Best Practices For Conducting Multinational Clinical Trials | Page 8

Multinational pharmaceutical companies typically conduct Phase II or III studies in Taiwan for products that will be made available in Taiwan. The clinical trial application can be submitted in Chinese or English; however, the informed consent form and any questionnaires must be in Chinese. Parallel review of the ethics application and clinical trial application is possible, but must be clearly stated in the clinical trial application. Also of note, upon trial completion, investigational products cannot be destroyed or exported immediately; however, a local depot can be used instead.11 In Vietnam, all new products that have been available in other countries for less than 5 years must undergo a Vietnam-based clinical trial.12 For all countries, it would be beneficial to have local legal representation assist with regulatory requirements, particularly when the process is not well defined. This will also assist with country-specific contracting and payment processes. Timelines In the majority of Asian countries, approval timelines are no different from those in the US or Europe (Table 3). The longest review times are experienced in China and can take up to 7-12 months8, or longer if the trial is evaluating a biological product. In multinational trials, this can result in a 2-6 year lag between the introduction of the product in US/Europe and China.8 An amendment requires a new application, and the entire review process must begin again.8 What About Japan? Japan will be discussed separately here owing to its unique characteristics in relation to clinical trials. The regulatory bodies in Japan are the Ministry of Health, Labor and Welfare (MHLW), which is ultimately responsible for drug approval, and the Pharmaceuticals and Medical Devices Agency (PMDA), which reviews the drug application submission and safety report. The clinical trial application must be in Japanese. Per site accrual rate is typically very low, and Japan is considered one of the most expensive places to conduct a clinical trial. Investigator and site fees can be high. In addition, consultations with the PMDA incur a fee, while other countries do not charge consultation fees. Relationships with investigator sites are especially important in Japan; failing to  establish trust-based relationships before initiating a trial will more than likely result in an unsuccessful trial. NDAs require data from Japanese subjects who were studied in Japan, including results f  rom a study to determine the recommended dose in Japanese patients.13 Japanese Phase I data must be available. Phase II can be a global trial. Phase III can also be  conducted as a global trial, unless ethnic factors are determined to influence the efficacy;  then, Phase III should be conducted as a local clinical trial. Depending on the study/ indication, 10-20% of the patients in the Phase III evaluation must be Japanese.  In contrast, quick start-up times are possible in most other Asian countries (Table 3). Ongoing initiatives between Japan, Korea, and China are addressing ways for the countries to accept data from each other, enabling faster reviews.4 Prior FDA or European Medicines Agency (EMA) approval allows for a fast-track review of the study protocol by the regulatory bodies in China, Taiwan, Korea, Hong Kong, and possibly others. In Taiwan, a fast-track review is also allowed with prior approval of a multinational clinical trials protocol from any of the following countries: United Kingdom, France, Japan, Switzerland, Canada, Australia, Belgium, Sweden, or Germany. In China, a fast-track application based on prior FDA or EMA approval can reduce the time from 13 months to 8–10 months. clinipace.com 7