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Considerations for the Development of Chimeric Antigen Receptor (CAR) T Cell Products

FinalCenter for Biologics Evaluation and Research01/31/2024

Description

Chimeric antigen receptor (CAR) T cell products are human gene therapy  products in which the T cell specificity is genetically modified to enable recognition of a desired target antigen for therapeutic purposes.  This guidance is intended to assist sponsors, including industry and academic sponsors, developing CAR T cell products.  In this guidance, we, FDA, provide CAR T cell specific recommendations regarding chemistry, manufacturing, and control (CMC), pharmacology and toxicology, and clinical study design.  Recommendations specific to autologous or allogeneic CAR T cell products are noted in this guidance.  This guidance also provides recommendations for analytical comparability studies for CAR T cell products.  While this guidance specifically focuses on CAR T cell products, much of the information and recommendations provided will also be applicable to other genetically modified lymphocyte products, such as CAR Natural Killer (NK) cells or T cell receptor (TCR) modified T cells.  These related product types can be highly specialized, and in many cases, considerations beyond those recommended in this guidance would depend on the specific product and manufacturing process.  To discuss considerations specific to these related products, we recommend sponsors communicate with the Office of Tissues and Advanced Therapies (OTAT) in the Center for Biologics Evaluation and Research (CBER) before submitting an Investigational New Drug Application (IND) (e.g., by requesting a pre-IND meeting (Ref. 1)).

Scope & Applicability

Product Classes

9
Chimeric Antigen Receptor (CAR) T Cell Products

Guidance for Industry regarding development of these products; Considerations for the development of CAR T cell products; Considerations for the development of these products

Autologous CAR T cells

manufactured separately for each subject

Allogeneic CAR T cells

modified to reduce immunogenicity

Human gene therapy

CAR T cell products are human gene therapy products

Autologous CAR T cell products

Recommendations specific to autologous products

Allogeneic CAR T cell products

Recommendations specific to allogeneic products; CAR T cells derived from allogeneic sources

CAR Natural Killer (NK) cells

Information may be applicable to other genetically modified lymphocyte products

T cell receptor (TCR)-modified T cells

Information may be applicable to other genetically modified lymphocyte products

CAR T Cell Products

Considerations for the Development of Chimeric Antigen Receptor (CAR) T Cell Products; Subject of the guidance document; Considerations for the development of Chimeric Antigen Receptor T cell products

Stakeholders

3
Sponsors

Assist sponsors in the nonclinical evaluation

Sponsor

Entity responsible for submitting applications under section 524B

Healthy donors

starting material obtained by leukapheresis of patients or healthy donors

Regulatory Context

Attributes

9
CQAs

testing of intermediates and the final product for CQAs (Critical Quality Attributes)

pAUC

Area under the concentration vs. time curve between two specific time points

Tmax

time to reach peak exposure

Cmax

Cmax may be more informative for safety

Transduction efficiency

can differ from lot to lot

CQA

Critical Quality Attributes evaluated by RTRT

Critical Quality Attributes

Physical, chemical, biological, or microbiological properties

CPPs

CPPs (Critical Process Parameters) should be identified and used to establish in-process controls

PPs

in-process control of PPs (Process Parameters)

Identified Hazards

Hazards

6
Delayed adverse events

integrating vectors may increase the risk of delayed adverse events

neurotoxicity

toxicity associated with CAR T cells that can be life-threatening

HAMA

human anti-mouse antibody generated from murine-derived sequences

CRS

Cytokine Release Syndrome is a particular concern of CAR T cell toxicity

On-target/off-tumor toxicity

Undesired targeting of healthy tissues that express the intended target antigen

Insertional Mutagenesis

Risk associated with vector integration

Related CFR Sections (13)

Related Warning Letters (10)

  • CGMP/Finished Pharmaceuticals/Adulterated

    SV Labs Corporation

    2025-12-23
  • CGMP/Finished Pharmaceuticals/Adulterated

    Guangdong Renhe Guozhuang Biotechnology Co., Ltd.

    2025-12-23
  • CGMP/Finished Pharmaceuticals/Adulterated

    Medinatura New Mexico, Inc.

    2025-12-23
  • CGMP/Finished Pharmaceuticals/Adulterated

    Sklar Personal Care Inc.

    2025-12-16
  • CGMP/Deviations/Biologics License Application (BLA)

    Microvascular Tissue, Inc.

    2025-12-16
  • Deviations/CFR/Regulations for Human Cells, Tissues & Cellular Products (HCT/Ps)

    Green Valley Fertility Partners

    2025-12-16
  • CGMP/Finished Pharmaceuticals/Adulterated

    Catalent Indiana, LLC

    2025-12-11
  • Unapproved New Drug/Unlicensed Biological Product/Biologics License Application (BLA)

    BioXtek LLC

    2025-12-09
  • CGMP/Finished Pharmaceuticals/Adulterated

    DeVere Manufacturing Inc.

    2025-12-09
  • CGMP/Finished Pharmaceuticals/Adulterated

    CDL Services, Inc. DBA Technichem

    2025-12-09

See Also (8)