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ARTICLE · 05 NOVEMBER 2025

Streamlining The Studies: New FDA Guidance Aims To Speed Up Biosimilar Development

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On Wednesday, the FDA issued a new draft guidance proposing to reduce the need for sponsors to conduct a comparative efficacy study (CES) to demonstrate biosimilarity...

United StatesIntellectual Property

On Wednesday, the FDA issued a new draft guidance proposing to reduce the need for sponsors to conduct a comparative efficacy study (CES) to demonstrate biosimilarity in an abbreviated biologics license application (aBLA). This approach could significantly lower the cost of bringing biosimilars to market.

Though promising, there remains uncertainty about how the FDA will apply its new policy. Whether a CES will be required is largely a product-specific determination that will require engagement with the Agency early in development. In addition, what types of immunogenicity studies that the FDA may require is an open question. For example, the FDA could demand a full switching study which is costly, time-consuming, and generally used to obtain an interchangeable designation. Manufacturers will have to engage the FDA early to clarify whether a CES may not be required for a particular product and, if so, whether that would represent a real saving in terms of time and

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