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Precedia/Cell therapy/Test article

Clinical lot or not: what material did approved cell therapies test?

From the FDA and EMA reviews of all 27 approved cell therapies. Each answer links to the regulator's own sentence.

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Short answer
22 of 27 approved cell therapies were tested in animals with something other than the clinical lot.
Several of these9/27
Earlier process or lot8/27
Clinical lot or same process4/27
Surrogate (animal analogue)4/27
Prototype1/27
Not stated1/27

Precedent by precedent

27 approved cell therapies, with the reviewers' own words.

Abecma

idecabtagene vicleucel · BCMA CAR-T
Test article vs clinical lot
Pharmacology used experimental CAR T batches without lot numbers; clinical drug product lots used for insertion site and growth studies. Bridging: Per certificates of testing, nonclinical experiment batches met the clinical lot release specifications
“*Lot Nos. were not assigned for CAR T cells assessed in nonclinical studies #1-8; they were manufactured under Experiment Nos.”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗
Genetically modified?
Autologous CD3+ CAR-T, lentiviral vector
“Idecabtagene vicleucel (ide-cel, bb2121) consists of autologous CD3+ T cells that are transduced using a lentiviral vector to express a BCMA-directed chimeric antigen receptor (CAR).”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Alofisel

darvadstrocel · Allogeneic adipose MSC
Test article vs clinical lot
Human eASC expanded with the manufacturing method to the clinical population doubling level, in most studies. Bridging: Same manufacturing method and population doubling level as the clinical product
“In most studies, cell preparations were expanded with the method of manufacture and to the same population doubling level of the product for clinical use.”
✓ VerifiedEMA assessment report, p. 19Source ↗
Genetically modified?
Expanded allogeneic adipose-derived stem cells (eASC); not genetically modified
“assess efficacy and safety of expanded allogeneic adipose-derived stem cells (eASC) for the”
✓ VerifiedEMA assessment report, p. 30Source ↗

Amtagvi

lifileucel · TIL therapy
Test article vs clinical lot
No studies with the product; published data on similar murine and human tumor-derived T lymphocytes. Bridging: None; FDA noted the GEN2 process differs from the published TIL expansion methods
“No nonclinical studies were conducted with AMTAGVI. Instead, the applicant cited published nonclinical data evaluating similar murine and human tumor-derived T lymphocytes to provide support for AMTAGVI.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Genetically modified?
Autologous tumor-derived T lymphocytes (TIL), not genetically modified
“AMTAGVI is a cellular suspension containing live autologous T lymphocytes isolated from a patient’s resected tumor.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Aucatzyl

obecabtagene autoleucel · CD19 CAR-T
Test article vs clinical lot
Nonclinical CAT19 CAR T cells from healthy donor PBMCs; clinical product from patient leukapheresate. Bridging: Constructs, including the binding domain, identical; nonclinical product judged appropriate despite minor process differences
“The main difference is that the starting material for the nonclinical product was healthy donor PBMCs, while for the clinical product it was non-stimulated leukapheresate from patients.”
✓ VerifiedFDA pharmacology/toxicology review, p. 5Source ↗
Genetically modified?
Autologous CD4+ and CD8+ CAR-T, lentiviral vector
“AUCATZYL™ (obecabtagene autoleucel; obe-cel; AUTO1; CAT19 CAR T cells) is a cell suspension consisting of autologous human CD4+ and CD8+ T cells transduced with a lentiviral vector encoding a CAR consisting of an anti-CD19 scFv linked to 4-1BB and CD3ζ T cell activating domains.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Breyanzi

lisocabtagene maraleucel · CD19 CAR-T
Test article vs clinical lot
Cryopreserved preclinical JCAR017 lots from preclinical production runs, expanded by a protocol mimicking the commercial post-transduction process. Bridging: Cells expanded according to a protocol that mimics the post-transduction manipulation process for BREYANZI
“The objective of this in vivo study was to evaluate the anti-tumor activity of cryopreserved preclinical lots of JCAR017 produced from several preclinical production runs (page 3 in the study report). The cells were thawed and expanded according to a protocol that mimics the post-transduction manipulation process for BREYANZI®.”
✓ VerifiedFDA pharmacology/toxicology review, p. 23Source ↗
Genetically modified?
Autologous CD4+ and CD8+ CAR-T, lentiviral vector
“BREYANZI® (lisocabtagene maraleucel; JCAR017) is a cell suspension consisting of autologous human CD4+ and CD8+ T cells that are engineered with a lentiviral vector encoding a chimeric antigen receptor (CAR) consisting of an anti-CD19 single-chain variable fragment (scFv)”
✓ VerifiedFDA pharmacology/toxicology review, p. 1Source ↗

