the overall drug price revision was -3.0% when a 1.4% rise based on the increased consumption tax rate
is included.

Since a new premium formula was introduced for the promotion of new drug research and resolution of
problems of treatment not covered by insurance on a trial basis after 2010, above data are not available.
The drug price revision implemented in 2016 is outlined below:
The revision rate is -5.57% on the drug price basis and -1.22% on the medical care expenditure basis.
In addition, the revision rate of the drug price by repricing according to regular market expansion is
-0.90% on the drug price basis and -0.91% on the medical care expenditure basis. For others, special
repricing according to market expansion was implemented.

1. “Premiums for the promotion of innovative drug discovery and resolution of off-label use issue,
etc.”

(1) Products covered

1) Premium is added to the price of a new drug calculated based on current market prices of drugs in
class if the new drug meets all of the following conditions:
i. The drug was listed in the NHI Price List less than 15 years ago and no generic drug has not been
available on the market yet.

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Pharmaceutical Regulations in Japan:

ii. The discrepancy between the NHI price and current market price of the drug is not larger than that
averaged for all drugs available in the NHI Price List.
iii. The drug is manufactured and marketed by a company engaged in the development of a new
drug(s) upon request by the MHLW or application for public recruitment or a company conducting
R&D activities for the development of “new drugs that could truly contribute to the improvement of
medical care quality.”
iv. The drug is not subject to repricing.

2) Number of active ingredients and products that met requirements for premiums (a drug reformulated
(old and new formulations) was counted once)
Oral Injection Topical Total
Number of active ingredients 190 162 64 416
Number of products 376 323 124 823

3) Premium rate
0 − 5.41%

4) The proportion of products which NHI price was maintained the same by obtaining premium
79.7% (656 out of 823 products)

5) The proportion of original products that received premiums whereby generic products are not available
Approximately 37%

(2) Number of products which premiums were abolished

1) The price of a new drug that has become not compliant with Requirements i) or iii) above is reduced by
a premium(s) given in a preceding price revision from the price calculated by referring to current
market price.

2) Number of active ingredients and products which premiums were abolished


Oral Injection Topical Total
Number of active ingredients 29 27 13 69
Number of products 44 52 16 112

2. Special price reduction for original products for which the entry of generic products is slow

1) The price of an original drug which replacement rate with generic products does not exceed 70% over
5 years after the entry of the first generic product in the NHI Price List is lowered by the following rate
from the price calculated by referring to current market price.
i. Replacement rate of < 30%: 2.00%
ii. Replacement rate of ≥ 30% - < 50%: 1.75%
iii. Replacement rate of ≥ 50% -< 70%: 1.50%

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Pharmaceutical Regulations in Japan:

2) Number of active ingredients and products that were subject to special price reduction
Price reduction (%) Oral Injection Topical Total
2.00 85 35 43 163

Number of active 1.75 130 13 25 168


ingredients 1.50 61 32 15 108
Total 276 80 83 439
2.00 150 119 131 400
1.75 288 42 61 391
Number of products
1.50 165 77 24 266
Total 603 238 216 1057

3. Repricing based on expanded market size and indication changes

1) Number of ingredients and products that were subjected to repricing according to expanded market
size
Repricing based on expanded market size Repricing based on special expansion
Oral Injection Topical Total Oral Injection Topical Total
Number of active
13 7 0 20 3 1 0 4
ingredients
Number of products 35 9 0 44 4 2 0 6

2) Number of ingredients and products that were subjected to repricing according to indication changes
Oral Injection Topical Total
Number of active ingredients 1 0 0 1
Number of products 3 0 0 3

4. Premiums for pediatric indication, orphan indication, and innovative clinical usefulness
(therapeutic benefits)

1) Number of active ingredients and products that received premiums for additional pediatric indication
Oral Injection Topical Total
Number of active ingredients 4 2 2 8
Number of products 13 3 2 18

2) Number of active ingredients and products that received premiums for additional orphan indication
Oral Injection Topical Total
Number of active ingredients 4 9 0 13
Number of products 8 23 0 31

