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Regulatory Environment in the Middle Eastopportunities & challenges
Mamoona Firdous Naqvi
Dec16,2015
RAK Medical & Health sciences University
RAK College of Pharmaceutical Sciences
RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
Discussion points What is Regulatory Affairs and why it is needed
Approval pathway of new / Generic drug
Regulatory environment in major markets of the Middle East
Harmonization Initiatives in the region
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Julphar 6 2
Opportunities and Challenges
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What is Regulatory Affairs?Regulatory Affairs: It is a unique mix of science and management tofull fill medical need of patients and achieve a commercially important goal within a drug-development organization.
Touches everything relating to drugs from the earliest non-clinical studies, through development, into routine manufacture, registration of product , marketing and post marketing surveillance
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RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
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Regulatory Affairs
Regulatory Affairs
Medical
Business Developmen
t
Finance
PRODUCT DEVELOPMENT
MARKETING SALE
QUALITY CONTROL
QUALITY ASSURANCE
SUPPLY CHAIN AND PROCURME
NT
Medical Indication s, Labeling &packaging , pharmaco-vigilance
Build pipeline , fast track registration , early entry in
the market
Price
Regulatory Documents as per requirement
Business potential align with Regulatory Strategy Promotion of product
Regulatory Affairs Department Central Position in Industry
API import , export of FP
Validation/ Controls as per regulation
Stability Studies
Distribution practices
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Why is Regulatory Affairs Needed?• To put better control on Drug development and
commercialization
• The path to drug registration (Marketing Approval) is paved with good intention but can be complicated
• Things change....constantly!
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Role of Regulatory Affairs Pharmacist
• To keep track of the ever changing legislation
• Registration of company and product in respective markets
• Life Cycle management of product and company
• To file variation to Health Authorities • To give strategic and technical advice to
R&D, Production, QC and Quality assurance
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• Construction of core dossier • Global regulatory strategies • Core labelling profile • IND, CTA, NDA, MAA • Scientific advice • • Due-diligence/RI • Global SOPs • Pharmacovigilance • Medical • ePublishing • Global business development
• Country/Region specific data
• Product information• Local developments and specific variations • Local/regional RA strategies • Technical support, CTAs • Pharmacovigilance • Due-diligence/RI • Local SOPs• Medico-Marketing • ePublishing • Local business development
Corporate/ Central Regional /local
REGULATORY AFFAIRS PHARMACIST
Strategic Importance of Regulatory Affairs Pharmacist
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• Regulatory expertise required throughout the product lifecycle
• Identification of various regulatory options for drug development
• Optimizing and speeding “time-to-market”–• Engagement in manufacturing site optimization activities• Engagement in portfolio optimization activities• Engagement during Merger, Demerger & Divestment activities• Engagement in critical business functions
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COMPANY REGISTRATION & PRODUCT REGISTRATION
Requirement for registrationof Company
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Company registration prior to product registrationCompanies ( sites ) for conventional , general sale , medical devices and herbal should be registered by health authorities Approval time 3-6 months
EXAMPLE OF REQUESTED INFORMATIONApplication form of UAEGMP Letter of agency authorization Legalized company LicenseList of subsidiaries List of products produced by company List of countries where company is registered Research information Receipt of fees informationCompany profile List of associated manufacturing faculties
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PRODUCT REGISTRATION
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RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
Emerging Markets
ONE DOES FİT TO ALL
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NOT
