Summary Basis of Decision for Rymti

Review decision

The Summary Basis of Decision explains why the product was approved for sale in Canada. The document includes regulatory, safety, effectiveness and quality (in terms of chemistry and manufacturing) considerations.


Product type:

Drug

Summary Basis of Decision (SBD) documents provide information related to the original authorization of a product. The SBD for Rymti is located below.

Recent Activity for Rymti

SBDs written for eligible drugs approved after September 1, 2012 will be updated to include post-authorization information. This information will be compiled in a Post-Authorization Activity Table (PAAT). The PAAT will include brief summaries of activities such as submissions for new uses of the product, and whether Health Canada's decisions were negative or positive. PAATs will be updated regularly with post-authorization activity throughout the product's life cycle.

Summary Basis of Decision (SBD) for Rymti

Date SBD issued: 2023-02-03

The following information relates to the new drug submission for Rymti.

Etanercept

Drug Identification Number (DIN):

  • DIN 02530287 - 25 mg/0.5 mL etanercept, solution, subcutaneous injection, pre-filled syringe
  • DIN 02530295 - 50 mg/mL etanercept, solution, subcutaneous injection, pre-filled syringe
  • DIN 02530309 - 50 mg/mL etanercept; solution, subcutaneous injection, pre-filled auto-injector pen

Lupin Pharma Canada Ltd.

New Drug Submission Control Number: 234562

On August 31, 2022, Health Canada issued a Notice of Compliance (NOC) to Lupin Pharma Canada Limited for Rymti, a biosimilar to Enbrel (the reference biologic drug). The terms "biosimilar biologic drug" and "biosimilar" are used by Health Canada to describe subsequent entry versions of a Canadian approved innovator biologic drug with demonstrated similarity to a reference biologic drug. Biosimilars were previously referred to as subsequent entry biologics in Canada. Rymti contains the medicinal ingredient etanercept, which has been demonstrated to be highly similar to etanercept contained in the reference biologic drug Enbrel.

Authorization of a biosimilar means that it is highly similar to the reference biologic drug in terms of quality and that there are no clinically meaningful differences in efficacy and safety between the two products. To be considered a biosimilar, the weight of evidence is provided by the structural and functional studies; the non-clinical and clinical programs are designed to address potential areas of residual uncertainty. A final determination of similarity is based on the entire submission, including data derived from comparative structural, functional, non-clinical, pharmacokinetic and pharmacodynamic, and clinical studies.

The demonstration of similarity between the biosimilar and its reference biologic drug enables the sponsor's submission for the biosimilar to rely on the safety and efficacy information of the reference biologic drug in the indications being sought.

For more information on the authorization of biosimilars, refer to the Health Canada website on Biosimilar Biologic Drugs.

In this drug submission, Enbrel is the reference biologic drug. Similarity between Rymti and Enbrel was established in accordance with the Information and Submission Requirements for Biosimilar Biologic Drugs Guidance Document. Within this drug submission, the sponsor requested the authorization of Rymti for all of the indications that are currently authorized for Enbrel.

The market authorization was based on the quality (chemistry and manufacturing) package submitted, as well as demonstrated similarity between the biosimilar and the reference biologic drug. Similarity was established through data derived from comparative structural, functional, non-clinical, and clinical studies. Based on Health Canada’s review, the benefit-risk profile of Rymti is considered to be similar to the benefit-risk profile of the reference biologic drug, and therefore is authorized for the following indications:

  • Treatment of moderately to severely active rheumatoid arthritis (RA) in adults. Treatment is effective in reducing the signs and symptoms of RA, inducing major clinical response, inhibiting the progression of structural damage, and improving physical function. Rymti can be initiated in combination with methotrexate (MTX) in adult patients or used alone.
  • Reducing signs and symptoms of moderately to severely active polyarticular juvenile idiopathic arthritis (JIA) in patients aged 4 to 17 years who have had an inadequate response to one or more disease-modifying antirheumatic drugs (DMARDs). Efficacy and safety have not been established in children less than 4 years of age.
  • Reducing signs and symptoms, inhibiting the progression of structural damage of active arthritis, and improving physical function in adult patients with psoriatic arthritis (PsA). Rymti can be used in combination with methotrexate in adult patients who do not respond adequately to methotrexate alone.
  • Reducing signs and symptoms of active ankylosing spondylitis (AS).
  • Treatment of adult patients with chronic moderate to severe plaque psoriasis (PsO) who are candidates for systemic therapy or phototherapy.
  • Treatment of pediatric patients ages 4 to 17 years with chronic severe PsO who are candidates for systemic therapy or phototherapy. Data on safety and efficacy are limited in the age group 4 to 6 years.