3) Number of active ingredients and products that received premiums for innovative clinical usefulness

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Pharmaceutical Regulations in Japan:

(therapeutic benefits)
Oral Injection Topical Total
Number of active ingredients 1 1
Number of products 2 2

5. Price recalculation based on unprofitable trade of products

1) Number of active ingredients and products that were repriced due to unprofitable trade
Number of active ingredients: 47
Number of products: 111

6. Basic drugs
For drugs meeting the following requirements, their prices are totally adjusted to that of the brand with the
largest sales, which will be then maintained.
A. The drug has an established position in clinical settings and is clearly known to be widely used in
clinical practices.
B. Of the concerned already listed drug as well as all similar drugs with the same composition and
dosage form category as those of the former, at least one drug has been on a NHI Price List for 25
years or longer.
C. If there are similar drugs with the same composition and dosage form category as those of the
concerned already listed drug, the mean discrepancy of the similar drugs including the concerned
already listed drug between the NHI price and current market price does not exceed that of all the
listed drugs.
D. The discrepancy of the concerned already listed drug between the NHI price and current market
price does not exceed the mean discrepancy of all the already listed drugs.
Ingredients subjected to repricing: 134
Products subjected to repricing: 439

7. Other
Number and market share of products by the category of drugs in the NHI Price List (source: Drug price
survey conducted in September 2015) (The number of products was obtained by the survey conducted in
April 2014 and the market share in sales quantity and amount in September 2015.)
Number of products Share in sales quantity Share in sales amount
Generic drugs
2,246 18.0% 55.9%
not available
Original drugs
Generic drugs
1,583 26.1% 24.9%
available (A)
Generic drugs (B) 8,555 33.5% 12.4%
Other drugs (JP standard drugs,
3,541 22.4% 6.8%
crude drugs, etc.)

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Pharmaceutical Regulations in Japan:

Share in sales quantity* (new index) = (B) / [(A) + (B)] = 56.2%

*Source: “Roadmap for Further Promoting the Use of Generic Drugs” (MHLW April 2013)

Note 1) Generic drugs are defined as any drugs other than those approved as new drugs by the
Pharmaceutical Affairs Law (excluding “drugs in other classes”)
Note 2) “Drugs in other classes” are defined as JP standard drugs, crude drugs, biologicals (including
vaccines, blood products), and drugs approved in or before 1967.
Note 3) Figures are rounded to one decimal place: the total does not add up to 100%.

Number of products included in the NHI Price List as of April 2016.


Oral Injection Topical Dental Total
Number 9,617 3,871 2,411 26 15,925

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Pharmaceutical Regulations in Japan:

