Research of Regulatory Science
LIAN Jia-ge, ZHU Meng-ya, CHEN Yi, HUANG Miao, JIA Tong, XIE Jin-ping, SHAO Rong
The production of biological products features extended supply chains and complex manufacturing processes. In the context of globalization, cross-border segmented production of bulk drug substances and finished drug products has emerged as an important model to enhance product accessibility and optimize resource allocation. To promote the high-quality development of the biopharmaceutical industry, the National Medical Products Administration (NMPA) launched a pilot program for segmented production of biological products in 2024, and the newly revised Regulations for the Implementation of the Drug Administration Law of the People's Republic of China in 2026 further clarified the conditional liberalization of drug segmented production at the institutional level. Against this background, the production of biological products has shifted from a traditional single-site model to a multi-site segmented production, posing new challenges to both the quality management system and the drug regulatory system. This study analyzes the quality risks and regulatory challenges of cross-border segmented production of biological products. Based on the ICH Q9 (R1) quality risk management framework, a risk assessment framework was developed spanning four dimensions: fundamental risks, technical risks, marketing authorization holder (MAH) responsibility risks, and regulatory risks. Targeted risk prevention and control measures are proposed accordingly. Furthermore, corresponding policy recommendations are put forward from two aspects: strengthening the primary responsibility of MAHs and enhancing the regulatory responsibility of drug regulatory authorities, so as to facilitate the orderly implementation of segmented production of biological products.