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The Regulatory SubmissionBuilding the CTD Pyramid
Data
Summaries
Product information
Summary of ProductCharacteristics
Administrativeinformation
The Regulatory Submission
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COMPREHENSIVE TABLE OF CONTENTS (MODULE 1 – 5)Module 1 Administrative Information
1.1 Comprehensive tablet of contents 1.2 Application form 1.3 Product information 1.3.1 SPC, labelling and package leaflet 1.3.2 Mock up 1.3.3 Specimen 1.3.4 Consultation with target patient groups 1.3.5 Product information already approved in the member states 1.3.6 Braille 1.4 Information about the experts 1.4.1 Quality 1.4.2 Non-clinical 1.4.3 Clinical 1.5 Specific requirements for different types of applications 1.5.1 Information for bibliographical applications 1.5.2 Information for generic, ‘hybrid’ or bio-similar applications 1.5.3 (Extended) Data/market exclusivity 1.5.4 Exceptional circumstances 1.5.5 Conditional marketing authorization 1.6 Environmental risk assessment 1.6.1 Non-GMO 1.6.2 GMO 1.7 Information relating to orphan market exclusivity 1.7.1 Similarity 1.7.2 Market exclusivity 1.8 Information relating to pharmacovigilance 1.8.1 Pharmacovigilance system 1.8.2 Risk management system 1.9 Information relating to clinical trials
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Module 3 Drug Substance (DS)Section Title Functional Area3.1 Table of Contents
3.2 Body of Data
3.2.S Drug Substance
3.2.S.1 General Information DS Characterization
3.2.S.2 Manufacture DS Manufacture
3.2.S.3 Characterization DS Characterization
3.2.S.4 Control of Drug Substance Analytical
3.2.S.5 Reference Standard Analytical
3.2.S.6 Container Closure System DS Manufacture
3.2.S.7 Stability Stability
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Module 3 Drug Product (DP)Section Title Functional Area
3.2.P DRUG PRODUCT
3.2.P.1 Description & Composition DP Manufacture
3.2.P.2 Pharmaceutical Development DP Manufacture
3.2.P.3 Manufacture DP Manufacture
3.2.P.4 Control of Excipients Analytical
3.2.P.5 Control of Drug Product Analytical
3.2.P.6 Reference Standard Analytical
3.2.P.7 Container Closure System DP Manufacture
3.2.P.8 Stability Stability
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Module 4 Non-clinical Study Reports
4.1. Table of Contents
4.2 Study Reports
4.3 Literature References
Module 5 Clinical Study Reports
5.1 Table of Contents
5.2 Tabular Listing of all Clinical Studies
5.3 Clinical Study Reports
5.4 Literature References
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eCTD
Julphar.net
Variations
Any change(s) to the information approved in the marketing authorization application
Health authority must be notified as per the variation regulations and procedures to ensure REGULATORY COMPLIANCE
In GCC, variations are governed by GCC Guidelines for Variation Requirements, adapted from Europe Regulation (EC) No. 1234/2008 Article 4(1)a
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Regulations in Middle East
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HealthCare
Health care USD $ 12 Billion market growth rate over 10 %74.6 % of pharmaceutical are on imports basisVery Vibrant domestic pharmaceutical markets e.g. . Iran, Egypt 90 % of consumption in Egypt based on local production vs. Saudia Arabia with 85 % pharmaceutical consumption being imported Healthcare has strong ties to the WEST Drug price controlled by Government Data exclusivity 5 years from date of MA
Pharmaceutical environment Young Population – will be doubled by 2030Government development plans in MENA REGIONNeed to develop hospitals and clinics Implementing insurance schemes Necessity for trained staffNeed to strengthen public surveillance system
CULTURE - Regional Trends
UNITED ARAB EMIRATES (UAE )
Area 83,6000 km and population is 4.8 million growth 3.7%85% of the labor force is expatriatesGDP US$ 201.4 bn GDP capita US $ 42,000UAE is spending US$ 2.9 bn on various healthcare projects Dubai and Abu Dhabi introduced universal health insurance models during 2008 Pharmaceutical markets – 65% private and 35 % Governmental tenders and institutions Market split : patented drugs 67.7 % Generic 14.6% , OTC 17.7%Health expenditure US $ bn 6.9
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China India MENA + Turkey
USA Brazil Russia0
200
400
600
800
1000
1200
1400
1338 1210
396.2 311 195 142
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Brazil Russia MENA + Turkey
China India02468
101214161820
10.8 10.57.7
4.41.3
10.4
Why MENA REGION ?
