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2025 年 11 月 26 日

The EU’s Paediatric Regulation mandates that drug developers submit a Paediatric Investigation Plan (PIP) early in the development lifecycle, typically upon completion of Phase 1 pharmacokinetic (PK) studies. However, the European Medicines Agency (EMA) website gives somewhat more flexibility, requiring a submission before commencing phase 3 studies. While the intention is to ensure children receive timely access to new medicines, this early timing often creates significant friction between regulators and sponsors. Committing to a comprehensive development plan from birth to 18 based on limited adult safety and PK data frequently led to “unworkable or no longer appropriate” initial PIP decisions. This would then trigger a resource-intensive cycle of complex clinical development modifications. To resolve this conflict between early submission and scientific uncertainty, the European Medicines Agency (EMA) launched the stepwise Paediatric Investigation Plan (sPIP) pilot in February 2023.

The adaptive stepwise Paediatric Investigation Plan solution

The sPIP was reserved for exceptional cases where there was a lack of crucial information needed to define key plan elements, such as whether a clinical study is necessary for an entire age group. It was specifically suited for innovative products, like those that are first-in-disease for children.

The core mechanism involved submitting only a partial development program, conditional on the sponsor completing a full PIP once the necessary scientific evidence was generated against predefined, agreed-upon milestones. It is likely that this structured, staged approach will replace unpredictable revisions with a planned regulatory pathway.

Certara has already encountered the paediatric committee (PDCO) requesting a stepwise approach and supported clients in pediatric drug development strategy.

Permanent status and regulatory modernization

The sPIP is no longer a temporary experiment. Following a pilot phase designed for procedural learning—which was due for review upon the adoption of eight initial opinions —the concept has been cemented in the EU’s forward-looking regulatory strategy.

The proposal for the revision of the EU general pharmaceutical legislation (published April 2023) explicitly includes the new concept of a “step-wise PIP system”. Most definitively, the PDCO Work Plan 2025 lists the key objective: “To establish the stepwise PIP (sPIP) as a permanent procedure”.

This permanent shift is supported by broader regulatory modernization. The PDCO focuses on how Real-World Evidence (RWE) and advanced extrapolation can support assessments, methodologies that fit perfectly within the staged sPIP framework. Alongside this, the updated template for scientific document for paediatric investigation plan now includes new instructions for addressing extrapolation and implementation of the draft ICH M15 guidance ‘General Principles for Model-Informed Drug Development’.

While the final adoption of the EU’s new pharmaceutical legislation (likely to be implemented in member states sometime between 2028 and 2030) remains key for pediatrics, a critical question is whether the EMA and other regulators will apply the same stepwise, adaptive regulatory approach to the requirements set forth in the recently drafted ICH E21 guideline concerning the inclusion of pregnant and breastfeeding individuals in clinical trials.

This adaptive approach elevates the early PIP submission, transforming it from a rigid procedural requirement into a dynamic, structured regulatory pathway designed to accelerate complex, innovative pediatric drug development.

Do you need help crafting your PIP? Our clinical pharmacology consultants can help!

Justin Hay, PhD

Senior Director, Clinical Pharmacology Consulting, Co-Lead of Certara’s Rare and Neglected Innovation Engine

Dr. Hay joined Certara in 2022 with 25+ years of clinical pharmacology experience having started his career as Senior Clinical Scientist at the Centre for Human Drug Research (CHDR), Leiden. More recently he worked as Senior Pharmacokinetics Assessor and Deputy Unit Manager at the Medicine and Healthcare Products Regulatory Agency (MHRA), UK where he also had a leading role with the Access Consortium (Regulatory agencies of Australia, Canada, Singapore, Switzerland and UK).

Justin has also been a member of the EMA’s former Modelling and Simulation Working Party (MSWP). He has a special interest in biologics, CNS research, pain management and pediatric pharmacology. Justin has a PhD from the University of Adelaide, Australia.

Eva Berglund, PhD, Director, Clinical Pharmacology and Regulatory Strategy, Certara Drug Development Solutions
Eva Gil Berglund, PhD

Senior Director, Regulatory Strategy

Dr. Eva Gil Berglund is a pharmacist by training and has a PhD in Clinical Pharmacology, both from Uppsala University, Sweden. She has been a Clinical Pharmacology reviewer at the Swedish Medical Products Agency for over 20 years and a Senior Expert for 12 years, working with all types of molecules in marketing applications, clinical trials and scientific advice procedures in the EMA Network of National agencies. Eva has been working in all therapeutic areas and has extensive knowledge in antivirals, antibiotics, CNS active drugs, oncology, rheumatology, inhalation products etc.