1 What was approved?

Rymti, a biological response modifier, was authorized for the following indications:

  • Treatment of moderately to severely active rheumatoid arthritis (RA) in adults. Treatment is effective in reducing the signs and symptoms of RA, inducing major clinical response, inhibiting the progression of structural damage, and improving physical function. Rymti can be initiated in combination with methotrexate (MTX) in adult patients or used alone.
  • Reducing signs and symptoms of moderately to severely active polyarticular juvenile idiopathic arthritis (JIA) in patients aged 4 to 17 years who have had an inadequate response to one or more disease-modifying antirheumatic drugs (DMARDs). Efficacy and safety have not been established in children less than 4 years of age.
  • Reducing signs and symptoms, inhibiting the progression of structural damage of active arthritis, and improving physical function in adult patients with psoriatic arthritis (PsA). Rymti can be used in combination with methotrexate in adult patients who do not respond adequately to methotrexate alone.
  • Reducing signs and symptoms of active ankylosing spondylitis (AS).
  • Treatment of adult patients with chronic moderate to severe plaque psoriasis (PsO) who are candidates for systemic therapy or phototherapy.
  • Treatment of pediatric patients ages 4 to 17 years with chronic severe PsO who are candidates for systemic therapy or phototherapy. Data on safety and efficacy are limited in the age group 4 to 6 years.

Rymti is a biosimilar to Enbrel. Both drugs contain the medicinal ingredient etanercept. Improvement may be seen as early as 1 week after initial administration of etanercept in adults, and within 2 weeks in children with JIA and within 4 weeks in children with PsO. Attainment of full effect was usually seen by 3 months in both populations and remained durable thereafter with continued treatment with etanercept. Some patients see continuing improvement after 3 months of treatment with etanercept.

After discontinuation of etanercept, symptoms of arthritis generally returned within a month. Reintroduction of treatment with etanercept in adults after discontinuation of up to 18 months resulted in the same magnitudes of response as patients who received etanercept without interruption of therapy based on results of open-label studies. Reintroduction of etanercept to children with JIA after discontinuation up to 4 months also resulted in a subsequent response to therapy.

The clinical efficacy and safety of etanercept have not been established in children less than 4 years of age.

Rymti is indicated in the treatment of polyarticular JIA in patients 4 to 17 years of age who have had an inadequate response to one or more DMARDs, and in patients 4 to 17 years of age with chronic PsO who are candidates for systemic therapy or phototherapy. Data on the safety and efficacy in patients with PsO are limited in the age group of 4 to 6 years.

Only pediatric patients weighing 63 kg (138 pounds) or more, who do not require weight-based dosing, can be treated with Rymti 50 mg prefilled syringes or 50 mg auto-injector pens. Patients weighing less than 63 kg should be accurately dosed on a mg/kg basis with other etanercept products.

In clinical studies, 480 patients with RA were 65 years of age or older. No overall differences in safety or effectiveness were observed between these patients and younger patients.

In clinical studies, 138 patients with PsO were 65 years of age or older. No overall differences in effectiveness were observed between younger and older patients with psoriasis. Because there is greater sensitivity and predisposition of older individuals to infection, caution should be used in treating the elderly.

Rymti is contraindicated in:

  • Patients who are hypersensitive to this drug or to any ingredient in the formulation, including any non-medicinal ingredient, or component of the container.
  • Patients with, or at risk of, sepsis syndrome, such as immunocompromised and human immunodeficiency virus (HIV)-positive patients.

Similarity between Rymti and Enbrel has been established on the basis of structural, functional, non-clinical, and clinical pharmacokinetic, efficacy, and safety comparisons, in accordance with the Information and Submission Requirements for Biosimilar Biologic Drugs Guidance Document.

Rymti (50 mg/mL etanercept) is presented as a solution for injection in either a pre-filled syringe or pre-filled auto-injector pen. In addition to the medicinal ingredient, the solution contains glycine, sucrose, sodium chloride, sodium dihydrogen phosphate dihydrate, trisodium citrate dihydrate, and water for injection.

