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FDA relaxes requirements for manufacturing cell and gene therapies in clinical development

Published 14 January 2026
Last update 14 January 2026
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The FDA has published a document outlining the transition to adaptive, risk-based regulation of cell and gene therapy manufacturing. The regulator formally acknowledged that classic Good Manufacturing Practice (GMP) requirements developed for mass-market drugs are not always applicable to highly complex, individualized, and rapidly evolving biotechnological products.


The key provision of the document is the waiver of the strict requirement for full GMP compliance in the manufacturing of drugs for Phase II-III clinical trials. The FDA allows for the phased development of a quality system, provided that:

 

  • critical process and product parameters are under control;

  •  Residual risks to patients are scientifically substantiated and adequately documented.


Change management is a separate priority. The regulator allows modifications to the manufacturing process without conducting a full set of comparability studies, as long as the changes do not affect critical quality attributes. This ensures the possibility of technological optimization of production in the late stages of clinical development without the risk of program shutdown.


The approach to process validation has also been revised. The document allows for the use of alternative process qualification models, including the combination of clinical manufacturing and process qualification batches, without the mandatory requirement for three consecutive PPQ batches before submitting a registration dossier.


Taken together, the document reflects the FDA's strategic shift from formal compliance monitoring to quality risk management throughout the product lifecycle. This approach reduces the regulatory burden on cell and gene therapy developers while simultaneously enhancing the role of scientific justification and transparency in manufacturing decisions.


Source: FDA - Flexible Requirements for Cell and Gene Therapies to Advance Innovation (https://www.fda.gov/vaccines-blood-biologics/cellular-gene-therapy-products/flexible-requirements-ce...)

FDA relaxes requirements for manufacturing cell and gene therapies in clinical development
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