MENA contains 6.7% of the world's population, about the same as the population of the EU.
Turkey and MENA have the 4th largest population in the world.
The GDP per capita (MENA + Turkey) > $18K nearly double of Brazil and Russia.
The healthcare expenditure per capita in MENA has significant room for growth. (only US$ 183 in Y2009)
Source: IMF - PWC – World Bank
GDP per capital (US$)
Population MM
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MARKET COMPOSITION OF GCC
Your AssetYour Partner
Healthcare Regulations
Local Giants &
Competition
Complex & lengthy
registrations
Pricing Pressures
Tenders unified
purchasing
Loose IP
The environment in MENA
• Protectionist & nationalistic approach adopted by most of the countries- trend
of local protectionist laws favoring local manufacturing (Algeria, Egypt,
Tunisia, Morocco, Turkey )• Lengthy and bureaucratic marketing
authorization processes• Difficulty to find reliable and
successful partners• Potential for growth but fragmented
and competitive landscape with many local and multinational players
• Trend of local governments to decrease health costs (obligatory price decreases
in Saudi Arabia, reference pricing in Algeria, etc…) 29
The Common Themes
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Sciences
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Gulf Corporate Council of the Arab States (GCC )
Vision – Highly effective and safe use of medication to protect the Community health in Gulf states Mission – Establishing a unified registration system that ensures effectiveness, safety and quality of medicine Member states – Saudia Arabia, Kuwait , UAE Oman , Bahrain , Qatar and Yemen Main Office – Riyadh ( KSA )Meeting frequency – 4 meetings /year GCC – publish guideline regarding registration , GMP, Pharmacovigilance etc
Company registration – first step for new entries in GCC , registration fee is 2700 US $ Product registration – Format of dossier is CTD , administrative review by two members states , lab analysis - GCC registration Certificate issued , registration fee is 2450 US $
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Tender Business in the Middle East
SGH ( SECRETARIAT GENERAL OF HEALTH – TENDER )
• Unified purchase program establish in 1978 • Tender Volume – 1.5 bn US $• 424 International and local companies are accredited • Tender is presented annually and permanent committee evaluate the applications • Purchase - under control of WTO especially for the pharmaceutical medicine • Tender announced – end of March and closing date end of April • Preliminary award information – 2-3 weeks after closing date • Final award Information - 22-24 weeks after closing , within 45 days 5 % of awarded amount suppose to pay • 3 partial shipment in 4 months interval
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Regulations in Middle East
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Models for regulation of medicines are determined by:
• Public health needs• Organization of the state and state administration• Size of the pharmaceutical market• Presence and type of pharmaceutical industry• Availability of resources (human, scientific, financial)• Maturity of stakeholders• Participation in regulatory networks
Medicine Regulation
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The Regulatory Partners
PATIENTS
Government (HA)
Pharmaceutical Industries
Professional Bodies
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The Regulatory Guidelines
International
r
INTERNATIONAL GUIDELINES
REGIONAL GUIDELINES
LOCAL GUIDELINES
RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
UAE• The UAE’s drug market is dominated in value
terms by foreign MNCs.• Most major research-based firms have a long-
standing presence in the UAE, either via contract manufacturing or local distribution arrangements.
• The UAE does have a thriving biotech and domestic pharmaceutical industry, which the government is keen to boost. The authorities are, therefore, likely to alter their import policies, favoring local production where possible
• The Pharmaceutical & Medicine Control Dep. is the main pharmaceutical regulatory division within the MoH
• Products with US, EU or Japanese approval experience less difficulty in gaining access to the market.
