[Hybrid medicines in France. Hybrid medicines: Genesis and legal framework in Europe and in France]

Abstract

Hybrid medicines are defined as medicines that do not fill generic medicines' definition, forming a medicines group that stands half-way between reference medicinal products and generic medicines. The term "hybrid" was introduced in France in 2018, but the concept has existed for some fifteen years in Community legislation. The aim of this work is to expose hybrid medicines' legal framework, in Europe and in France. Hybrid medicines' European legal framework specifies in a guide of the European Medicines Agency, marketing authorization procedures that can be used for hybrid medicines, and what is required for marketing authorization applications. In France, a register of hybrid medicines' groups has been created, and registration procedures were specified in a decree at the end of 2019. Legal texts also underlined that substitution within hybrid medicines' group would be possible for some specific medical cases. Decrees specifying hybrid medicines' groups list and specific medical cases allowing substitution, are not appeared yet at the end of February 2021. Moreover, some elements have never been raised, particularly medical and economic assessment modalities.

Keywords: Cadre juridique; Code de la santé publique; Dossier d’autorisation de mise sur le marché; French public health code; Hybrid medicines; Hybrid medicines groups’ register; Legal framework; Marketing authorization applications; Médicaments hybrides; Registre des groupes hybrides.