Human cell and gene therapy (CGT) products are manufactured and controlled within the existing regulatory framework for biological products. They can be affected by factors such as limited knowledge of product quality attributes, lack of manufacturing experience, limited and variable starting materials, low amount of product, complex manufacturing processes and limited product shelf-life. These aspects can make managing manufacturing changes more difficult than for other biological products.
This complexity poses a major challenge. The FDA therefore published a draft guidance in August 2023 to provide recommendations to both Investigational New Drug Applicants (INDs) and Biologics License Applicants (BLAs) on how to compare products and manage manufacturing changes for investigational and licensed CGT products.