The drug product was approved for use under the conditions stated in its Product Monograph taking into consideration the potential risks associated with its administration. The Rymti Product Monograph is available through the Drug Product Database.

For more information about the rationale for Health Canada's decision, refer to the Quality (Chemistry and Manufacturing), Non-clinical, and Clinical Basis for Decision sections.

2 Why was Rymti approved?

Based on Health Canada's review, the benefit‑risk profile of Rymti is considered to be similar to that of the reference biologic drug. It is indicated for the treatment of rheumatoid arthritis, psoriatic arthritis, ankylosing spondylitis, juvenile idiopathic arthritis, and plaque psoriasis in adult and pediatric patients.

Rymti is considered to be biosimilar to Enbrel. Similarity between Rymti and Enbrel was established in accordance with the Information and Submission Requirements for Biosimilar Biologic Drugs Guidance Document. Enbrel is authorized and marketed in Canada for several indications and clinical uses. The specific diseases for which Enbrel is authorized are rheumatoid arthritis, psoriatic arthritis, ankylosing spondylitis, juvenile idiopathic arthritis, and plaque psoriasis in adult and pediatric patients. The New Drug Submission (NDS) filed for Rymti requested authorization for all of the indications and clinical uses that are currently authorized for Enbrel. The indications have been authorized on the basis of demonstrated similarity between Rymti and the reference biologic drug.

The primary mechanism of action of etanercept, the medicinal ingredient in Rymti, in inflammatory conditions is based on the competitive inhibition of tumour necrosis factor (TNF) alpha (TNF‑α). Produced by activated macrophages and T cells, TNF is a naturally occurring cytokine. Elevation of this cytokine has been observed in patients with a variety of inflammatory conditions such as rheumatoid arthritis, psoriatic arthritis, ankylosing spondylitis, and plaque psoriasis in adults and pediatric patients. The efficacious response of etanercept has been demonstrated in these conditions and has established the favourable benefit-risk profile leading to authorization of Rymti for the treatment of rheumatoid arthritis, psoriatic arthritis, ankylosing spondylitis, juvenile idiopathic arthritis, and plaque psoriasis in adult and pediatric patients aged 4 to 17 years.

Pharmacokinetic similarity between Rymti and Enbrel was supported by a Phase I comparative bioavailability study conducted in healthy male volunteers. Each subject received two 50 mg subcutaneous injections of either Rymti or Enbrel 28 days apart. Serum samples were collected up to Day 20 and a non-compartmental analysis method was used to estimate pharmacokinetic parameters. The study demonstrated pharmacokinetic comparability between Rymti and Enbrel; the point estimate for the Rymti and Enbrel geometric least square mean ratio for the maximum concentration and the 90% confidence intervals (CI) for the area under the concentration versus time curve to the time of the last quantifiable concentration were within the prespecified comparability margins of 80.0% to 125.0%.

The confirmatory clinical study was a Phase III, randomized, active-controlled, double-blind, multicentre study designed to evaluate the comparative efficacy, safety and immunogenicity of Rymti and Enbrel in adults aged 18 to 75 years with diagnosed rheumatoid arthritis according to the American College of Rheumatology (ACR) classification criteria.

The primary endpoint to support efficacy was the proportion of patients that achieved a 20% reduction in the ACR score (ACR20) at Week 24. At Week 24, the proportion of patients achieving an ACR20 response was comparable between Rymti and Enbrel treatment groups (81.3% and 87.1% respectively). The results of the study demonstrated a difference of ‑5.8% (95% CI: ‑11.8, 0.2), which was found to fall within the predefined equivalence margin of (‑15%, 15%).

The study also supported a comparable safety and immunogenicity profile between Rymti and Enbrel, which was consistent with historical information for the reference biologic product. For the primary assessment period (at Week 24), there was at least one treatment emergent adverse event (TEAE), experienced by 316 (60.3%) patients in the study; 146 (55.3%) patients in the Rymti group and 170 (65.4%) patients in the Enbrel group. The most frequently reported TEAEs overall were nasopharyngitis (56 [10.7%]), injection site reaction (45 [8.6%]), injection site erythema (30 [5.7%]), abnormal hepatic function (17 [3.3%]), rheumatoid arthritis (12 [2.3%]), and headache (12 [2.3%]). There were no deaths reported in the study and no new safety signals were identified. The reported incidence and impact of immunogenicity was comparable with a numerically lower incidence of anti-drug antibodies in the Rymti group that was not clinically meaningful.