Table 16 Requirements for Applying Premiums


<Types, requirements and rates of premiums>
Premium for innovativeness (rate: 70-120%)
Applied to new drug products in the NHI Price List meeting all of the following requirements:
1) The newly entered drug has a clinically useful new mechanism of action.
(1) 2) The newly entered drug has been shown objectively to have greater efficacy and safety than existing
(comparator) drugs in the same class.
3) The newly entered drug has been shown objectively to improve treatment of the indicated disease or
trauma.
Premium for usefulness I (35-60%)
(2)
Applied to new drug products in the NHI Price List that meet two of the three requirements listed above
Premium for usefulness II (5-30%)
Applied to new drug products in the NHI Price List that meet one of the following requirements (excluding
products to which the innovativeness premium or usefulness premium (I) is applied):
1) The newly entered drug has a clinically useful new mechanism of action.
2) The newly entered drug has been shown objectively to be more effective and safe than existing
(3)
(comparator) drugs in the same class.
3) The newly entered drug has been shown objectively to offer, as a result of formulation improvement,
greater therapeutic usefulness than other drugs in the same class.
4) The newly entered drug has been shown objectively to improve treatment of the indicated disease or
trauma.
Premium for pediatric use (5-20%)
Applied to new drug products in the NHI Price List meeting all of the following requirements:
1) The newly entered drug is explicitly shown in the Indications section or Dosage and Administration
(4) section to be indicated for children (including infants, suckling infants, newborns, and low-birthweight
infants).
2) The premiums for pediatric use must not have been given to comparator drugs available in the NHI Price
List.
Premium for marketability (I) (10-20%)
Applied to new drug products in the NHI Price List meeting all of the following requirements:
1) Orphan drugs pursuant to the provisions of Article 77-2 of the Pharmaceutical Affairs Law in the NHI
(5) Price List for which the orphan indications for the disease or trauma are the main indications of the drugs
concerned.
2) The premium for marketability (I) must not have been given to comparator drugs available in the NHI Price
List.
Premium for marketability (II) (5%)
Applied to new drug products in the NHI Price List meeting all of the following requirements (excluding
products to which marketability premium (I) is applied):
1) New drugs in the NHI Price List for which the main indications correspond to separately specified
(6)
indication categories with a small market scale among drug indication classifications specified in the
Standard Commodity Classification of Japan.
2) The premium for marketability (I) or (II) must not have been given to comparator drugs available in the NHI
Price List.
Premium for the world’s first registration in Japan (10%)
Applied to new drug products in the NHI Price List meeting all of the following requirements (the price of
a comparator drug should be free of the premium for the world’s first registration in Japan, when the
price of a new drug is calculated by the Similar Efficacy Comparison-Based Price Setting Method I or II
comparing with the price of the comparator to which the premium for the world’s first registration in
Japan was applied):
(7) 1) A new drug with novel action mechanism different from that of any drugs already approved in foreign
countries (specifically in the US, UK, Germany, and France) and Japan
2) A new drug first approved in Japan
3) A new drug ascertained not to be marketed solely in Japan based on foreign clinical development status
(including R&D plan), clinical trial notification, etc.
4) A new drug for which premium for innovativeness or usefulness I is applicable

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Pharmaceutical Regulations in Japan:

Index
1 C
15-Day reports (ADR)............................................. 59, 125 Certificates Issued by MHLW ......................................... 43
Classification of reexamination approval ...................... 132
3 Clinical development/studies
Phases of studies....................................................... 79
30-Day reports (ADR)................................................... 126 Clinical Studies............................................................... 78
Clinical study reports (FSR) ........................................... 82
Codevelopment of Drugs ............................................... 42
7 Combination Products .................................................... 41
7-Day reports (ADR) ...................................................... 59 Commentaries on Precautions in package inserts ....... 152
Compliance and Narcotics Division (PFSB) ..................... 3
Compliance Reviews...................................................... 64
A Conditional Accelerated Approval System for
Pharmaceuticals............................................................. 40
ADR reporting system
Reporting by pharmaceutical companies ................. 125 Common Technical Document (CTD) ........................... 105
ADR Reporting System CTD Module 1 ................................................................. 69
Reporting by MHLW ................................................. 124 CTD Module 2: Data summaries....................................... 70
Advanced Review with Electronic Data Promotion CTD Module 3: Quality ..................................................... 70
Group ...............................................................................8 CTD Module 4: Nonclinical study reports ........................... 71
Adverse Drug Reaction (ADR) and Infection CTD Module 5: Clinical study reports ................................ 71
Reporting........................................................................ 29
Age classification for pediatric use ............................... 143
AIDS Research Center (NIID) ........................................ 10

Approval and Licensed Development of New Drugs ........................................... 56
Data Required for Approval Applications .................... 68 Dissemination of drug information
Approval and licenses General .................................................................... 139
Acceptance of foreign clinical trial data ...................... 72 Safety information .................................................... 147
Application forms ....................................................... 32 Dissemination of information .......................................... 29
Data to be Attached to Approval Application................... 71
Dissemination of information on adverse reactions
Approval and Licenses
to drugs ........................................................................ 151
Approval Applications for Drugs Manufactured
Overseas ............................................................... 42 Drug Master File (DMF) ................................................. 23
Transfer of Marketing Approvals ................................ 42 Drug Abuse Control ........................................................ 31
Approval review.............................................................. 63 Drug Development
Approval System for Regenerative Medicine ................. 40 Process from Development to Approval ..................... 56
Article 42 of the Pharmaceutical Affairs Law .................. 45 Drug Marketing Approvals .............................................. 32
Drug pricing .................................................................. 160
Drug Safety Update...................................................... 152
B Drug Seller Licensing ..................................................... 23
Drugs
Biological products ......................................................... 18
Classification .............................................................. 17
Biosimilar Products .................................................. 41, 87 Definition .................................................................... 17
Biotechnological products .............................................. 85 Quality Standards Based on Notifications .................. 46
Blood and Blood Products Division (PFSB)......................4 Drugs for Pediatric Use .................................................. 36
Brand names of prescriptions drugs ............................. 145 Drugs using materials of human or animal origin ........... 86
bridging studies .............................................................. 72