Carvykti

ciltacabtagene autoleucel · BCMA CAR-T
Test article vs clinical lot
CAR T cells made with lentiviral vectors from different developmental stages; CAR identical in all cases. Bridging: CAR expressed by the CAR-T cells identical across lentiviral vector versions
“In the non-clinical package, CAR T cells from different LV manufacturing developmental stages have been used (refer to Section 2.4.2. ). In all cases, the CAR expressed by the CAR-T cells is identical.”
✓ VerifiedEMA assessment report, p. 31Source ↗
Genetically modified?
Autologous CAR-T, lentiviral vector
“CARVYKTI™ (ciltacabtagene autoleucel; cilta-cel; JNJ-68284528; or LCAR-B38M CAR-T cells) is a cell suspension consisting of autologous T cells that are genetically modified ex vivo with a lentiviral vector (LV) encoding a chimeric antigen receptor (CAR) targeting the B cell maturation antigen (BCMA).”
✓ VerifiedFDA pharmacology/toxicology review, p. 1Source ↗

ChondroCelect

characterised viable autologous cartilage cells · Autologous chondrocytes
Test article vs clinical lot
Human chondrocytes and autologous goat cells expanded by the ChondroCelect culture process
“In goats either autologous cells or human articular chondrocytes, expanded according to the ChondroCelect culture process were implancted via an ACI procedure.”
✓ VerifiedEMA assessment report, p. 11Source ↗
Genetically modified?
Non-modified human autologous chondrocytes
“ChondroCelect is composed of non-modified human autologous cells.”
✓ VerifiedEMA assessment report, p. 13Source ↗

Ebvallo

tabelecleucel · EBV-specific allogeneic T cells
Test article vs clinical lot
In-process ATA129 product (Day 27 of culture) used for in vitro pharmacology
“In process ATA129 product was received on Day 27 of ongoing culture and was separated into CD4 and CD8 enriched fractions.”
✓ VerifiedEMA assessment report, p. 24Source ↗
Genetically modified?
Allogeneic EBV-specific T cells; not genetically modified
“Tabelecleucel is a cell based therapeutic product that is not genetically modified.”
✓ VerifiedEMA assessment report, p. 30Source ↗

Encelto

revakinagene taroretcel · CNTF (encapsulated RPE cell implant)
Test article vs clinical lot
Dog pharmacology study used an early 11 mm prototype device; the clinical device is 6.5 mm. Bridging: None; reviewers judged the prototype study preliminary for the pharmacology of NT-501
“The device used in this study is an early prototype that is 11 mm in length (the proposed clinical device is 6.5 mm). Thus, this study is preliminary regarding assessing the overall pharmacology of the product, NT-501.”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗
Genetically modified?
Encapsulated allogeneic RPE cell line NTC-201-6A engineered to express rhCNTF
“The ENCELTO dose of rhCNTF derives from an implant containing 200,000-440,000 allogeneic retinal pigment epithelial (RPE) cells expressing rhCNTF (NTC-201-6A cell line).”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Gintuit

allogeneic cultured keratinocytes and fibroblasts in bovine collagen · Allogeneic keratinocytes + fibroblasts
Test article vs clinical lot
Apligraf, stated to be identical to Apligraf (oral). Bridging: Apligraf used in the studies is identical to Apligraf (oral)
“Apligraf®, which is identical to Apligraf® (oral), is approved under a PMA filing (reviewed by CDRH) for the treatment of venous leg and diabetic foot ulcers; therefore, limited additional preclinical studies were conducted in support of this BLA.”
✓ VerifiedFDA pharmacology/toxicology review, p. 48Source ↗
Genetically modified?
Allogeneic keratinocytes and dermal fibroblasts
“In vitro analysis of the cellular components of Apligraf®, allogeneic keratinocytes and dermal fibroblasts, did not show induction of an alloimmune response”
✓ VerifiedFDA pharmacology/toxicology review, p. 49Source ↗

Holoclar

autologous corneal epithelial cells containing limbal stem cells · Autologous limbal stem cells
Test article vs clinical lot
Six batches cultured from the drug product, tested in vitro (karyotype)
“The karyotype analysis included chromosomal counts and the frequency of hyperploidy, hypoploidy, polyploidy, breaks and structural abnormalities in 50 metaphasic cells in six batches cultured from the drug product.”
✓ VerifiedEMA assessment report, p. 18Source ↗
Genetically modified?
Autologous human corneal epithelial cells including stem cells
“The non-clinical development programme of Holoclar, a transparent sheet of autologous human corneal epithelial cells including stem cells, comprised an evaluation of published studies from the scientific literature”
✓ VerifiedEMA assessment report, p. 16Source ↗