• Asks for US FDA or EU manufacturing license to accept the importation & registration
• Fx rate on the pharmaceutical market; Dirham vs. Euro
Local Enviroment Regulatory Regime2011 Drug Market Size1:US$1,5 bn (AED 5,6bn)2016 Drug Market Size1:US$2,3 bn (AED 8,4bn)
CAGR 2011-20161: 8,5% (local currency & USD)Pharmaceutical Spend (2011)1: 0,4% of GDPPharma % of Health expen. (2011)1:12,3%Healthcare Spend (2011)1: 3,52% of GDP
By numbers
• One of the more developed markets in the Middle East, with a strong healthcare infrastructure and the highest per-capita drug expenditure in the region.
• Strong patented drug market, largely as a result of the country’s traditional wealth and a preference for the latest medicines.• Local manufacturing industry activity has increased notably over the past few years, with a strong focus on regional and global exports.• Increase in population numbers, including expatriates, feeding through to significantly higher healthcare expenditure.• Although improving, domestic patent law is below international standards.• Market is reliant on imports, in particular at the hi-tech end of the scale.• Disparate regulations between different parts of the Emirates, which are likely to be further complicated by the introduction of new
structures in Dubai.• Shake-up of the laws limiting foreign ownership is expected to boost investment.• Introduction of integrated healthcare insurance system.
1. BMI Pharmaceutical and Healthcare Report Q3 2012
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RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
UAEBiosimilar Update; Drivers vs. Resistors
Drivers UAE Biosimilar Industry
Resistors UAE Biosimilar Industry
- Highest per-capital spending for pharmaceuticals in the region
- Regionally fragmented healthcare system and insurance coverage, leading to an uneven access to healthcare services
- Loose IPR - Increasing generics usage
in Abu Dhabi in accordance to the basic insurance policies
- The UAE pharma market has retained a strong preference for originator, branded products
- Only considered if EMA or FDA approved
- No Biosimilar regulation yet
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Saudi31%
Algeria21%
Egypt21%
UAE10%
Morocco8%
Local/regional company
J&J
ROCHE
JULPHAR
BAYER
ABBOTT
ASTRAZENECA
SANOFI
MERCK & CO
PFIZER
NOVARTIS
GSK
21,426
25,534
27,377
27,765
29,635
39,447
43,458
59,100
62,957
72,398
77,954
Market dominated by MNCs
2011 Total sales in MENA (Public + Retail)
IMS 2011- USD ‘ MM
RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
KSA• 27 pharmaceutical manufacturing factories
currently operating in Saudi Arabia. Most are generic drug manufacturers, including TABUK, SPIMACO, al-Jazeera, Dar Al Dawa, Riyad Pharma.
• Imports continue to account for the bulk of total spending, although government support has the potential to stimulate export growth of local firms, as well as the local use of generic medicines.
• The market reliance on imports, particularly at the hi-tech end of the scale.
• All pharmaceutical companies to be registered (6-18 months for registration, registation renewal every five years)
• MoH and SFDA – transition period• Guidelines include the stipulation that drugs
launched in Saudi Arabia must have already been marketed in developed countries (US, UK)
• Products also have to be manufactured in the same plant as those destined for the US or UK
• Strict control over the pricing system – a significant deterrent to market access.
• 1st generic – 70% of originator price• Next – 90% of previously intr. generic
Local Enviroment Regulatory Regime
2011 Drug Market Size1:$4,46bn (SAR 16,70bn)2016 Drug Market Size1:$7,00bn (SAR 26,23bn)CAGR 2011-20161: 9,5% (local currency & USD)Pharmaceutical Spend (2011)1: 0,77% of GDPPharma % of Health expen. (2011)1: 21,23%Healthcare Spend (2011)1: 3,64% of GDP
By Numbers
The largest pharmaceutical market in the MENA region (over half of the total), with steady growth expectation and foreseeable future• Rapidly expanding population, with more diseases of ‘urbanization’ in evidence.• Rising government investment in the local drug industry.• Aaccelerating modernization and expansion of healthcare infrastructure and provision.• Complex nature of the domestic regulatory system restricting the entry of multinationals and drug makers from developing countries
such as India.• Market entry delays due to requirements for laboratory testing in the country.• Reference pricing to other markets negatively affecting price levels in Saudi Arabia.• Inadequate protection for patented pharmaceutical products.