The totality of evidence, including structural, functional, non-clinical, clinical pharmacokinetic, and clinical efficacy and safety comparisons, provide adequate evidence to establish clinical biosimilarity between Rymti and the Canadian reference biologic drug.

Appropriate warnings and precautions are in place in the approved Rymti Product Monograph to address the identified safety concerns, as is found in the Product Monograph for Enbrel, including a Serious Warnings and Precautions box describing the risk of serious infections and malignancies.

A Risk Management Plan (RMP) for Rymti was submitted by Lupin Pharma Canada Limited to Health Canada. The RMP is designed to describe known and potential safety issues, to present the monitoring scheme and when needed, to describe measures that will be put in place to minimize risks associated with the product. Upon review, the RMP was considered to be acceptable.

The submitted inner and outer labels, package insert and Patient Medication Information section of the Rymti Product Monograph meet the necessary regulatory labelling, plain language, and design element requirements. The sponsor submitted a brand name assessment that included testing for look‑alike sound‑alike attributes. Upon review, the proposed name Rymti was accepted.

Overall, Rymti demonstrated a comparable benefit/risk profile for the treatment of rheumatoid arthritis to the Canadian reference biologic drug Enbrel. Based on the sponsor’s rationale and scientific justification, this favourable profile is extended to other indications that are authorized for the Canadian reference product, in line with relevant guidelines. Overall, the benefit/risk profile of Rymti is considered to be favourable for the authorized indications.

This New Drug Submission complies with the requirements of sections C.08.002 and C.08.005.1 and therefore Health Canada has granted the Notice of Compliance pursuant to section C.08.004 of the Food and Drug Regulations. For more information, refer to the Quality (Chemistry and Manufacturing), Non-clinical, and Clinical Basis for Decision sections.

3 What steps led to the approval of Rymti?

A Notice of Deficiency (NOD) was initially issued for the New Drug Submission (NDS) for Rymti on December 4, 2020. During the initial Quality review of the submission, major gaps were identified in terms of reflecting recent revisions to the manufacturing processes. Two additional major objections and several minor concerns were issued as part of the NOD. The sponsor provided adequate responses to all of the quality objections/issues. Following a comprehensive review of the entire dossier, a Notice of Compliance was recommended.

The review of the quality component of the NDS for Rymti was based on a critical assessment of the data package submitted to Health Canada. The review completed by the European Medicines Agency was used as an added reference, as per Method 3 described in the Draft Guidance Document: The Use of Foreign Reviews by Health Canada. The Canadian regulatory decision on the NDS for Rymti was made independently based on the Canadian review.

For additional information about the drug submission process, refer to the Management of Drug Submissions and Applications Guidance

Submission Milestones: Rymti

Submission MilestoneDate
Pre-submission meeting2018-03-28
New Drug Submission filed2019-12-19
Screening
Screening Acceptance Letter issued2020-02-10
Review 1
Labelling review inactive2020-09-09
Non-clinical evaluation inactive2020-09-10
Quality evaluation completed2020-09-10
Review of Risk Management Plan inactive2020-09-18
Clinical/medical evaluation inactive2020-12-04
Notice of Deficiency issued by Director General, Biologic and Radiopharmaceutical Drugs Directorate (quality issues)2020-12-04
Response to Notice of Deficiency filed:2021-10-20
Screening of Response to Notice of Deficiency (Screening 1)
Screening Acceptance Letter issued2021-11-04
Review of Response to Notice of Deficiency (Review 1)
Review of Risk Management Plan completed2022-07-29
Quality evaluation completed2022-08-24
Non-clinical evaluation completed2022-08-24
Clinical/medical evaluation completed2022-08-26
Labelling review completed2022-08-29
Notice of Compliance issued by Director General, Biologic and Radiopharmaceutical Drugs Directorate2022-08-31

4 What follow-up measures will the company take?

Requirements for post-market commitments are outlined in the Food and Drugs Act and Regulations.