Early post-marketing phase vigilance........................... 118

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Pharmaceutical Regulations in Japan:

Economic Affairs Division (HPB) ......................................4 I


Electronic information dissemination
Safety information .................................................... 152 ICH ................................................................................. 88
Emergency safety information (Yellow letter) ............... 149 Infectious Diseases Information Center (NIID) ............... 10
Entries for biological products ...................................... 144 Information for drugs which completed
Entry of generic drugs in the NHI price list ................... 166 reexamination or reevaluation ...................................... 151
International Conference on Harmonization (ICH) ......... 89
Interview advice meetings .............................................. 60
G Investigational product GMP .......................................... 84
GCP Investigational products
General requirements ................................................ 83 Quality........................................................................ 79
General Affairs Division (PFSB) .......................................2 Issues related to the use of determination of
GMP unapproved drugs and off-label use ............................. 166
Compliance review ..................................................... 66
Global harmonization ................................................. 67
GMP compliance inspection ........................................... 66 J
Good Clinical Practice (GCP) ......................................... 26
Japan Agency for Medical Research and
Good Laboratory Practice (GLP) .................................... 25
Development (AMED) ...................................................... 9
Good Laboratory Practice (GLP) .................................... 75
Japanese Pharmacopoeia (JP) ...................................... 43
Good Manufacturing Practice (GMP) ............................. 22
Japanese Pharmacopoeia and Other Standards ........... 43
Good Post-marketing Study Practice (GPMSP) ............. 28
Good Vigilance Practice (GVP) .................................... 114
Government Batch Test K
Quality of Drugs ......................................................... 46
GPMSP .......................................................................... 28 Kansai Branch .................................................................. 8
GPSP
Paper Compliance Review and On-site GPSP
Surveys for Reexamination and Reevaluation ..... 124 L
GPSP ........................................................................... 120 Labeling and Package Inserts ........................................ 24
Guidance-mandatory drugs ............................................ 17 Labeling of excipients................................................... 144
Guidelines Law Concerning Access to Information .......................... 30
Clinical evaluation ...................................................... 83
Nonclinical Studies ......................................................... 73
Guidelines Concerning Drug Approval Applications ....... 72 M
Guidelines for bioequivalence Studies ........................... 77
Manufacturing Business and Accreditation License ....... 20
Guidelines for General Pharmacological Studies ........... 77
Manufacturing/Marketing Approval Application with
Guidelines for Pharmacokinetic Studies ......................... 77
Electronic Data ............................................................... 34
Guidelines for Promoting Optimal Use ........................... 40
Manufacturing/Marketing Approvals
Guidelines for Stability Tests .......................................... 74
Manufacturing/Marketing License .................................. 19
Guidelines for Toxicity Tests .......................................... 75
Marketing Approval Review............................................ 32
Guidelines on Physicochemical Properties,
Marketing Approvals....................................................... 32
Specifications, and Tests Methods ................................. 73
Medical benefits under NHI programs .......................... 161
GVP.............................................................................. 114
Medical Device Evaluation Division (PFSB) ..................... 2
Microdose studies .......................................................... 81
H Ministry of Health, Labour and Welfare (MHLW)
Organization and function ............................................ 1
Health and Medical Services Law for the Aged ............ 160
Health insurance programs .......................................... 160
Health Policy Bureau (HPB) .............................................4 N
History of health insurance programs ........................... 160
National Institute of Biomedical Innovation ...................... 9
Hokuriku Branch ...............................................................9
National Institute of Health Sciences (Health
Sciences) ......................................................................... 5

