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What flexibility did FDA and EMA accept for approved multispecifics?

From the FDA and EMA reviews of all 18 approved multispecifics. Each answer links to the regulator's own sentence.

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Short answer
14 of 18 approved multispecifics had at least one departure from the guideline that regulators accepted; reviewers questioned at least one departure in 1.
DART8/18
Study length5/18
Species3/18
Safety margin2/18
Other2/18
Efficacy model1/18
Safety pharmacology1/18
First dose1/18

Precedent by precedent

18 approved multispecifics, with the reviewers' own words.

Vabysmo

faricimab · VEGF-A x Ang-2
CarcinogenicityAccepted
No rodent carcinogenicity studies for a chronic ophthalmic product; weight-of-evidence assessment instead
Why: Not fully cross-reactive in rodents; anti-angiogenic mechanism and weight of evidence suggest no carcinogenic potential (ICH S6 (R1)) · Within the guideline · No relevant species · Weight of evidence
“No standard rodent carcinogenicity studies have been conducted as faricimab is not fully cross-reactive in rodents. The intended anti-angiogenic effects of faricimab and the weight of evidence do not suggest a carcinogenic potential of faricimab.”
✓ VerifiedEMA assessment report, p. 34Source ↗
DARTAcceptedBeyond the letter
No pre- and postnatal development study; literature on VEGF-A/ANG-2 knockouts used for risk
Why: ADA formation and exposure loss in monkeys prevent sufficient systemic exposure · Pharmacology or kinetics · Weight of evidence
“A pre- and postnatal development study could not be conducted in cynomolgus monkeys due to ADA formation and exposure loss observed in general toxicology studies preventing sufficient systemic exposure with faricimab in such a study.”
✓ VerifiedEMA assessment report, p. 34Source ↗
DARTAccepted with a conditionBeyond the letter
Fertility assessed only by reproductive organ weights and histopathology in the 6-month study; menstrual cycling not monitored
Why: Risk to female reproductive function already established; label states possible risk to reproductive capacity · Pharmacology or kinetics
“The Applicant explained that menstrual cycling was not explicitly monitored in the 6-month monkey study as it would not have contributed to human risk assessment in view of the already established risk of perturbation of female reproductive function.”
✓ VerifiedFDA pharmacology/toxicology review, p. 39Source ↗
Safety marginCriticised but acceptedBeyond the letter
Exposure margin at the ocular NOAEL (0.5 mg/eye/dose, 6-month monkey) only around 1x human
Why: Ocular immune-mediated effects seen in animals were not recorded in the clinical program · Human data
“the exposure margin at the NOAEL of 0.5 mg/eye/dose (based on the animal immune mediated ocular effects in the 6 month monkey study) with mean AUC(0-72h) = 20200 ng•hr/mL and a mean Cmax = 220 ng/mL on Day 141, is only around 1 when compared to values of human exposure”
✓ VerifiedEMA assessment report, p. 33Source ↗
First doseAccepted with a conditionBeyond the letter
At IND, nonclinical data supported the 0.5 mg/eye starting dose but not the 6.0 mg/eye high dose
Why: Unclear whether ocular inflammation is direct or ADA-mediated; clinical protocol adjustment recommended
“The proposed clinical starting dose of 0.5 mg/eye is supported by the nonclinical data but the high dose of 6.0 mg/eye is not.”
✓ VerifiedFDA pharmacology/toxicology review, p. 26Source ↗