Kymriah

tisagenlecleucel · CD19 CAR-T
Test article vs clinical lot
Pharmacology used cells transduced with UPenn/US-made research lentiviral vector; clinical studies used Oxford Biomedica vector. Bridging: No comparative in vivo studies; CHMP judged them uninformative for comparability and accepted their absence
“the pharmacology studies were conducted with cells transduced with lentiviral vector made at the University of Pennsylvania, or at a further facility in the US, whereas clinical studies were done with cells transduced with vector made by Oxford Biomedica”
✓ VerifiedEMA assessment report, p. 39Source ↗
Genetically modified?
Autologous CAR-T, replication-deficient lentiviral vector
“Tisagenlecleucel (KYMRIAH™, CTL019) gene transfer is accomplished via ex vivo transduction with a replication-deficient human lentiviral vector (LV) encoding the transgene.”
✓ VerifiedFDA pharmacology/toxicology review, p. 1Source ↗

Lantidra

donislecel · Allogeneic pancreatic islets
Test article vs clinical lot
No studies with LANTIDRA; published studies of transplanted allogeneic or syngeneic animal islets
“No nonclinical studies were conducted with LANTIDRA. Instead, the applicant referenced multiple publications and one manuscript in the BLA submission that evaluated biological activity, local (liver) distribution, and the local (liver) safety of transplanted allogeneic or syngeneic islets”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Genetically modified?
Islets of Langerhans from deceased adult human donor pancreata; not genetically modified
“LANTIDRA (donislecel-jujn) is a cellular therapy comprised of islets of Langerhans obtained from the pancreas of deceased adult human donors.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Laviv

azficel-T · Autologous fibroblasts
Test article vs clinical lot
Published rabbit study used analog fibroblasts prepared by mincing and dispase, unlike the IT process. Bridging: None; rabbit analog cell preparation did not duplicate the IT procedure
“The preparation of the rabbit analog cells used in this study did not duplicate the procedure that is used for IT preparation; for example, the rabbit cells were separated from the skin biopsy by mincing and treating with dispase; however, only digestive enzymes are used to prepare IT.”
✓ VerifiedFDA pharmacology/toxicology review, p. 24Source ↗
Genetically modified?
Autologous human dermal fibroblasts expanded ex vivo; not genetically modified
“Autologous fibroblasts (Human, dermal, Isolagen Technologies, Inc.) expanded ex vivo, administered intradermally.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

MACI

autologous cultured chondrocytes on porcine collagen membrane · Autologous chondrocytes
Test article vs clinical lot
Analogous products: ACI-Maix membrane seeded with rabbit or horse cells. Bridging: Same ACI-Maix membrane as the clinical product, seeded with animal instead of human cells
“Studies conducted in horses and rabbits compared ACI-Maix or empty defects to analogous products consisting of ACI-Maix seeded with rabbit or horse cells.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Genetically modified?
Characterized autologous cultured chondrocytes on porcine collagen membrane
“The product, MACI™, is an implant which consists of characterized autologous cultured chondrocytes (ACI) seeded on a resorbable porcine-derived collagen membrane (ACI-Maix)”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Omisirge

omidubicel · Expanded cord blood HPC
Test article vs clinical lot
Products from different development stages, before the final omidubicel-onlv manufacturing process was implemented
“The nonclinical studies were conducted with products from different stages of development before the final manufacturing process of omidubicel-onlv was implemented.”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗
Genetically modified?
Allogeneic hematopoietic cell therapy: CF and NF fractions from the same cord blood unit; not genetically modified
“OMISIRGE is a cryopreserved, allogeneic hematopoietic cellular therapy consisting of two cell fractions; a CF and NF, which are both derived from the same subject-specific CBU.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Provenge

sipuleucel-T · PAP-GM-CSF (autologous APC)
Test article vs clinical lot
Rat splenic cells loaded with PAP antigens instead of PBMCs, made by a process differing from sipuleucel-T
“However, splenic rat cells were loaded with PAP antigens instead of peripheral blood mononuclear cells and the manufacturing processes for the cellular products differed from the sipuleucel-T process.”
✓ VerifiedEMA assessment report, p. 33Source ↗
Genetically modified?
Autologous PBMCs including APCs activated ex vivo with PAP–GM-CSF fusion protein PA2024; not genetically modified
“Provenge (sipuleucel-T) consists of autologous peripheral blood mononuclear cells (PBMCs), including antigen presenting cells (APCs) that have been activated ex vivo with a recombinant fusion protein, PA2024, composed of prostatic acid phosphatase (PAP) and granulocyte-macrophage colony-stimulating factor (GM-CSF).”
✓ VerifiedEMA assessment report, p. 25Source ↗