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Pharmaceutical Regulations in Japan:

National Institute of Infectious Diseases (NIID) .............. 10 Style and format ....................................................... 141
NHI price list ................................................................. 162 Package Inserts in English ........................................... 146
NHI reimbursement of medical fees ............................. 161 Package inserts of guidance-mandatory drugs ............ 154
Nonclinical studies Packaging Strategy for World-first Products................... 38
Requirements............................................................. 78 Paper reviews ................................................................ 65
Non-prescription drugs ................................................... 18 Patent System ................................................................ 30
Non-prescription Drugs .................................................. 71 Patient-requested Therapy System ................................ 27
Periodic infection reports for biological products .......... 128
Periodic safety reports ................................................. 130
O Pharmaceutical Affairs and Food Sanitation
Office of Cellular and Tissue-based Products Council (PAFSC) .............................................................. 9
(PMDA) ............................................................................7 Pharmaceutical and Medical Device Act ........................ 15
Office of Chemical Safety (PFSB) ....................................3 Pharmaceutical Evaluation Division (PFSB) .................... 2
Office of Compliance and Standards (PMDA) ..................8 Pharmaceutical Interview Forms (IF) ........................... 147
Office of Drug Induced Damages (PFSB) ........................2 Pharmaceutical Laws ..................................................... 15
Office of Generic Drugs (PMDA) ......................................7 Pharmaceutical laws and regulations ............................. 15
Office of in Vitro Diagnostics (PMDA) ...............................7 Pharmaceutical Safety and Environmental Health
Office of International Cooperation ...................................8 Bureau (PSEHB) .............................................................. 2
Office of International Programs .......................................8 Pharmaceutical Safety Division (PFSB) ........................... 3
Office of Manufacturing/Quality and Compliance Pharmaceutical Supervision........................................... 47
(PMDA) ............................................................................8 Pharmaceuticals and Medical Devices Agency, an
Office of Medical Devices I (PMDA) .................................7 Independent Administrative Organization......................... 5
Office of Medical Devices II (PMDA) ................................7 Pharmacological studies
Office of Medical Devices III (PMDA) ...............................7 Requirements............................................................. 79
Phase I of clinical studies ............................................... 80
Office of Medical Informatics and
Epidemiology(PMDA) .......................................................8 Phase II of clinical studies .............................................. 80
Phase III of clinical studies ............................................. 80
Office of New Drug I (PMDA) ...........................................6
Phase IV of clinical studies ............................................ 81
Office of New Drug II (PMDA) ..........................................6
Office of New Drug III (PMDA) .........................................6 PMS ............................................................................. 111
Post-marketing surveillance (PMS) .............................. 111
Office of New Drug IV (PMDA) .........................................7
Precautions (package inserts) ...................................... 143
Office of New Drug V (PMDA) ..........................................7
Office of OTC/Quasi-drugs (PMDA) .................................7 Prescription drugs .......................................................... 17
Prescription Drugs.......................................................... 71
Office of Review Administration (PMDA) ..........................6
Prevention of Medical Accidents .................................... 47
Office of Review Management (PMDA)............................6
Office of Safety I (PMDA) .................................................8 Pricing formula for reimbursement price revisions ....... 162
Priority Review System .................................................. 35
Office of Safety II (PMDA) ................................................8
Priority reviews ............................................................... 15
Office of Standards and Guidelines Development
(PMDA) ............................................................................6 Procedures for Clinical Trials ......................................... 57
Product Recalls .............................................................. 47
Office of Vaccines and Blood Products (PMDA) ...............7
Proper Advertisement..................................................... 25
On-site reviews .............................................................. 65
Orphan Drugs................................................................. 36 Public disclosure of information on new drug
development................................................................... 88
Outline of Pharmaceutical Regulations .......................... 17
Outline of prescription of drug information.................... 146

