ABSTRACT
In vivo and/or in vitro bioequivalence (BE) testing is required for most generic drug products
submitted for marketing approval. A proposed generic drug product must be compared in vivo
and/or in vitro to the officially designated reference drug product. Harmonized BE criteria for
the interchangeability of pharmaceutical products address the issue of waivers for in vivo trials,
which are expensive and as recently concluded, not always discriminating enough to form the
sole basis of approval of interchangeability. As discussed below, the worldwide requirements to
demonstrate BE vary widely, mostly as a result of the ability of the regulatory authorities to
enforce such requirements, both from an economic as well as ethical perspective. Waiver for BE
testing therefore becomes a topic of great interest worldwide. Several consortiums have
debated this topic for years and a consensus has begun to develop on this topic. A large
number of policy documents address this topic and include the published Food and Drug
Administration (FDA) and International Conference on Harmonization (ICH) guidelines;
Health Canada’s Guideline on Preparation of Drug Identification Number (DIN) Submissions;
the World Health Organization (WHO) document (1999) entitled “Marketing Authorization of
Pharmaceutical Products with Special Reference to Multisource (Generic) Products: A Manual
for Drug Regulatory Authorities; Multisource (Generic) Pharmaceutical Products: Guidelines
on Registration Requirements to Establish Interchangeability”; Note for Guidance on the
Investigation of Bioavailability and Bioequivalence, Committee for Proprietary Medicinal
Products (CPMP) (https://www.emea.eu.int/pdfs/human/ewp/140198en.pdf), 26 July 2001
(CPMP/EWP/QWP/98), Pan-American Network on Regulatory Harmonization: Bioavail-
ability and Bioequivalence Working Group 2004.