The onus is on the Rymti sponsor to monitor the post-market safety profile of this biosimilar as well as the Product Monograph of the reference biologic drug for safety signals that could impact the biosimilar, and make safety updates to the Rymti Product Monograph as appropriate. New safety issues that are first identified with the biosimilar, the reference biologic drug, or other biologics that share a common medicinal ingredient may or may not have relevance to both the biosimilar and the reference biologic drug. For more information, refer to the Fact Sheet: Biosimilars.

6 What other information is available about drugs?

Up-to-date information on drug products can be found at the following links:

7 What was the scientific rationale for Health Canada's decision?
7.1 Quality Basis for Decision

As described above, the review of the quality component of the New Drug Submission (NDS) for Rymti was conducted as per Method 3 described in the Draft Guidance Document: The Use of Foreign Reviews by Health Canada.

Rymti was developed as a biosimilar to the reference biologic drug, Enbrel. For biosimilars, the weight of evidence is provided by structural and functional studies. Biosimilars are manufactured to the same regulatory standards as other biologic drugs. In addition to a typical chemistry and manufacturing data package that is submitted for a standard new biologic drug, biosimilar submissions include extensive data demonstrating similarity with the reference biologic drug.

The biological activity of Rymti is considered to be representative of the mechanism of action and pharmacological effect of Enbrel.

A Notice of Deficiency (NOD) was initially issued for the NDS on December 4, 2020. During the initial review of the submission, major gaps were identified regarding accuracy in terms of reflecting recent revisions to manufacturing processes. Two additional major objections and several minor concerns were issued as part of the NOD. The sponsor provided adequate responses to all of the quality objections/issues. Following a thorough review of the entire dossier, a Notice of Compliance (NOC) was recommended from a quality perspective.

Comparative Structural and Functional Studies

The sponsor has declared Enbrel sourced from the European Union (EU‑Enbrel) as a proxy for the Canadian reference biologic drug, Enbrel. Enbrel sourced from the EU is considered a suitable proxy as it meets the requirements outlined in the Information and Submission Requirements for Biosimilar Biologic Drugs Guidance Document.

Rymti was found to be identical to Enbrel in terms of primary structure, and highly similar with regards to higher order structure, functional activity, and drug product attributes. Differences were observed with respect to product-related impurities, glycosylation, and antibody-dependent cell-mediated cytotoxicity. However, these differences have no impact on the biological activity and mode of action of Rymti, and are unlikely to be clinically meaningful. Comparative stability and forced degradation studies using different stress conditions generated similar degradation profiles for Rymti and EU‑Enbrel, further supporting the similarity assessment. Together, these results support the assertion that Rymti is similar to EU‑Enbrel, and support the quality requirements for Rymti to be considered a biosimilar to the Canadian reference biologic drug.

Characterization of the Drug Substance

The drug substance, etanercept, is a fully human recombinant dimer protein consisting of two soluble75 kilodalton (p75) tumor necrosis factor (TNF) receptor molecules fused to the Fc fragment of human immunoglobulin G1 (IgG1). The mechanism of action of etanercept is the inhibition of TNF activity. Etanercept reduces inflammation by competitively inhibiting the binding of tumour necrosis factor (TNF) alpha (TNF‑α) and lymphotoxin α to TNF receptors on the cell surface, and thus rendering TNF molecules biologically inactive. The Fc region of IgG as a fusion element of etanercept prolongs its serum half-life. Critical attributes are highly related with TNF binding and the corresponding neutralization effect, but the effector functions associated with the Fc domain in general are not considered to be critical attributes of etanercept.

Detailed characterization studies were performed to provide assurance that etanercept consistently exhibits the desired characteristic structure and biological activity. The structure, functional activity, and other characteristics were delineated during the biosimilarity assessment described above.

Manufacturing Process of the Drug Substance and Drug Product and Process Controls

The drug substance is expressed in Chinese hamster ovary cells in a production bioreactor. The resulting culture is harvested and purified using a series of chromatography steps. Viral inactivation and nanofiltration steps ensure viral safety. Excipients are added prior to final drug substance filtration. Finally, the drug substance is filtered into glass bottles and stored at 2 ºC to 8 ºC for up to 24 months. The shelf life is supported by stability data provided in the submission.