Kimmtrak

tebentafusp · CD3 x gp100 (TCR fusion)
SpeciesAccepted
No in vivo toxicology; all toxicology in vitro with human tissues and cells (no relevant species for HLA-restricted TCR and human CD3)
Why: Human-specific protein; no relevant animal species in which toxicology could be tested · No relevant species · Within the guideline
“Tebentafusp can only recognize human HLA; therefore, all nonclinical toxicology studies were conducted in vitro. Human tissue and cell-based in vitro approaches were taken to understand potential organ-specific toxicities that may arise in the clinical setting with tebentafusp.”
✓ VerifiedFDA multi-discipline review, p. 44Source ↗
Safety pharmacologyAcceptedBeyond the letter
No safety pharmacology studies; functional in vitro assays across human tissue cell types instead
Why: Tebentafusp only recognises human HLA · No relevant species
“Tebentafusp can only recognize human HLA; therefore, all nonclinical toxicology studies were conducted in vitro. Therefore, no specific safety pharmacology studies were conducted.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗
DARTAcceptedBeyond the letter
No embryo-fetal or other DART studies; literature-based weight-of-evidence assessment instead
Why: Human-specific targets; embryo-fetal studies cannot be conducted in nonclinical species · No relevant species · Weight of evidence
“Due to the specificity for human targets, embryo-fetal development (EFD) studies cannot be conducted in nonclinical species. Therefore, a weight of evidence assessment was conducted to evaluate the risk of tebentafusp administration on pregnancy and embryo-fetal development.”
✓ VerifiedFDA multi-discipline review, p. 46Source ↗
GLPVerdict not stated
In vitro human-blood safety studies, such as cytokine release assessment, conducted non-GLP
“The potential for cytokine release syndrome (CRS) was assessed in blood from 6 healthy HLA-A*02:01-positive donors incubated with increasing concentrations of tebentafusp, and samples were analyzed for evidence of cytokine release by multiplex. These studies were non-GLP.”
✓ VerifiedFDA multi-discipline review, p. 41Source ↗
Safety marginAcceptedBeyond the letter
No in vitro margin for on-target melanocyte reactivity: patient serum concentrations exceed melanocyte EC50 (margin below 1)
Why: Skin adverse events, consistent with in vitro data, appear manageable in clinical trials · Human data
“In vitro studies suggest some safety margin between the two cell types, however not convincing. When comparing serum concentrations in patients just after infusion with EC50 in normal melanocytes, the safety margin is below 1.”
✓ VerifiedEMA assessment report, p. 31Source ↗

Tecvayli

teclistamab · BCMA x CD3
Study lengthAcceptedBeyond the letter
Only a 5-week repeat-dose monkey study; no 13-week study
Why: No findings and neutralizing ADAs in the 5-week study; a 13-week study would not provide meaningful information · Weight of evidence
“Given the dearth of findings and the induction of neutralizing ADAs in the 5-week repeat-dose toxicity study in cynomolgus monkeys, a 13-week repeat-dose toxicity study would not provide meaningful information and is not warranted to support a BLA.”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗
SpeciesCriticised but acceptedBeyond the letter
No pharmacodynamic activity in the monkey toxicity study (lower monkey BCMA affinity, few target cells, neutralizing ADAs)
Why: PD absence attributed to lower monkey BCMA affinity, few BCMA-expressing target cells and neutralizing ADAs · Pharmacology or kinetics
“Teclistamab was administered at dose levels expected to be pharmacologically active, but there was no evidence of pharmacodynamic (PD) activity or teclistamab-related adverse effects.”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗
DARTAccepted
No reproductive and developmental toxicity studies; weight-of-evidence assessment using BCMA biology and BCMA-deficient mice
Why: No BCMA expression in human reproductive organs, so on-target/off-tumor risk in these tissues relatively low · Weight of evidence · Within the guideline
“The Applicant’s Position: No reproductive and developmental toxicity studies were conducted for teclistamab. In accordance with ICH S5(R3) and S6(R1) and the US FDA Guidance for Oncology, a weight of evidence based on the intended patient population, BCMA target biology including data from genetically modified mice that lack BCMA,”
✓ VerifiedFDA multi-discipline review, p. 46Source ↗
OtherVerdict not stated
Monkey toxicity study used IV dosing while the clinical route is subcutaneous
“This study evaluated the IV route of administration, whereas the clinical route of administration is subcutaneous (SC).”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗

