RE: timeframe5 Oct 2017 12:56
Based on what RP have disclosed, estimated approval timelines are:
HK- August 25th interims indicate that submission is �in preparation�. From receipt of a complete submission, review and grant takes five months. However, time to submission will depend on which manufacturing data is submitted. �Historical� 12 or 20 dose CMC, as long as it includes the necessary region specific stability data, would not entail delay, but if they go with the 300l 12 dose data, earliest submission would be Q1/Q2 2018. So, Q1 2018 possible, but could go to Q3-ish.
There�s a potential complication in that, with the transfer of the European MA to Recordati, Plethora may no longer be considered as the wholesaler by the HK regulators.
China- there is a raft of amendments under discussion which could reduce approval from around the five years it currently takes. Most are intended to speed Chinese access to leading edge products, but there is an amendment relating to drugs with no patent protection in China which, in theory, could allow a Class 3 filing as a generic product. However, I�d still assume 5 years until if and when relevant amendments are incorporated.
CFDA considers HK and Macau as not being China for regulatory purposes, there is no �backdoor� into China.No OTC registration without history of ex-China OTC use.
US- Interims state that an FDA meeting is scheduled sometime in Q3, and I�m assuming that this is to discuss the crucial PRO issue and fixed-dose combination criteria. The PRO was claimed to have been submitted in March 2016, but with no announcement or study registration, it�s reasonable to assume that the FDA still have issues with it. If the COA does give the thumbs up this year, two part validation and pivotal study with revised endpoints would take a minimum of 18 months, plus a year for submission including pre submission review. So, earliest approval mid 2020.