The manufacturing process of the drug product begins with individual bottles of drug substance being pooled and mixed, bioburden reduction filtered, and sterile filtered. The sterile solution is then aseptically filled into 1 mL glass syringes using an automated filling machine. Two strengths are filled into the prefilled syringes: 25 mg/0.5 mL and 50 mg/1.0 mL. The 50 mg/1.0 mL strength also has the option of being equipped with an autoinjector device. Prefilled syringes are stoppered and 100% visually inspected. Finally, labelling and secondary packaging are performed.

Process validation batches and lots were manufactured at the intended commercial scales and manufacturing sites. Process performance qualification data demonstrated that the manufacturing processes are capable of consistently manufacturing Rymti drug substance and drug product of acceptable quality. All process parameters, in-process controls and tests, process attributes, release testing results, and stability results met pre-defined criteria, acceptance limits, and specifications for all validation batches and lots.

None of the non-medicinal ingredients (excipients, described earlier) found in the drug product are prohibited by the Food and Drug Regulations. The compatibility of the medicinal ingredient with the excipients is supported by the stability data provided.

Control of the Drug Substance and Drug Product

The drug substance and drug product manufacturing process is controlled by process parameters, in-process controls, and in-process tests with defined operating ranges, action limits, and acceptance criteria. Criticality of each of these was appropriately defined, and were based on risk assessments, process characterisation studies, and previous experience gained during development. Any results outside of specified ranges or limits results in the opening of a deviation, with subsequent investigation. The deviation and investigation process was thoroughly reviewed during the virtual site evaluation of the manufacturing facility.

Concerns were raised during the review of the submission regarding the level of detail in the written standard operating procedures for quality control testing of the drug substance and drug product. These concerns were adequately addressed during the review process, and consistent method performance and quality control will be managed and mitigated through Health Canada's Lot Release Program as per the Guidance for Sponsors: Lot Release Program for Schedule D (Biologic) Drugs.

Stability of the Drug Substance and Drug Product

Based on the stability data submitted, the proposed shelf life and storage conditions for the drug substance and drug product were adequately supported and are considered to be satisfactory. The proposed shelf life of 24 months when stored at 2 ºC to 8 ºC for Rymti is considered acceptable.

The compatibility of the drug product with the container closure system was demonstrated through compendial testing and stability studies. The container closure system met all validation test acceptance criteria.

Facilities and Equipment

The design, operations, and controls of the facility and equipment that are involved in production are considered suitable for the activities and products manufactured.

Due to ongoing travel restrictions related to the COVID‑19 pandemic, a virtual site evaluation (VSE) of the facilities involved in the manufacture and testing of the drug substance and drug product was conducted by Health Canada in lieu of an on-site evaluation. Information obtained through the VSE supports the issuance of an NOC.

Adventitious Agents Safety Evaluation

The drug product manufacturing process incorporates adequate control measures to prevent contamination and maintain microbial control. Pre-harvest culture fluid from each lot is tested to ensure freedom from adventitious microorganisms (bioburden, mycoplasma, and viruses) and appropriate limits are set. Purification process steps designed to remove and inactivate viruses are adequately validated.

Raw materials of biological origin used in the manufacturing process are adequately tested to ensure freedom from adventitious agents. The excipients used in the final product formulation are not of animal or human origin.

7.2 Non-Clinical Basis for Decision

For biosimilars, the degree of similarity at the quality level determines the scope and the breadth of the required non-clinical data. Non-clinical studies serve to complement the structural and functional studies and address potential areas of residual uncertainty.

In a comparative in vivo study conducted in a collagen-induced mouse model of arthritis, Rymti etanercept (YLB113) or reference etanercept sourced from India was administered to males at doses of 0.1, 1, 10, or 50 mcg by intraperitoneal injection once per day for 14 days. The reference etanercept and YLB113 showed similar efficacy in reducing arthritic scores, paw swelling, and/or joint inflammation/damage when compared to arthritic mice given placebo (phosphate buffered saline).

In the pivotal comparative repeat-dose toxicity study conducted in cynomolgus monkeys, YLB113 or reference etanercept sourced from Japan was administered at doses of 1, 5, or 15 mg/kg by subcutaneous injection twice per week for 4 weeks. Monkeys administered YLB113 did not develop any unique toxicity when compared to monkeys administered reference etanercept.

The non-clinical database submitted for Rymti was in compliance with the requirements for non-clinical studies of biosimilars, as presented in the Information and Submission Requirements for Biosimilar Biologic Drugs Guidance Document.