Talvey

talquetamab · GPRC5D x CD3
SpeciesVerdict not stated
No cross-reactivity of talquetamab with monkey GPRC5D; pivotal monkey toxicology used a surrogate tool molecule (JNJ-64024701)
Why: Talquetamab lacks cross-reactivity to monkey GPRC5D
“Due to the lack of cross reactivity of talquetamab to cynomolgus monkey GPRC5D, the tool molecule (JNJ-64024701) was developed.”
✓ VerifiedFDA multi-discipline review, p. 51Source ↗
Study lengthCriticised but acceptedBeyond the letter
No 13-week study; longest general toxicology study was 1 month with the tool molecule
Why: ADAs reduced tool molecule exposure, so longer studies would add no value; limited PD alone not accepted as a reason · Pharmacology or kinetics
“Exposure to JNJ-64024701 was compromised following the development of ADAs in the 1-month repeat-dose toxicity study in cynomolgus monkeys. Longer-duration general toxicology studies with JNJ-64024701 would not provide meaningful information and are not warranted to support a BLA.”
✓ VerifiedFDA multi-discipline review, p. 44Source ↗
DARTAcceptedBeyond the letter
No embryo-fetal or enhanced pre- and postnatal development study; weight-of-evidence assessment instead
Why: ADAs would prevent adequate exposure throughout organogenesis in a monkey developmental toxicity study · Weight of evidence · Pharmacology or kinetics
“The FDA’s Assessment: We agree with the Applicant’s WOE-based approach for the assessment of reproductive and developmental toxicity.”
✓ VerifiedFDA multi-discipline review, p. 58Source ↗

Epkinly

epcoritamab · CD20 x CD3
Study lengthAcceptedBeyond the letter
No 3-month monkey study; exposure could not be maintained with repeated dosing
Why: Exposure could not be maintained with repeated dosing; longer studies would not provide meaningful information · Pharmacology or kinetics
“A 3-month repeat-dose toxicity study of epcoritamab in cynomolgus monkeys was waived for phase 3 trials and registration of epcoritamab across the ICH regions (FDA, EMEA, and PMDA) based on the inability to maintain sufficient exposures to epcoritamab with repeated dosing.”
✓ VerifiedFDA multi-discipline review, p. 53Source ↗
DARTAcceptedBeyond the letter
Embryo-fetal development study waived; weight-of-evidence risk assessment instead
Why: High immunogenicity in monkeys; weight of evidence from mechanism of action and other B-cell targeting agents · Weight of evidence · Class precedent · Pharmacology or kinetics
“An EFD toxicity study of epcoritamab in cynomolgus monkeys was waived for phase 3 trials and registration of epcoritamab across ICH regions (FDA, EMEA, and PMDA) given the high potential for immunogenicity of epcoritamab in cynomolgus monkeys. A risk assessment-based on a weight of evidence approach was conducted considering the mechanism of action of epcoritamab and relevant information from other B-cell targeting agents (Module 2.6.6).”
✓ VerifiedFDA multi-discipline review, p. 57Source ↗

Lynozyfic

linvoseltamab · BCMA x CD3
Study lengthAcceptedBeyond the letter
Planned 26-week monkey study shortened after declining body condition in all dose groups; no 26-week study
Why: FDA did not request a 26-week study
“A subsequent toxicology study was initially planned as a 26-week repeat-dose study with once weekly dosing at 1, 5, and 20 mg/kg; the FDA did not request the study to be 26 weeks in duration. The study protocol was amended due to the declining body conditions across all dose groups compared to control.”
✓ VerifiedFDA multi-discipline review, p. 72Source ↗
DARTAcceptedBeyond the letter
No standalone fertility or embryo-fetal studies; fertility endpoints in the 5-week monkey study and weight-of-evidence assessment of developmental risk
Why: In vivo studies of limited value to understand or communicate the risk to patients with advanced cancer · Serious disease
“Standalone fertility studies were not conducted by the applicant as male and female fertility endpoints were evaluated in the 5-week study and specific immunotoxicology endpoints were evaluated in both the 5- and 9- or 14-week studies repeat dose toxicity studies.”
✓ VerifiedEMA assessment report, p. 33Source ↗