P Recent revisions of NHI price list ................................. 164
Reevaluation .................................................................. 28
Package inserts
Background .............................................................. 139 Reevaluation
Guidelines ................................................................ 140 System ..................................................................... 132
Headings and their sequence .................................. 142 Reexamination ............................................................... 28
Information to supplement package inserts.............. 146 Data and procedures ............................................... 131
Non-prescription drugs ............................................. 153 Designated classifications........................................ 132

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Pharmaceutical Regulations in Japan:

Designation of drugs ................................................ 129 Specified biological products .......................................... 18


System ..................................................................... 129
Standards for Biological Materials .................................. 45
Regulations for Imported Drug Management and
Structure and Layout of Package Insert for
Quality Control ............................................................... 67
Prescription Drugs........................................................ 156
Regulatory Science Strategy Consultations for
Studies of drug interactions............................................ 81
Regenerative Medicine Products ................................... 39
Studies of drug metabolites............................................ 81
Reimbursement prices for new drugs ........................... 165
Research and Development Division (HPB).....................4
Restrictive Approval System........................................... 36 T
Risk Management Plan .................................................. 29
Trial Conducted from a Compassionate Viewpoint
Risk management plan (RMP) ..................................... 118
(expanded trial) .............................................................. 27



Safety flash report ( ...................................................... 150
Unapproved Drugs and Drugs of Off-label Use .............. 37
Safety information
Reporting System by Medical Personnel ................. 128
Safety Measures against Bovine Spongiform W
Encephalitis (BSE) ......................................................... 48
Safety monitoring WHO safety monitoring program .................................. 128
During clinical studies ................................................ 59
Safety studies
Requirements............................................................. 79 Y
SOP for PMS ................................................................ 115
Yellow letter .................................................................. 149
Special populations ........................................................ 81

2018 - 180 -
Pharmaceutical Regulations in Japan:

Participating Company List

Under the supervision of Ministry of Health Labour and Welfare Japan, this publication
has been updated regularly with the cooperation of the enthusiastic editors below.

Leader: Katsunori KURUSU


Diabetes & Cardiovascular Regulatory Affairs
(Chapter 1) Sanofi KK Oncology & Immunology 2 Regulatory Affairs:
Katsunori KURUSU
Eisai Co, Ltd Japan Regulatory Affairs: Michiyuki SUZUKI

(Chapter 2) EA Pharma Co, Ltd Regulatory Affairs: Tsuyoshi KOBAYASHI


Takeda Pharmaceutical
Regulatory Affairs: Katsunori INUI
Company Limited
Daiichi Sankyo Co, Ltd New Drug Regulatory Affairs: Yoshiyuki HATTORI
Regulatory Development Department:
Janssen Pharmaceutical KK
Taihei SHIRASAKA
Regulatory Policy & Intelligence:
(Chapter 3) MSD KK
Kanji HIRAI, Jun ONO
UCB Japan Co, Ltd Regulatory Affairs: Yasuhiro HASEGAWA
Mitsubishi Tanabe Pharma
Regulatory Affairs: Mamoru IKEDA
Corporation
Shionogi & Co, Ltd Regulatory Affairs: Kazuyo MARUCHI
(Chapter 4)
Kyowa Hakko Kirin Co, Ltd PV Operations Department: Hiroyuki OHTSUKA
Regulatory Intelligence & Management
(Chapter 5) Chugai Pharmaceutical Co, Ltd
Department: Yuichi TAKIDO, Yasuhiro KITSUTA
(Chapter 6) Otsuka Pharmaceutical Co, Ltd Regulatory Affairs Department: Toshio SATO

Contact:
JAPAN PHARMACEUTICAL
Office of International Affairs
MANUFACTURERS ASSOCIATION

Administrative 2-3-11 Nihonbashi-Honcho, Chuo-ku, Tokyo 103-0023, Japan


Office e-Mail address: international @ jpma.or.jp
Phone 81-3 (3241) 0326
Fax 81-3 (3242) 1767

2018 - 181 -

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