For more information, refer to the Rymti Product Monograph, approved by Health Canada and available through the Drug Product Database.

7.3 Clinical basis for decision

The purpose of the clinical program for a biosimilar is to demonstrate that there are no clinically meaningful differences between the biosimilar and the reference biologic drug. The structural complexity of the biologic drug and availability of a relevant and sensitive pharmacodynamic endpoint determine the scope and the breadth of the required clinical data. The clinical program is designed to complement the structural and functional studies and address potential areas of residual uncertainty.

The submission included a Phase I comparative pharmacokinetic study in healthy volunteers and a Phase III comparative efficacy study in patients with active rheumatoid arthritis. The sponsor’s approach to supporting a lack of clinically meaningful difference involved demonstrating comparative biopharmaceutics as well as the safety, efficacy, and immunogenicity of Rymti compared to the reference biologic drug.

Comparative Pharmacokinetic and Pharmacodynamic Studies

Etanercept, the medicinal ingredient in Rymti, binds specifically to soluble and cell surface tumour necrosis factor (TNF) and blocks its interaction with cell surface TNF receptors. Etanercept inactivates TNF without causing in vitro lysis of cells involved in the immune response. Tumour necrosis factor is a naturally occurring cytokine, or immune system protein, that is implicated in the development and progression of inflammatory, infectious, and autoimmune diseases. It plays an important role in the inflammatory processes of rheumatoid arthritis, polyarticular juvenile idiopathic arthritis, ankylosing spondylitis, and the resulting joint pathology. In addition, TNF plays an important role in the inflammatory process of plaque psoriasis and resulting skin pathology. Elevated levels of TNF are found in the synovial fluid of patients with rheumatoid arthritis, in both the synovium and psoriatic plaques of patients with psoriatic arthritis and plaque psoriasis, and in serum and synovial tissue of patients with ankylosing spondylitis. In plaque psoriasis, infiltration by inflammatory cells including T cells leads to increased TNF levels in psoriatic lesions, compared with levels in uninvolved skin.

Two distinct receptors for TNF, a 55 kilodalton protein (p55) and a 75 kilodalton protein (p75), exist naturally as monomeric molecules on cell surfaces and in soluble forms. Biological activity of TNF is dependent upon binding to either cell surface TNF receptor. Etanercept is a dimeric soluble form of the p75 TNF receptor that can bind to two TNF molecules. This dimeric binding provides substantially greater competitive inhibition of TNF than monomeric soluble receptors. Much of the joint pathology in rheumatoid arthritis is mediated by proinflammatory molecules that are linked in a network controlled by TNF. Etanercept competitively inhibits binding of both TNF alpha (TNF‑α) and lymphotoxin α to cell surface TNF receptors, rendering TNF biologically inactive. Etanercept does not cause lysis of TNF-producing cells in vitro, in the presence or absence of complement.

Study ETA.50/334 was a Phase I, randomized, open-label, active-controlled, single dose crossover study evaluating the pharmacokinetics of Rymti or Enbrel sourced from the European Union (EU‑Enbrel) in healthy male volunteers. The primary objective of this study was to compare the relative bioavailability of Rymti and EU‑Enbrel. Each subject received two 50 mg subcutaneous injections of either Rymti or EU‑Enbrel 28 days apart.

Serum samples were collected up to Day 20 and a non-compartmental analysis method was used to estimate pharmacokinetic parameters. The study demonstrated pharmacokinetic comparability between Rymti and EU‑Enbrel; the point estimate for the Rymti and EU‑Enbrel geometric least square mean ratio for the maximum concentration and the 90% confidence intervals (CI) for the area under the concentration versus time curve to the time of the last quantifiable concentration were within the prespecified comparability margins of 80.0% to 125.0%.

For further details, please refer to the Rymti Product Monograph, approved by Health Canada and available through the Drug Product Database.

Comparable Clinical Efficacy, Safety, and Immunogenicity

Study YLB113-002 was a Phase III, randomized, double-blind, active controlled study that was conducted to compare the efficacy, safety, and immunogenicity of 50 mg/mL of Rymti or Enbrel, administered once a week as a subcutaneous injection in patients with active moderate to severe rheumatoid arthritis despite methotrexate therapy. The primary comparison was performed at Week 24 of treatment with additional safety and immunogenicity data presented up to Week 52. The study randomized 524 patients to Rymti or Enbrel in a 1:1 ratio, with 497 patients included in the primary analysis population.