1. BMI Pharmaceutical and Healthcare Report Q3 2012
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RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
JULPHAR
SANOFI
JAMJOOM
MERCK & CO
ABBOTT
TABUK
HIKMA
NOVARTIS
PFIZER
GSK
SPIMACO
70,569
83,210
87,461
88,306
97,508
113,738
114,204
126,591
150,392
200,007
213,883
KSABiosimilar Update; Drivers vs. Resistors
Drivers S.Arabia Biosimilar Industry
Resistors S.Arabia Biosimilar Industry
- Biosimilar* definition in place with Guidelines on Biosimilars version 1.1, Dec 2010
- Rising chronic disease burden
- Increasing generic usage as a result of the efforts of the Government to lower pharmaceutical costs
- Fluctuating oil prices affecting healthcare budgets
- COFO (subsequently developed country – US & EU- launch)
- The relative wealth of the population acts as a significant barrier to market expansion, as there is little demand for low cost drugs.
- Still very low generic drugs penetration (< 7.7% of the market by value)
- Reference pricing- Technology Transfer
expectation- In Government tenders,
preferences are normally granted to local or GCC-based companies
1. Saudi Arabia December 2010 Guidelines on Biosimilars version 1.1
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Saudi31%
Algeria21%
Egypt21%
UAE10%
Morocco8%
Both strong local and
MNC players
Local/regional company
2011 Total sales in MENA (Public + Retail)
IMS 2011- USD ‘ MM
RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
Egypt• Egypt has 212 pharmaceuticals factories,
with local product development focused on drug formulation rrather than research 61 with partnership and 18 foreign companies
• Well-established manufacturing industry comprised of many privately owned local companies, focusing on high-volume basic medicines.
• Local production of finished pharmaceuticals accounts for around 90% of domestic consumption, with imports limited to patented and difficult to manufacture products.
• Regulatory process is complex and many committee review process
• Lack of resources • Pricing could be an obstacle to launch a
product ---new pricing decree required list of product in 36 countries and Egypt price would be 10 % lowest price in the list
• New product should be registered and marketed for one year in reference country
• CAPA is Regulatory body in Egypt • CPP of Country of Origin is required to
submit the file • Lose IP
Local Enviroment Regulatory Regime
2011 Drug Market Size1:US$3,07bn (EGP 18,23bn)
2016 Drug Market Size1:US$5,51bn (EGP 31,97bn)
CAGR 2011-20161: 11,9% (local currency)
Pharmaceutical Spend (2011)1: 1,3% of GDP
Pharma % of Health expen. (2011)1:29,3%
Healthcare Spend (2011)1: 4,37% of GDP
Pharma per capita sales (2011)1 : US$37,1
By numbers
• .Egypt is the largest consumer of pharmaceuticals in the MENA region
• Egypt has 1969 private and governmental hospitals & 5034 primary health care units
• Egypt has a fragmented health system with multiple sources of financing and providers.
• Spending on pharmaceuticals is 34 % of total health care spending*.