Rethymic

allogeneic processed thymus tissue · Allogeneic thymus tissue
Test article vs clinical lot
Allogeneic neonatal thymus under candidate culture conditions, implanted in nude rats
“Animal studies were conducted in nude rats to identify potentially optimal culture conditions of allogeneic neonatal thymus that result in engraftment and development of an endogenous T cell population (i.e., thymogenesis) following transplantation.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗
Genetically modified?
Allogeneic processed postnatal thymus tissue
“RVT-802 is an allogeneic, processed postnatal thymus tissue product that is administered via surgical implantation.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Ryoncil

remestemcel-L · Allogeneic BM-MSC
Test article vs clinical lot
Human bone marrow ceMSC and surrogate animal-derived ceMSC, made with an early manufacturing process. Bridging: Not bridged; reviewers concluded the studies provide limited support for RYONCIL
“Nonclinical studies were conducted using human bone marrow-derived culture-expanded MSC (ceMSC) and surrogate animal-derived ceMSC produced using an early manufacturing process. As a result, the completed nonclinical studies provide limited support for RYONCIL.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗
Genetically modified?
Expanded allogeneic human bone marrow mesenchymal stromal cells; not genetically modified
“Remestemcel-L is comprised of expanded allogeneic human bone marrow-derived mesenchymal stromal cells.”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗

Spherox

spheroids of autologous matrix-associated chondrocytes · Autologous chondrocyte spheroids
Test article vs clinical lot
Human Spherox or autologous animal spheroids produced in an analogous way
“In these studies human Spheroxs or autologous spheroids produced in an analogous way were used.”
✓ VerifiedEMA assessment report, p. 30Source ↗
Genetically modified?
Spheroids of human autologous matrix-associated chondrocytes
“The active substance, spheroids of human autologous matrix-associated chondrocytes, is formulated in 0.9% sodium chloride solution”
✓ VerifiedEMA assessment report, p. 21Source ↗

StrataGraft

allogeneic cultured keratinocytes and dermal fibroblasts in murine collagen · Allogeneic keratinocytes + fibroblasts
Test article vs clinical lot
STRATAGRAFT batches from earlier development processes that differed from the commercial process. Bridging: Differences from the commercial process were listed; the batch reflecting each change was not specified
“Per the applicant, the STRATAGRAFT® manufacturing process was being refined as the product development program progressed. The applicant cited the following differences between the manufacturing process of STRATAGRAFT® for Studies #1 and #14 and the commercial process.”
✓ VerifiedFDA pharmacology/toxicology review, p. 8Source ↗
Genetically modified?
Allogeneic immortalized NIKS keratinocytes on allogeneic dermal fibroblasts in collagen
“The construct is composed of an epidermal layer of fully-stratified allogeneic immortalized near-diploid human keratinocytes (NIKS® keratinocytes) grown on a dermal equivalent (DE) consisting of allogeneic normal human dermal fibroblasts (NHDFs) in a rat tail collagen-rich matrix.”
✓ VerifiedFDA pharmacology/toxicology review, p. 1Source ↗

Tecartus

brexucabtagene autoleucel · CD19 CAR-T
Test article vs clinical lot
Some in vitro pharmacology used NCI-made CAR T cells from a similar but not equivalent process; additional studies used KTE-X19-process cells. Bridging: Additional in vitro pharmacology studies with CAR T cells manufactured using the KTE-X19 process, per CHMP protocol assistance
“Some of the presented non-clinical in vitro pharmacology studies were conducted with CD19 CAR T cells that were generated at the NCI with a manufacturing process similar, but not fully equivalent to the KTE-X19 process. In order to complete the pharmacology data package, additional non-clinical in vitro pharmacology studies were conducted with CD19 CAR T cells manufactured using the KTE-X19 process.”
✓ VerifiedEMA assessment report, p. 34Source ↗
Genetically modified?
Autologous CAR-T, retroviral vector
“KTE-X19 (also referred to as axicabtagene ciloleucel) is an autologous chimeric antigen receptor (CAR) T-cell product engineered with a retroviral vector”
✓ VerifiedFDA pharmacology/toxicology review, p. 1Source ↗

