The development of affordable biologics and biosimilars are of particular interest in Brazil as the utilization of these products
represents a significant portion of the Brazilian Ministry of Health's total budget. In order to increase access to these
medications, the Agência Nacional de Vigilância Sanitária (ANVISA) released guidelines in December 2010 that further define
a pathway to bring biologics and subsequent entry biosimilar medications to market in Brazil.
J. Michael Nicholas
The guidelines require applicants to provide a record of whole quality information and necessary clinical data for their proposed
biologic or biosimilar product. While this is an imperative first step in bringing affordable versions of these medications
to the Brazilian market, additional guidance is needed from ANVISA to encompass complex medications that fall outside the
realm of biologics. These medications, namely non-biologic complex drugs (NBCDs), possess large synthetic molecules, including
synthetic proteins, and are typically comprised of higher order structures.
As a result, NBCDs are often difficult to fully characterize. Taking into considering these regulatory complications, additional
guidelines for development of these therapies in Brazil will ensure patients secure affordable medications that are proven
safe and efficacious.
Small molecule, biologic, and NBCDs medications
Small molecule therapies, like aspirins, are manufactured by chemical synthesis and generic equivalence can be demonstrated
by relatively simple, straightforward testing. While complex medications are also developed via chemical synthesis in laboratories,
they can possess primary, secondary, and tertiary structures, similar to biologics, and may contain an enormous number of
polypeptide sequences. NBCDs are often comparable to biologics in size, but the latter are derived from living matter, or
manufactured in living cells using recombinant DNA biotechnologies rather than being chemically produced. The figure on page
65 depicts the differences between complex drugs, biologics, and small molecule medications.
As illustrated, it can be difficult, and in some cases impossible, to characterize the active ingredients of NBCDs. Even slight
modifications in the amino acid sequences of molecular weight of these products can have major safety and efficacy implications.
Furthermore, changes in the manufacturing process conditions for NBCDs can cause significant changes to the primary and secondary
structures, leading to challenges in establishing bioequivalence for follow-on products.
One example of an NBCD is glatiramer acetate (Copaxone), indicated for relapsing remitting multiple sclerosis (RRMS) and part
of the glatiramoid class of drugs. Glatiramer acetate is a heterogeneous mixture of polypeptides comprising of the four amino
acids L-glutamic acid, L-alanine, L-lysine and L-tyrosine. The constituent amino acid sequences and chain lengths of polypeptides
in glatiramer acetate vary and the pharmacologically active epitopes cannot be identified. Currently available analytical
technology is incapable of characterizing all of the active sequences of this product, so pharmaceutical equivalence cannot
be assured by follow on manufacturers. Consequently, the only way to guarantee safety and efficacy of follow on versions of
glatiramer acetate would be through clinical trials with relapse rate as the clinical endpoint. However, this may not be the
case for all NBCDs. When securing applications for follow on versions of NBCDs, ANVISA should determine the need for clinical
trials on a case-by-case basis to reduce the amount of unnecessary spend and time by manufacturers. As a result, NBCDs possess
many of the same challenges of biologics and warrant similar specifications to ensure patient safety continues to remain a
top priority. When securing applications for follow-on versions of NBCDs, ANVISA should determine the need for clinical trials
on a case-by-case basis to reduce the amount of unnecessary spend and time by manufacturers.
Regulatory framework surrounding complex drugs
Currently, ANVISA has not yet defined a pathway for follow-on versions of complex medications. The 2010 Biosimilar Guidelines
released by the Brazilian regulatory agency took into account frameworks from around the world including Health Canada (Canada),
EMA (Europe), CECMED (Cuba), KFDA (Korea) and the World Health Organization (WHO). In its guidelines, ANVISA outlined two
potential pathways to bring biosimilars to market: the development copy for comparison path and the individual development
copy path. In the development copy for comparison path, applicants are required to compare their biosimilar to the reference
product by supplying information surrounding cellular origin, production process, quality parameters, and non-clinical/clinical
This route enables extrapolation of therapeutic indications and was adapted from the WHO SBP Guidelines. The individual development
copy path is used in instances where the biosimilar and reference product cannot be compared. With this pathway, applicants
are requested to provide information surrounding the technological development of their product including production data,
quality control, and non-clinical and clinical Phase I/II studies on a non-comparison basis. The data submission can then
be increased or decreased according to the complexity and specific characteristics of the molecule. Currently, there is one
biological product, a low molecular weight Heparin, approved under the individual development pathway and two more products
On September 10-11, 2012, ANVISA and the US Food and Drug Administration (FDA) came together to discuss issues in law, regulation,
and trade between the United States and Brazil surrounding food, medical devices, and pharmaceuticals. During this meeting,
industry experts discussed the recent legislation, regulation, and guidance covering biosimilars, follow-on NBCDs, and the
bioequivalence standards for both. Discussion at the meeting surrounded the substantially different approaches between the
United States and Brazil in defining the pathway of these products. For example, unlike the United States, Brazil does not
recognize a data exclusivity period for a company introducing a biologic. In addition, Brazilian law does not apply to complex
drugs, a complicating factor for Brazilian innovators. Conferences of this kind are necessary to navigate the new frontiers
being explored for complex drugs by regulatory authorities.