Dear
<< Antragsteller:in >> << Antragsteller:in >>
Thank you for your questions about Comirnaty. Please see our responses below.
1. Page 15/78 states: "The functional elements of the pST4-1525 are sufficiently described in graphic and tabular formats and the sequence is included." Did the EMA ever independently verify the provided sequence contains the claimed functional elements? Did EMA ever independently sequence the MCBs/WCBs?
*EMA does not carry out sequencing of materials. EMA assesses information provided by companies and, in conjunction with national authorities, ensures that manufacturing is carried out in line with Good Manufacturing Practices (GMP). You can find more information in the link below:*
https://www.ema.europa.eu/en/human-regulatory-overview/research-and-development/compliance-research-and-development/good-manufacturing-practice (
https://www.ema.europa.eu/en/human-regulatory-overview/research-and-development/compliance-research-and-development/good-manufacturing-practice )
2, Does the document 3.2.S.2.3. "Control of Materials - Source, History and Generation of Plasmids" make any mention of "SV-40", or describe the promotors driving the antibiotic resistance genes' expression? I assume the document is entirely withheld due to trade secrets, yet the question is justified due to the presence of this promotor in all pfizer-biontech vials thus sequenced by third parties.
*While the full DNA sequence of the plasmid starting material was provided in the initial marketing authorisation application for Comirnaty, the applicant did not specifically highlight the SV40 sequence, as it was considered to be a non-functional part of the plasmid. They have since clarified this information in response to questions raised by EMA.*
3. How does the EMA explain the difference between pST4-1525 and the verified-by-replication sequencing results? How can there be differences between the regulatory filings and the product released onto the market?
*As stated above, the full sequence was provided with the application for marketing authorisation. Companies cannot make changes to their products when placing them on the market without submitting the necessary applications to amend or extend the marketing authorisation.*
We hope you find this helpful.
On behalf of
Juan Garcia Burgos
Head of Public and Stakeholder Engagement Department
__
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**_____________________________________________________**
**We received your question(s) on**:27/11/2023
**Subject of your enquiry**:(MC-REH)Questions regarding the Rapporteur’s Rolling Review assessment report of 19.11.2020 [#293382]
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