Rybrevant

amivantamab · EGFR x MET
DARTAcceptedBeyond the letter
No embryo-fetal development study; weight-of-evidence assessment of reproductive and embryo-fetal risk instead
Why: Risks to human development can be communicated from existing scientific information without further animal studies · Weight of evidence
“Rather than conducting a dedicated embryofetal development study, Janssen provided a weight-of-evidence-based assessment of the potential for amivantamab to cause reproductive and embryofetal toxicity.”
✓ VerifiedFDA multi-discipline review, p. 37Source ↗
OtherCriticised but acceptedBeyond the letter
Highest dose in monkey repeat-dose studies not fully justified (dose volume above recommended maximum)
Why: EGFR and MET are well characterised targets and the indication is advanced cancer · Pharmacology or kinetics · Serious disease
“Taken together, the highest dose level employed in the repeat-dose toxicity studies is not considered fully justified but given that EFGR and MET are rather well characterised targets, and that amivantamab is indicated for treatment of patients with advanced cancer, no further studies are needed.”
✓ VerifiedEMA assessment report, p. 41Source ↗

Korjuny

catumaxomab · EpCAM x CD3
SpeciesAcceptedBeyond the letter
No pharmacologically relevant species; limited single-dose studies plus partially active murine surrogate BiLu
Why: No cross-reactivity with CD3 or EpCAM in any routine species, including NHPs · No relevant species
“None of the animal species analysed is suitable for assessing the safety of catumaxomab. Any in vivo study with catumaxomab provides results on safety of catumaxomab with limited information for humans.”
✓ VerifiedEMA assessment report, p. 37Source ↗
Study lengthVerdict not stated
No repeat-dose toxicity studies with catumaxomab
Why: No appropriate animal species · No relevant species
“Repeat-dose toxicity studies have not been performed with catumaxomab due to the lack of an appropriate animal species.”
✓ VerifiedEMA assessment report, p. 38Source ↗
DARTVerdict not stated
No reproductive and developmental toxicity studies
Why: No appropriate animal species; patients with late-stage malignant disease · No relevant species · Within the guideline
“Studies to investigate reproductive and developmental toxicity have not been performed due to the lack of an appropriate animal species, the intended patient population with late-stage malignant disease.”
✓ VerifiedEMA assessment report, p. 38Source ↗
Safety marginVerdict not stated
Surrogate BiLu mouse NOAEL equivalent to the clinical catumaxomab dose (no margin)
“In this study, the no observed adverse effect level (NOAEL) for BiLu is considered to be the low dose (0.2 to 3.0 μg/kg). This mouse dose is equivalent to the catumaxomab dose used in the clinical regimen; the maximum human dose is 100 µg (i.e. 1.43 µg/kg in a 70 kg person).”
✓ VerifiedEMA assessment report, p. 38Source ↗

Removab

catumaxomab · EpCAM x CD3
SpeciesAccepted
No relevant species: no repeat-dose, genotoxicity, carcinogenicity or reproductive toxicity studies submitted
Why: Absence of suitable animal models · No relevant species · Within the guideline
“Repeated-dose toxicity, genotoxicity, carcinogenicity, reproductive and developmental toxicity studies have not been performed.”
✓ VerifiedEMA assessment report, p. 50Source ↗
OtherCriticised but acceptedBeyond the letter
Toxicity assessed only with the mouse-CD3 surrogate antibody BiLu, considered of limited value; safety assessment relies on clinical data
Why: Lack of a relevant animal model; safety assessment depends on clinical data · No relevant species · Human data
“BiLu may thus not have similar toxicological and dynamic effects in the mouse as catumaxomab has in the human leaving the safety assessment of catumaxomab largely to the clinical studies.”
✓ VerifiedEMA assessment report, p. 14Source ↗
Impurity or metaboliteVerdict not stated
No toxicity studies with trace impurities
Why: No animal model permits testing of the full pharmacological activity · No relevant species
“"Since no animal model is available which permits toxicological testing of the full pharmacological activity of catumaxomab, toxicity studies with trace impurities were not performed."”
✓ VerifiedEMA assessment report, p. 15Source ↗
GLPVerdict not stated
Most pharmacokinetic studies not fully GLP-compliant
Why: Studies subjected to quality assurance evaluation
“Although not fully complying with GLP, most pharmacokinetic studies were subjected to quality assurance evaluation.”
✓ VerifiedEMA assessment report, p. 15Source ↗

