Regulatory Open Forum

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  • 1.  Import/Export

    This message was posted by a user wishing to remain anonymous
    Posted 09-Nov-2020 15:54
    This message was posted by a user wishing to remain anonymous

    How does one import from the EU an API that has neither and NDA nor an IND in effect and will be used to produce clinical product in the USA for an IND in the USA?


  • 2.  RE: Import/Export

    Posted 20-Nov-2020 21:50
    The post doesn't describe if this is a small molecule or a biologic.  Assuming this is a small molecule, you may request an IND number from CDER that you can reference in the importation documentation.  Specify in the importation paperwork that this is a CDER IND number.  Use a reputable importer who understands the documentation required by FDA.  Also indicate that the API is not for clinical trial use and not for commercial sale.

    However, check with a reputable shipper/importer about the paperwork needed for importation.

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    Mark De Rosch FRAPS
    Chief Regulatory Officer, Epizyme, Inc.
    Laconia NH
    United States
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