FDA Complete Response Letters Highlight Growing CMC Challenges in Immunotherapy Development
- Recent FDA complete response letters for Replimune's RP1 and Capricor's CAP-1002 underscore increasing regulatory emphasis on analytical validation, tech transfer execution, and manufacturing controls in immunotherapy development.
- Despite following FDA guidance throughout development, both companies received unexpected rejections, with 74% of CRLs issued from 2020 to 2024 citing quality or manufacturing deficiencies.
- Industry experts warn that analytical methods and tech transfer plans that pass early scrutiny often collapse under commercial-scale expectations, requiring CMC rigor to be treated as front-line regulatory strategy.
- The FDA's heightened scrutiny reflects evolving standards for biologics and advanced therapies, demanding robust manufacturing control strategies and comprehensive CMC data to ensure consistency, safety, and efficacy.
Capricor Inc.
Posted 4/4/2018
Replimune Inc.
Posted 9/20/2017