Blincyto

blinatumomab · CD19 x CD3
SpeciesAcceptedBeyond the letter
Chimpanzee the only relevant species; limited non-terminal chimpanzee studies plus mouse studies with murine surrogate muS103new
Why: Chimpanzee is the only relevant species and its use is ethically limited; surrogate similar in binding, lysis and T-cell activation · No relevant species · Other reason
“Since there are very limited possibilities to evaluate the toxicology of blinatumomab in the only non-clinical relevant species for ethical reasons, the applicant developed a surrogate BiTE molecule specific for murine CD3 and murine CD19 from rat monoclonal antibodies.”
✓ VerifiedEMA assessment report, p. 20Source ↗
DARTVerdict not stated
No reproductive toxicity studies with blinatumomab; mouse embryo-foetal study with murine surrogate only
“Reproductive toxicity studies have not been conducted with blinatumomab. In an embryo-foetal developmental toxicity study performed in mice, the murine surrogate crossed the placenta to a limited extent (foetal-to-maternal serum concentration ratio < 1%) and did not induce embryo-foetal toxicity or teratogenicity.”
✓ VerifiedEMA assessment report, p. 32Source ↗
DARTVerdict not stated
No fertility studies; reproductive organs assessed in surrogate repeat-dose toxicity studies
Why: No effects on male or female reproductive organs in murine surrogate toxicity studies
“No studies have been conducted to evaluate treatment-related effects on fertility. There were no effects on male or female reproductive organs in toxicity studies with the murine surrogate (SmPC section 5.3).”
✓ VerifiedEMA assessment report, p. 32Source ↗

Columvi

glofitamab · CD20 x CD3
Study lengthAcceptedBeyond the letter
No repeat-dose study longer than 4 weeks; 13-week monkey study waived
Why: High ADA incidence in monkeys caused loss of exposure and effect; effects similar to other B-cell depleting agents · Pharmacology or kinetics · Class precedent
“Studies longer than 4 weeks were not performed, as glofitamab was highly immunogenic in cynomolgus monkeys leading to loss of exposure and loss of the pharmacologic effect.”
✓ VerifiedFDA multi-discipline review, p. 57Source ↗
DARTAccepted
No animal reproductive or developmental toxicity studies; weight-of-evidence risk assessment instead
Why: Weight-of-evidence per ICH S6(R1); further testing unlikely to add to current nonclinical and clinical knowledge · Weight of evidence · Within the guideline · Class precedent
“While no animal studies were conducted to assess the reproductive and developmental risks of glofitamab, a weight of evidence (WoE)-based risk assessment report was submitted.”
✓ VerifiedFDA multi-discipline review, p. 41Source ↗
Safety marginAccepted
Monkey exposures below clinical: AUC multiples 0.03 to 0.28 in studies without obinutuzumab pretreatment
Why: Advanced cancer indication; adverse effects from exaggerated pharmacology; no alternative species besides monkey · Serious disease · Within the guideline · Pharmacology or kinetics
“In summary, obtained exposure levels in toxicology studies conducted without Gpt did not exceed those obtained in the clinical setting, as estimations of exposure multiples resulted in values of 0.03 to 0.28 (based on AUC), implying that CRS-related effects occur at clinically relevant dose levels.”
✓ VerifiedEMA assessment report, p. 35Source ↗