Tregzi

allogeneic Treg immunotherapy with HSPC and T cells (Orca-T) · Allogeneic Treg + HSPC + Tcon
Test article vs clinical lot
Human Tregs and Tcons manufactured similarly to intended clinical DP lots. Bridging: Manufactured similarly to clinical lots; unclear dose basis limits comparison of biological activity with clinical doses
“Although the human Tregs and Tcons administered in the nonclinical studies were manufactured similarly to the intended clinical DP lots, this lack of clarity limits the ability to determine whether nonclinical dose levels (cells/mouse) reflect comparable biological activity to clinical Treg DP and Tcon DP dose levels in TREGZI.”
✓ VerifiedFDA pharmacology/toxicology review, p. 33Source ↗
Genetically modified?
Allogeneic HSPC and T-cell immunotherapy
“TREGZI (Orca-T) is an allogeneic hematopoietic stem and progenitor cell (HSPC), and T-cell immunotherapy designed to improve survival free of cGVHD in adult patients with hematologic malignancies undergoing a myeloablative preparative regimen.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Yescarta

axicabtagene ciloleucel · CD19 CAR-T
Test article vs clinical lot
In vitro pharmacology used CAR T cells from earlier NCI processes CLP-1.0 and CLP-2.0, not the current CLP-2.2. Bridging: NCI split-apheresis comparison of CLP-1.0 and CLP-2.0; murine surrogate CAR T cells used in vivo; repeat studies with CLP-2.2 not required
“Non-clinical in vitro pharmacology studies were performed with CD19 CAR T cells that were generated using two previous manufacturing processes established at the NCI (CLP-1.0 and CLP-2.0); neither of them represents the current process (CLP-2.2).”
✓ VerifiedEMA assessment report, p. 33Source ↗
Genetically modified?
Autologous CAR-T, γ-retroviral vector
“KTE-C19 comprises human autologous cells transduced with a retroviral vector containing an anti-CD19 CAR.”
✓ VerifiedEMA assessment report, p. 35Source ↗

Zalmoxis

allogeneic T cells modified with HSV-TK / dLNGFR (nalotimagene carmaleucel) · HSV-TK suicide-gene T cells
Test article vs clinical lot
MM-TK made with the original SFCMM-3 #35 vector and the optimized Mut2 #48 vector and process
“Preclinical in vitro and in vivo studies in immune deficient mice were performed using for cell preparation both the SFCMM-3 #35 retroviral vector and an optimized version of the vector, encoding a mutated form of the HSV-TK gene (HSV-TK Mut2 #48), as well as and an optimized process manufacture developed before launching the phase III clinical study.”
✓ VerifiedEMA assessment report, p. 17Source ↗
Genetically modified?
Donor T lymphocytes genetically modified with SFCMM-3 Mut2 #48 retroviral vector (HSV-TK, ΔLNGFR)
“The finished medicinal product of Zalmoxis is defined as frozen donor T lymphocytes genetically modified with the SFCMM-3 Mut2 #48 retroviral vector and encoding for the HSV-TK and the ΔLNGFR genes”
✓ VerifiedEMA assessment report, p. 14Source ↗

Zemcelpro

dorocubicel · UM171-expanded cord blood CD34+
Test article vs clinical lot
Earlier culture processes; only study ECT/2018-12-001 used the clinical process (35 mM UM171, 4F, no LDLs, 7-day culture). Bridging: No thorough non-clinical study of the final clinical culture conditions all together
“Except for study ECT/2018-12-001, none of the submitted non-clinical studies have been conducted with the clinical/commercial manufacturing process using 35 mM UM171, 4F and no LDLs in a 7-day culture. No thorough non-clinical study has been conducted to evaluate the final clinical process culture conditions all together.”
✓ VerifiedEMA assessment report, p. 40Source ↗
Genetically modified?
Cord blood CD34+ cells expanded in vitro with small molecule UM171 and growth factors; not genetically modified
“The CD34+ cell fraction consists of cord blood-derived CD34+ cells that are expanded in vitro in the presence of the small molecule UM171 and hematopoietic growth factors.”
✓ VerifiedEMA assessment report, p. 20Source ↗

Tecelra

afamitresgene autoleucel · MAGE-A4 TCR-T
Test article vs clinical lot
Not stated in public reviews
Genetically modified?
Autologous TCR-T (affinity-enhanced MAGE-A4 TCR), lentiviral vector
“TECELRA consists of autologous T cells that are genetically modified with the lentiviral vector (LVV) MAGE-A4-c1032 to constitutively express an affinity-enhanced T cell receptor (TCR) specific for human MAGE-A4.”
✓ VerifiedFDA summary basis for approval, p. 4Source ↗