Eva actively involved in drafting of several EU Clinical Pharmacology guidance documents and Rapporteur of several (drug-drug and drug-food interactions, PBPK, pediatrics, pharmacogenetics, etc.), been extensively involved in inter-regional harmonization activities and in the work of EMA working parties Pharmacokinetics Working Party and Paediatrics Working Party. Eva joined Certara in 2019 and provides her Clinical Pharmacology experience and Regulatory strategy knowledge in GAP analyses, regulatory stress tests and moc meetings, regulatory interactions, filing and clin pharm response support, pediatric submissions (PIP, PSP, new indications). Eva is part of the Clinical Pharmacology Regulatory Strategy team and also part of the Pediatric Centre of Excellence. Her inspiration is scientific development and its practical application, optimizing drug development, pushing regulatory science forward, and improving patient access to efficacious and safe drugs.

Paola Coppola, MSc

Director, Clinical Pharmacology and Translational Medicine

Paola Coppola is currently Director Clinical Pharmacology at Certara. She has 15+ years of clinical pharmacology and regulatory experience having worked as Senior Pharmacokinetics Assessor at the Medicines and Healthcare products Regulatory Agency (MHRA), UK and in a number of roles in Industry such as Head of Clinical Pharmacokinetics and Marketed Products Clinical Pharmacology Lead at AstraZeneca, UK, and Pharmacokinetics Scientist in Angelini, Italy. She has been an observer of the EMA PK Working Party and Modelling & Simulation Working Party.

Paola has extensive experience in early phase clinical trials and strong interest in the evaluation of PK in special populations such as pregnancy and pediatrics. Having worked on a MHRA project on the evaluation of PK in pregnancy in collaboration with The Bill & Melinda Gates Foundation, she has authored a number of publications and presentations on that matter. Paola is a member of the Clinical Pharmacology Regulatory Strategy team and of the Pediatric Center of Excellence at Certara. She obtained her MSc in Biological Sciences from the University Federico II of Naples, Italy and a Post graduate Master from the Business School ISTUD, Italy.

This blog was originally published in April 2023, and has been updated for accuracy.

常见问题解答

What is a Paediatric Investigation Plan (PIP)?

A Paediatric Investigation Plan (PIP) is a comprehensive development program that outlines how a pharmaceutical company intends to study and ensure the safety and efficacy of a medicine for use in children. The PIP details the measures and timelines for conducting pediatric studies, aiming to generate the necessary data to support the authorization of medicines for pediatric populations. In the European Union, the PIP is a regulatory requirement intended to ensure that children have timely access to appropriately tested medicines and to encourage the development of medicines specifically for pediatric use.

Does the United States FDA require sponsors to submit the equivalent of a PIP?

Yes, the FDA requires sponsors to submit a pediatric study plan (PSP). A PSP is a structured document that outlines the strategy and specific steps a sponsor intends to take to evaluate the safety, efficacy, and appropriate use of a drug or biologic in children. It typically includes proposed study designs, age-appropriate formulations, timelines, and considerations for ethical conduct in pediatric populations. The plan is developed to ensure that medicines are properly tested in children, addressing their unique medical needs and regulatory requirements.

How can model-informed drug development approaches be used to increase the efficiency of pediatric drug development?

Model-informed drug development (MIDD) significantly enhances the efficiency of pediatric drug development by utilizing existing data and advanced modeling techniques to minimize the need for large, dedicated clinical trials. By extrapolating efficacy and safety data from a reference population, MIDD predicts drug responses in a target population, often facilitating regulatory approval without separate Phase 3 studies. These approaches optimize dose selection using population and physiologically-based pharmacokinetic models, support efficient trial design through informed sample sizes and schedules and incorporate biomarkers or natural history data as surrogate endpoints to reduce placebo use and accelerate development. Regulatory agencies like the FDA routinely accept MIDD analyses to support dosing decisions, trial waivers, and expanded labeling, especially with early sponsor engagement through programs such as the FDA MIDD Pilot Program. Overall, MIDD offers a scientifically robust and ethical pathway to accelerate pediatric medicine development.

What do paediatric investigation plan (PIPs) waivers and modifications refer to?

Drug developers can request PIP modifications, waivers, and deferrals from the PDCO. A waiver exempts the sponsor from conducting pediatric clinical studies on an investigational therapy. A deferral allows the sponsor to delay conducting pediatric studies until after adult trials are completed. If a sponsor encounters difficulties or needs to change the PIP after it has been agreed upon with regulators, they can request modifications to it.

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