Hemlibra

emicizumab · FIXa x FX
CarcinogenicityAccepted
No carcinogenicity studies for a chronic prophylactic antibody; written carcinogenicity assessment used instead
Why: No pharmacologically relevant rodent species; sponsor's carcinogenicity assessment judged sufficient, with ECAC concurrence · No relevant species · Within the guideline · Weight of evidence
“Carcinogenicity studies were not conducted due to lack of a pharmacologically relevant rodent species.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗
DARTVerdict not stated
No reproductive or developmental toxicity studies (fertility, embryo-fetal, pre/postnatal)
Why: Hemophilia A is X-linked recessive; 99% of patients are male, so use in females exceedingly rare · Other reason
“Animal reproductive and developmental toxicology studies were not conducted with emicizumab as hemophilia A is inherited in an X-linked recessive manner. Males represent 99% of the patients with hemophilia A, thus it would be exceedingly rare for females to be prescribed this drug.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗
Efficacy modelCriticised but acceptedBeyond the letter
Monkey acquired hemophilia A efficacy models poorly characterised at initial application
Why: Adequate justification of the parameters measured was subsequently provided · Other reason
“While the results are supportive of the proposed use, at the time of initial application, the models were poorly characterised. However, adequate justification of the choice of parameters measured was subsequently provided.”
✓ VerifiedEMA assessment report, p. 36Source ↗

Imdelltra

tarlatamab · DLL3 x CD3
SpeciesQuestioned
Monkey used as the only toxicology species although DLL3 is intracellular in normal tissues, so toxicity may be underrepresented
Why: Monkey chosen because tarlatamab binds human and monkey CD3 and DLL3 similarly in vitro
“Though the monkey was chosen for toxicity testing based on the ability of tarlatamab to bind human and monkey CD3 and DLL3 similarly in in vitro assays, toxicity associated with tarlatamab may be underrepresented in the monkey given that immunohistochemistry data described above indicates that DLL3 is expressed intracellularly in normal tissues and cells.”
✓ VerifiedFDA multi-discipline review, p. 71Source ↗
DARTAcceptedBeyond the letter
Embryo-fetal development assessed only in mice with a murine surrogate (muS757), not with tarlatamab
Why: Surrogate muS757 binds mouse CD3 and DLL3; developed at FDA's proposal · Pharmacology or kinetics
“Following the proposal of the FDA, a murine surrogate molecule of tarlatamab, designated muS757, was developed to evaluate potential effects of a DLL3-targeting BiTE molecule on embryofetal development in mice.”
✓ VerifiedFDA multi-discipline review, p. 73Source ↗
DARTAccepted
No dedicated fertility studies
Why: Not needed to support marketing of a drug for patients with advanced cancer · Within the guideline · Serious disease
“In addition, the Applicant did not conduct dedicated studies to assess fertility. In general, these studies are not needed to support a marketing application for a drug intended to treat patients with advanced cancer.”
✓ VerifiedFDA multi-discipline review, p. 50Source ↗

Ordspono

odronextamab · CD20 x CD3
DARTAcceptedBeyond the letter
No embryo-fetal development study; literature and nonclinical data risk assessment instead
Why: Consistent with previous CHMP conclusions for other bispecific antibodies of this class · Class precedent · Weight of evidence
“Embryo-fetal developmental toxicology studies were not conducted with odronextamab. A risk assessment based on available nonclinical data and literature was provided. This approach is agreed and is in line with previous CHMP conclusions on other members of this class of bispecific antibodies.”
✓ VerifiedEMA assessment report, p. 37Source ↗
SpeciesVerdict not stated
Monkey, the only relevant species, binds CD3 about 100-fold more weakly than human, possibly explaining lower cytokine responses than in humans
“Whereas the binding of CD20 was within the same concentration range for both human and monkey, there was approximately a 100-fold difference with respect to human and monkey CD3. This observed difference indicates a higher affinity for human CD3 which might be the cause of the observed discrepancy between cytokine levels observed in human and in cynomolgus, respectively.”
✓ VerifiedEMA assessment report, p. 36Source ↗

