Professional Documents
Culture Documents
2018 Pharmaceutical Administration and REgulation JApan
2018 Pharmaceutical Administration and REgulation JApan
2018 Pharmaceutical Administration and REgulation JApan
Pharmaceutical
Administration and
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)
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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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)
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(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
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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.
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Ministry Proper
Minister’s Secretariat
Equal Employment,
Children, and Families
Bureau
Insurance Bureau
Pension Bureau
Director-General for
Policy Planning and
Evaluation
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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
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Committee on Guidance-Mandatory
Drugs and Non-prescription Drugs
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Fig. 3 Organization of the Pharmaceutical Affairs and Food Sanitation Council (PAFSC)
(17 Committees and 19 Subcommittees)
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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
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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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(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.
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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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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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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
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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
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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
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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
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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)
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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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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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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:
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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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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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
2018 - 39 -
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
2018 - 40 -
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,
2018 - 41 -
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
2018 - 42 -
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).
2018 - 43 -
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,
2018 - 44 -
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
2018 - 46 -
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:
Patent
right 1
Patent
right 2 Patent Registration of Expiration
application establishment (20 years)
of patent right
2018 - 50 -
Pharmaceutical Regulations in Japan:
Outside
Applicant PMDA
experts
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.
Inquiries
Approval Pharmaceutical Affairs
MHLW and Food Sanitation
Replies Council
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Pharmaceutical Regulations in Japan:
overseas
drugs manufactured
Restrictive approval of
Fig. 6 Procedure for manufacturing and marketing approval of drugs for overseas
manufacturers in Japan
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Pharmaceutical Regulations in Japan:
PMDA MHLW
Selection of candidate drug items for Doc preparation Committee’s review PAFSC’s review & entry in JP
entry
Evaluation of
Letter of
request
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
Public comments
Entry in JP
Review by Review by
PAFSC’s PAFSC’s
Approval
MHLW Committee Committee
on JP on JP
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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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
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Pharmaceutical Regulations in Japan:
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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
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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Pharmaceutical Regulations in Japan:
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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
2018 - 65 -
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
2018 - 67 -
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,
2018 - 68 -
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
2018 - 69 -
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
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Pharmaceutical Regulations in Japan:
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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
2018 - 72 -
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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Evaluation and Licensing Division, PAB dated Dependence (Notification No. 383 of the Narcotics
February 15, 1991). Division, PAB dated June 7, 1978).
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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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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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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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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
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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,
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Basic investigation
Screening tests
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
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
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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.
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
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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.
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
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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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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
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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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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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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
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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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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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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
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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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Pharmaceutical Regulations in Japan:
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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Pharmaceutical Regulations in Japan:
[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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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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Pharmaceutical Regulations in Japan:
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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Pharmaceutical Regulations in Japan:
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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Pharmaceutical Regulations in Japan:
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:
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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:
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Pharmaceutical Regulations in Japan:
Post-marketing
surveillance GVP, GPSP (GCP)
(PMS) system
Reexamination system
Reexamination application
Reevaluation system
2018 - 134 -
Pharmaceutical Regulations in Japan:
Visits of MRs to
physicians to provide
safety information
and to ask
cooperation
Early post-marketing
phase vigilance
2018 - 135 -
Pharmaceutical Regulations in Japan:
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
2018 - 136 -
Pharmaceutical Regulations in Japan:
( MHLW ) ( PMDA)
Submission
2018 - 137 -
Pharmaceutical Regulations in Japan:
(MHLW) (PMDA)
Review by PMDA
Submission
2018 - 138 -
Pharmaceutical Regulations in Japan:
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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
2018 - 142 -
Pharmaceutical Regulations in Japan:
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.)
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Pharmaceutical Regulations in Japan:
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
2018 - 145 -
Pharmaceutical Regulations in Japan:
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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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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
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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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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:
(PMS Subcommittee, Drug Evaluation Committee, JPMA) Note: Sections in refer to Precautions
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Pharmaceutical Regulations in Japan:
**
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
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
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:
16.8 Others
17.3 Others
18. Pharmacology
18.1 Mechanism of action
18.2 ○○ action
19. Physicochemistry
22. Packaging
23. References
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Pharmaceutical Regulations in Japan:
Extraction of
noteworthy adverse
reactions
Sharing information
with the Ministry
Inquiries to
companies
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Pharmaceutical Regulations in Japan:
emergency
cases (1 week)
Emergency Company’s
Safety
Revision
Opinion
Information Consultation by the
Company
(1 week) (1 week)
Revise the
Package Insert
urgent Expert Review
cases (every 5 weeks in
Safety Information principle)
(1 week)
(1 week)
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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
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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
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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.
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Pharmaceutical Regulations in Japan:
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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
products)
● 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).
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Pharmaceutical Regulations in Japan:
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:
-8.5% 0.4% -
-6.8% 0.2% -
-7.0% 0.2% -
-7.5% 0.5% -
* 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) 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%
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. 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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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
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
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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*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%.
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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
D
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
E
Early post-marketing phase vigilance........................... 118
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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
R
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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S
U
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
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Pharmaceutical Regulations in Japan:
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.
Contact:
JAPAN PHARMACEUTICAL
Office of International Affairs
MANUFACTURERS ASSOCIATION
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