• Share of out-of-pocket spending to total health spending has increased from 51 % to 72 %*.• The most recent pricing policy has received much criticism from Egyptian and multinational companies operating in the country, leading
to the program being suspended until purchasing power parity is better reflected
1. BMI Pharmaceutical and Healthcare Report Q3 2012
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RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
EgyptBiosimilar Update; Drivers vs. Resistors
Drivers Egypt Biosimilar Industry
Resistors Egypt Biosimilar Industry
- Per capita spending will remain low, and the need for affordable medicines
- Poor Intellectual Property protection ; early entry opportunity
- Registration is highly complex w/ multi committees and reviews
- Inflexible pricing regulations
- Bio -similar guidelines are drafted and implemented in 2013
- CPP requirement
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Saudi31%
Algeria21%
Egypt21%
UAE10%
Morocco8%
IMS 2011 - USD ‘ MM (Retail only)
Local/regional company
MUP
MINAPHARM
EVA
PFIZER
SIGMA
SANOFI
AMOUN (APC)
EIPICO
PHARCO
NOVARTIS
GLAXOSMITHKLINE
53,602
58,779
65,148
74,652
89,382
110,818
124,742
126,126
158,986
162,843
168,838
Strong & experienced local players
2011 Total sales in MENA (Public + Retail)
IMS 2011- USD ‘ MM
Iraq
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Sciences
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• The Iraq’s drug market is dominated in value terms by foreign MNCs.
• Most major research-based firms have a long-standing presence in the Iraq , either via contract manufacturing or local distribution arrangements.
• The Iraq does have a thriving biotech and domestic pharmaceutical industry, which the government is keen to boost. The authorities are, therefore, likely to alter their import policies, favoring local production where possible
The Pharmaceutical & Medicine Control Dep. is the main pharmaceutical regulatory division within the MoH• Products with US, EU or Japanese approval
experience less difficulty in gaining access to the market.
• Asks for US FDA or EU manufacturing license to accept the importation & registration
Local Enviroment Regulatory Regime
201 2 Drug Market Size1:US$ 2.19 bn
(2016 Drug Market Size1:US$ 3.9 bn.
CAGR 2011-20161: 14. 1% (local currency & USD)
Pharmaceutical Spend (2013)1: 0,4% of GDP
Pharma % of Health expen. (2013)1:12,3%
Healthcare Spend (2013)1: 9.28 % of GDP
By numbers
• Iraq's economy is one of the fastest growing in the region, and increased revenues from oil ensure that the government will have funds to dedicate to improving healthcare services• Strong growth of pharmaceutical sales, based largely on volume drivers.• Overall healthcare sector set to expand strongly.• Higher total pharmaceutical spending than many markets in the region based on large and expanding population numbers.• Limited competition between domestic and foreign companies.• Improved intellectual property regime as a result of post-2003 changes to legislation.• High-potential demographic and epidemiological profiles.
1. BMI Pharmaceutical and Healthcare Report Q3 2012
• Pricing Unification
Harmonization Initiatives
• IPR
• Technical landscape
• B.E current guidelines & trends (Module 5)
• Manufacturing flow strategies
• Common guidelines of Biosimilars • Harmonization initiatives of eCTD, 2D barcodes
GTIN and GLN codes Implementation
• P.V evolution
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Increasing population base Increasing Income Increasing Insurance penetrationHigher incidence of life style diseaseRising number of senior citizensHigh population growth
Impeding Factors
Un-organized Regulatory Environment Less conducive payer model Lower incidence of communicable diseases
Opportunities & Threats
Stimulating growth factors of Private Sector outweigh impeding factors
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JULPHAR
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Head of Government Affairs Middle EastGilead SciencesDubai, Dubai, United Arab Emirates Dec 14, 2015
Regulatory Affairs ManagerConnect Executive Search Middle EastDubai, UAE Dec 7, 2015
International and Government Affairs ManagerEmiratesUnited Arab Emirates Dec 10, 2015
CHC Regulatory Affairs Manager NEMEBoehringer IngelheimDubai, AE Dec 1, 2015From jobs.boehringer-ingelheim.com
Director, EMEA Regulatory Affairs Lifecycle Innovation - Medical DevicesJohnson & JohnsonDubai, AEO Oct 24, 2015From jobs.jnj.com
SCOPE OF REGULATORY AFFAIRS
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Sharing is not new, our Moms taught us to do it!Sharing is not new, our Moms taught us to do it!
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RAK Medical & Health sciences University RAK College of Pharmaceutical Sciences
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Thanks aLL
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