Elrexfio

elranatamab · BCMA x CD3
DARTVerdict not stated
No reproductive or developmental toxicity studies; reproductive organs assessed in the 3-month study in sexually mature monkeys
Why: No effects on reproductive organs in sexually mature monkeys
“Reproductive and developmental toxicity studies have not been conducted with elranatamab. No effects on reproductive organs were observed in the 3-months toxicity study in sexually mature monkeys.”
✓ VerifiedEMA assessment report, p. 46Source ↗
RecoveryVerdict not stated
No recovery phase in any general toxicology study
Why: Effects are expected to recover
“Recovery was not formally assessed in any study, but effects are expected to recover.”
✓ VerifiedFDA multi-discipline review, p. 56Source ↗
Safety marginVerdict not stated
No exposure margin at the monkey NOAEL/LOEL of 0.3 mg/kg: 0.1x to 0.2x human exposure
“At the NOAEL/LOEL of 0.3 mg/kg, exposure in cynomolgus was well below the human exposure (0.1x or 0.2x).”
✓ VerifiedEMA assessment report, p. 46Source ↗

Lunsumio

mosunetuzumab · CD20 x CD3
DARTAccepted
Monkey embryo-fetal and pre-/postnatal development study waived; weight-of-evidence assessment using other anti-CD20 antibodies
Why: Further monkey testing unlikely to add information; anti-CD20 class effects known · Weight of evidence · Class precedent · Within the guideline
“A briefing book, including the WOE-based risk assessment and a request to waive a non-human primate embryo-fetal and prenatal/postnatal development study, was submitted to the FDA (dated 3 April 2018; Reference ID: 4277993).”
✓ VerifiedFDA multi-discipline review, p. 59Source ↗
Safety marginVerdict not stated
No NOAEL; CRS and infections in monkeys at exposure multiples of 0.008 to 1.84
“When applying the corrections of AUC, estimations of exposure multiples resulted in values of 0.008 to 1.84, implying that CRS related effects and immunosuppression leading to infections occur at clinically relevant dose levels.”
✓ VerifiedEMA assessment report, p. 36Source ↗
OtherVerdict not stated
No tissue cross-reactivity study: no robust IHC assay could be developed
Why: Poor analytical sensitivity and specificity of the antibody as an IHC reagent
“Due to technical limitations it was not possible to develop a robust, reproducible and accurate IHC assay to assess specific tissue binding and determine the potential cross-reactivity of mosunetuzumab in human and cynomolgus monkey tissue, as mosunetuzumab exhibits poor analytical sensitivity and specificity as an IHC reagent.”
✓ VerifiedEMA assessment report, p. 26Source ↗

Ziihera

zanidatamab · HER2 x HER2 (biparatopic)
DARTAccepted
No reproductive and developmental toxicity studies; HER2-antibody class weight-of-evidence assessment instead
Why: Embryo-fetal toxicity a likely class effect of HER2-binding antibodies per literature (ICH S5(R3)) · Within the guideline · Class precedent · Weight of evidence
“On the basis of a weight-of-evidence analysis supported by published literature indicating that embryo-fetal toxicity is a likely class effect of HER2 binding antibodies (ICH S5(R3) Section 1.2.2) (ICH, 2020), Jazz proposes that zanidatamab should be considered an embryofetal toxicant.”
✓ VerifiedFDA multi-discipline review, p. 45Source ↗
DARTVerdict not stated
No fertility studies; fertility assessed by reproductive organ histopathology and weights in the repeat-dose monkey study
“Fertility studies have not been performed with zanidatamab but its potential to impair fertility was assessed by histopathology and organ weight analysis as part of the pivotal repeat dose toxicity study.”
✓ VerifiedEMA assessment report, p. 52Source ↗

Bizengri

zenocutuzumab · HER2 x HER3
DARTAccepted
No reproductive or developmental toxicity studies; literature-based weight-of-evidence assessment of HER2/HER3 inhibition instead
Why: Mechanism-based literature weight of evidence, an alternative approach described in FDA oncology reproductive toxicity guidance · Within the guideline · Weight of evidence · Pharmacology or kinetics
“Rather, the Applicant provided a literature-based weight-of-evidence (WOE) assessment of the potential reproductive toxicity of zenocutuzumab based on its mechanism of action, consistent with the alternative approach described in the FDA Guidance for Industry, Oncology Pharmaceuticals: Reproductive Toxicity Testing and Labeling Recommendations.”
✓ VerifiedFDA multi-discipline review, p. 58Source ↗