Safety marginAccepted with a conditionBeyond the letter
Dog axonal dystrophy margin only 6.0-fold (Cmax) and 7.4-fold (AUC); lowest affected dog dose 10 mg/kg/day
Why: SmPC warning and nonclinical summary added; safety concern followed up post-approval
“According to the applicant, the margins between the clinical exposure and the exposures in the lowest dose group at which ritlecitinib-related axonal dystrophies were observed (rostral cerebellar vermis at 10 mg/kg/day, study 20099163) are only 6.0-fold in terms of Cmax and 7.4-fold in terms of AUC24.”
✓ VerifiedEMA assessment report, p. 45Source ↗ “Therefore, upon CHMP’s request, a warning was added in section 4.4 of the SmPC, and a summary of the axonal dystrophy findings in dogs was included in the section 5.3 of the SmPC. Furthermore, given the limited availability of long-term clinical safety data, this safety concern will be followed-up post-approval (see clinical safety and RMP sections below).”
✓ VerifiedEMA assessment report, p. 63Source ↗ GenotoxicityAcceptedBeyond the letter
Aneugenic in vitro (TK6 micronucleus); negative in vivo rat micronucleus
Why: Threshold effect seen only at supra-therapeutic exposures; in vivo micronucleus negative · Weight of evidence · Pharmacology or kinetics
“While ritlecitinib was unequivocally an in vitro aneugen, the in vivo relevance of this finding is considered to be low, especially as aneugenicity is generally considered to be a threshold effect and as in vitro aneugenicity was only observed at exceedingly high supra-therapeutic exposures.”
✓ VerifiedEMA assessment report, p. 46Source ↗ “This notion was supported by the in vivo micronucleus rat study 14GR132, in which no increases in micronucleated cells were observed in test-article groups at relevant exposures.”
✓ VerifiedEMA assessment report, p. 46Source ↗ Safety pharmacologyCriticised but acceptedBeyond the letter
Dog cardiovascular safety study with very small sample size (three evaluable dogs); supportive only
Why: Cardiovascular effects not expected given selectivity towards JAK3 · Pharmacology or kinetics
“However, the very small sample size of 4 beagle dogs, actually 3 in the GLP-compliant study, since the data of one dog could not be evaluated, poses an issue with the informative value of the results.”
✓ VerifiedEMA assessment report, p. 57Source ↗ “Although the results of these cardiovascular safety studies in beagle dogs can be regarded as supportive information only, possible CV effects are not expected with ritlecitinib due to selectivity towards JAK3.”
✓ VerifiedEMA assessment report, p. 57Source ↗ GLPAccepted
Non-GLP exploratory Ames tests used for mutagenicity evaluation of impurities
Why: Assays in line with appropriate guidance; ICH M7(R1) allows use without full GLP compliance · Within the guideline
“As the submitted exploratory Ames tests were nonetheless in line with appropriate guidance (e.g. highest tested concentrations 5 mg/plate, cytotoxicity and solubility assessments, 5 relevant strains, adequate positive controls etc.), the non-GLP assays submitted in the dossier are considered sufficient for mutagenicity evaluation of (potential) impurities.”
✓ VerifiedEMA assessment report, p. 65Source ↗ “The ICH M7(R1) specifies that bacterial mutagenicity assays are expected to be performed in compliance with Good Laboratory Practices (GLP) regulations and that lack of full GLP compliance does not necessarily mean that the data cannot be used to support clinical trials and marketing authorisations.”
✓ VerifiedEMA assessment report, p. 65Source ↗