Why Pharma Companies Are Choosing India for Clinical Trials: Cost, Talent & Compliance

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Frequently Asked Questions

Can a Drug Clinical Trial be initiated after two years of approval by CLA?

No. A CLA approved clinical trials shall be initiated by enrolling the first subject within a period of 2 year from the date of grant of permission, failing which the sponsor or investigator should get prior permission from CLA before initiating the trial. The permission to initiate clinical trial granted in Form CT-06 or automatic approval in Form CT 4A shall remain valid for a period of 2 years from the date of its issue, unless extended by the CLA.

Yes. The status of enrolment of the trial subjects shall be intimated to the CLA on quarterly basis or as appropriate as per the duration of treatment in accordance with the approved clinical trial protocol, whichever is earlier. Further, six monthly status report of each clinical trial, as to whether it is ongoing, completed or terminated, shall be submitted in SUGAM portal. In case of termination of any clinical trial the detailed reasons for such termination shall be communicated to CLA.

A three-tier mechanism has been established for granting approval for research and development activities on recombinant DNA products and monitoring and evaluation of research activities involving recombinant DNA technology.

SUGAM portal is an e-Governance solution for CDSCO. SUGAM enables online submission of applications requesting for permissions related to drugs, clinical trials, ethics committee, medical devices, vaccines and cosmetics. SUGAM has facility for users to possess multiple roles on the same registered ID. Applicant can register with different purposes with the assigned roles and forms.

A “clinical trial” in relation to a new drug or investigational new drug means any systematic study of such new drug or investigational new drug in human subjects to generate data for discovering or verifying its, clinical or; pharmacological including pharmacodynamics, pharmacokinetics or; adverse effects, with the objective of determining the safety, efficacy or tolerance of such new drug or investigational new drug

For drugs that are discovered in India, or research and development of the drug are being conducted in India, and if the drug is intended to be manufactured and marketed in India, the applications to conduct clinical trials will be considered approved if there are no queries raised by Drugs Controller General of India (DCGI) within 30 days of the application. However, the sponsor will still have to notify the DCGI prior to initiation of the clinical trial in Form CT-4A.

Any person who intends to manufacture a biological product as well as substance for CT shall submit application in CT-10 for obtaining permission from the CLA to manufacture such biological product. Any person who intends to manufacture a formulation of a biological product after obtaining biological substance from an approved source for CT shall submit application in CT-10 for obtaining permission from the CLA in Form CT-11 to manufacture such biological product. Any person who intends to manufacture a biological product after obtaining biological substance from an unapproved source for shall submit application in CT-12 for obtaining permission from the CLA in Form CT-14 to manufacture such biological product. In such case, the biological substance manufacturer is also required to submit application to CLA in Form CT-13 for obtaining permission in Form CT-15 to manufacture and supply the unapproved biological substance to the formulator for development of the biological product. Any person who intends to manufacture an investigational biological product after obtaining the unapproved biological substance from another manufacturer for CT shall submit application in CT-12 for obtaining permission from the CLA in Form CT-14 to manufacture such investigational biological product. In such case the biological substance manufacturer is also required to submit application to CLA in Form CT-13 for obtaining permission in Form-CT15 to manufacture and supply the unapproved biological substance to the formulator for development of the investigational biological product.

As per the new provision of pre-submission meetings, applicants can discuss their projects with the regulators and subject experts by paying a certain fee, before making actual submission to the regulator, for seeking guidance about the requirements of law and procedure applicable for their projects.

After evaluating the Form CT-16 and documents, if satisfied, that the requirements of these rules have been complied with, grant the licence to import the biological product for CT in Form CT-17 within a period of 90 working days from the date of receipt of the application.

No fee shall be chargeable in respect of application for conduct of clinical trial for orphan drugs as defined in clause (x) of rule 2 of the New Drugs and Clinical Trial Rules, 2019. The Rules exempt local clinical trials for orphan drugs permitted to be imported for sale or distribution. The phase IV study requirement could also be reduced in case of orphan drugs.

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