The study included male and female patients aged 18 to 75 years with diagnosed rheumatoid arthritis according to the American College of Rheumatology (ACR) classification criteria. For the primary analysis time point at Week 24, the median age of patients was 53.0 years. Overall, the majority of the patients were female (409 [78.1%]). The mean weight was 66.1 (±16.30) kg with the mean body mass index of 24.9 (±5.18) kg/m2. Approximately half of the patients were randomized in Japan (49.8%) and the rest were randomized in Europe (44.1%) and India (6.1%). Baseline characteristics were comparable across treatment groups.

The primary endpoint was the proportion of patients that achieved a 20% reduction in the ACR score (ACR20) at Week 24. The response rate of Rymti and Enbrel from baseline was compared at Week 24 with a predefined equivalence margin of (‑15%, 15%). The objective of the study would be met if the two-sided 95% CI of the difference between the ACR20 responses at Week 24 fell entirely within the equivalence margin.

The study met its primary objective. At Week 24, the proportion of patients achieving an ACR20 response in the Rymti and Enbrel groups was 81.3% and 87.1%, respectively. The results of the study demonstrated a difference of ‑5.8% (95% CI [‑11.8, 0.2]), which was found to fall within the predefined equivalence margin of (‑15%, 15%). Secondary endpoints, ACR50 and ACR70 response rates at additional time points, supported the comparability of Rymti and Enbrel. Sensitivity analyses supported the primary analysis. These responses were comparable up to Week 52.

For the primary assessment period (Week 24), there was at least one treatment emergent adverse event (TEAE), experienced by 316 (60.3%) patients in the Rymti (146 [55.3%]) and Enbrel (170 [65.4%]) groups. The most frequently reported TEAEs overall were nasopharyngitis (56 [10.7%]), injection site reaction (45 [8.6%]), injection site erythema (30 [5.7%]), abnormal hepatic function (17 [3.3%]), rheumatoid arthritis (12 [2.3%]), and headache (12 [2.3%]). There were no deaths reported in the study and no new safety signals were identified. The reported incidence and impact of immunogenicity was comparable, with a numerically lower incidence of anti-drug antibodies in the Rymti group that was not clinically meaningful. Overall, the safety and immunogenicity profile of Rymti was comparable with that of Enbrel and was consistent with clinical studies carried out for the reference biologic drug.

Overall, Rymti demonstrated a comparable benefit/risk profile for the treatment of rheumatoid arthritis to the Canadian reference biologic drug, Enbrel. Based on the sponsor’s rationale and scientific justification, this favourable profile is extended to other indications that are authorized for the Canadian reference product, in line with relevant guidelines. Overall, the benefit/risk profile of Rymti is considered to be favourable for the authorized indications.

Appropriate warnings and precautions are in place in the approved Rymti Product Monograph to address the identified safety concerns, as is found in the Product Monograph for Enbrel, including a Serious Warnings and Precautions box describing the risk of serious infections and malignancies.

For more information, refer to the Rymti Product Monograph, approved by Health Canada and available through the Drug Product Database.

Indications

Rymti is considered to be biosimilar to Enbrel, the reference biologic drug. Enbrel is authorized and marketed in Canada for several indications and clinical uses. The specific diseases for which Enbrel is authorized are rheumatoid arthritis, psoriatic arthritis, ankylosing spondylitis, juvenile idiopathic arthritis, and plaque psoriasis in adult and pediatric patients.

Within this drug submission, the sponsor requested the authorization of Rymti for all of the indications that are currently authorized for Enbrel.

Similarity between Rymti and Enbrel was established in accordance with the Information and Submission Requirements for Biosimilar Biologic Drugs Guidance Document. The demonstration of similarity between the biosimilar and its reference biologic drug enables the sponsor's submission for the biosimilar to rely on the safety and efficacy information of the reference biologic drug, and therefore clinical trials are not required to support each indication. The indications have been authorized on the basis of demonstrated similarity between Rymti and the reference biologic drug, in structural, functional, non-clinical, clinical pharmacokinetic, and clinical efficacy and safety comparisons.