Clinical trials

An 'unapproved' therapeutic good for the purposes of the CTN and CTA schemes includes:

• any medicine not included in the Australian Register of Therapeutic Goods (ARTG), such as any new formulation, strength or size, dosage form, name, indications, directions for use or type of container of a medicine already in the ARTG
• any medical device (including an in vitro diagnostic device (IVD)) not included in the ARTG, such as any new sponsor, manufacturer, device nomenclature system code, classification or unique product identifier (for certain classes of medical devices only) of a medical device already in the ARTG
  • any in-house IVD medical device, used for the purpose of a clinical trial, where the laboratory providing the in-house IVD is unable to comply with the regulatory requirements for in-house IVDs
• any biological not included in the ARTG such as:
  • any new applicable standards, intended clinical use or principal manufacturer of a Class 1 or 2 biological already in the ARTG
  • any new product name, dosage form, formulation or composition, therapeutic indication, type of container or principal manufacturer of a Class 3 or 4 biological already in the ARTG
• therapeutic goods already included in the ARTG to be used in a manner not covered by the existing entry in the ARTG.

The TGA administers two pathways for clinical trials, the Clinical Trials Notification (CTN) and Clinical Trials Approval (CTA) schemes. These provide an avenue through which 'unapproved' therapeutic goods may be lawfully supplied for use solely for experimental purposes in humans.

The choice of which route to use (CTN or CTA) lies firstly with the Australian clinical trial sponsor and then with the Human Research Ethics Committee (HREC) that approves the protocol.

The CTA route is generally designed for high-risk or novel treatments where there is no or limited knowledge of safety. For medical device trials, the CTA scheme may be more appropriate where the experimental device introduces new technology, new material or a new treatment concept which has not been evaluated previously in clinical trials in any country. The CTA scheme should also be considered for medical devices that pose a risk of serious patient harm.

The determining factor for an HREC is whether the committee has access to appropriate scientific and technical expertise in order to assess the safety of the product.

However, under the Australian regulatory framework for biologicals certain Class 4 biologicals are not able to be supplied under the CTN Scheme and must be submitted under the CTA scheme.

For assistance in determining whether the CTN or the CTA scheme is most appropriate for a clinical trial, please see Which clinical trial scheme should I choose?.

Sponsors should notify us of trial completion once the clinical trial-related activity afforded by a CTN exemption or CTA approval is no longer required. It is, however, the responsibility of the sponsor to determine when the exemption or approval is no longer required. Notification of completion of a clinical trial should be made only after the trial has been completed at all sites. It is not necessary to notify completion dates for individual trial sites.

The online CTN should be used to submit a completion advice to us. Please refer to the Clinical trial notification (CTN) form: User guide for further information.

The sponsor of a trial can be an individual, company, institution, or organisation which takes responsibility for the initiation, management, and/or financing of a clinical trial.

The type of sponsor will vary from trial to trial, depending on who takes overall responsibility for the conduct of the trial. If the investigator initiates and organises the trial, he or she is defined as the sponsor of the trial and will be responsible for the sponsor's functions.

The sponsor of the trial must be a legal Australian entity. An overseas company, person or entity, for the purpose of the Australian legislation, is not the 'sponsor' of the trial in Australia.

The Australian clinical trial sponsor is responsible for submitting the CTN or CTA.

The clinical trial sponsor's responsibilities in relation to Good Clinical Practice (GCP) are set out in section 5 of the ICH Guideline for Good Clinical Practice with TGA annotations. The clinical trial sponsor must also comply with the requirements of the therapeutic goods legislation as well as any other Commonwealth or state/territory legislation in relation to clinical trials and the supply of therapeutic goods.

The Australian sponsor of a clinical trial is also responsible for safety reporting. The guidance document Safety monitoring and reporting in clinical trials involving therapeutic goods addresses safety monitoring and reporting requirements for investigational products in Australia.

A sponsor may transfer any or all of the sponsor's trial-related duties and functions, including adverse drug reaction reporting, to a Contract Research Organisation (CRO). However, please note that the ultimate responsibility resides with the trial sponsor.

To submit CTNs online, you will need access to our secure online TGA Business Services (TBS) site. This applies to organisations that already have a TGA client identification number (Client ID), as well as new organisations.

If your organisation:

• already has a TGA client ID and online access to TBS - please see your organisation's TBS administrator who can add you as a user.
• has a TGA Client ID without online access to TBS - please nominate an administrator via the Organisation details form to gain online access to TBS.
• does not have a TGA Client ID - go to TGA Business Services: Getting started with the TGA for information and forms to obtain a new Client ID and online access to TBS.

Additional information for using the TBS site can be found at TGA Business Services - How to use the site. Any further questions can be directed to the TBS Helpdesk at ebs@tga.gov.au or 1800 010 624.

We have provided a step-by step Clinical Trial Notification (CTN) form: User guide.

If you experience any difficulties using the online CTN form, please contact the clinical trials team at clinical.trials@health.gov.au or contact us. 

If you have prematurely submitted a CTN and need to correct administrative errors, you may request that we 'push-back' the notification. Such requests should be sent via email to the clinical trials team at clinical.trials@health.gov.au.

If any details of your trial have changed after the CTN has been processed, you need to submit a variation using the online portal. See the Varying trial details section of the Clinical Trial Notification (CTN) form: User guide for further information.

Please note that certain variations to a previously notified CTN incur a fee.

Any changes to details notified in the online CTN form should be updated and submitted to us. See the Varying trial details section of the Clinical Trial Notification (CTN) form: User guide for guidance on how to vary your online CTN.

The target time to process online CTNs is 5-7 working days; however we endeavour to process the notification as soon as possible. Please note that this timeframe does not include the time taken for TGA finance to match the payment (if required) to your submission.

You can track the status of your CTN by logging onto the TBS online portal. Refer to the section How to check the status of your CTN in the Clinical Trial Notification (CTN) form: User guide.

We will accept CTN form submissions while the sponsor is obtaining the necessary endorsements. However, it is the responsibility of the sponsor to ensure that all relevant approvals are in place before commencement of the trial.

We encourage all parties to be in agreement as to when the CTN form should be submitted.

The therapeutic goods legislation requires that the trial be run with appropriate governance in place and in accordance with the ICH Guideline for Good Clinical Practice (GCP) with TGA annotations. Section 8.2 of these guidelines outlines the documents and signed agreements that should be on file before the clinical phase of the trial commences.

The clinical trial sponsor must acknowledge that the goods only remain exempt so long as:

• appropriate advice has been received from a Human Research Ethics Committee
• the trial is conducted in accordance with the:
  • ICH Guideline for Good Clinical Practice (GCP) with TGA annotations
  • National Statement on Ethical Conduct in Human Research (published by the National Health and Medical Research Council).

As soon as the requirements set out under Item 3 of Schedule 5A of the Therapeutic Goods Regulations 1990 (the Regulations) and Item 2.3 of Schedule 4 of the Therapeutic Goods (Medical Devices) Regulations 2002 have been met (i.e. submission of the online CTN form with payment of the relevant fee to the TGA), the clinical trial is deemed to have been notified.

Once this occurs, the exemption under Section 18(1), 32CA(2) and 41HA of the Therapeutic Goods Act 1989 (the Act) comes into effect, and the sponsor can supply the goods.

The TGA does not send acknowledgment letters by email as this information can be viewed and printed via your online portal and provide evidence that your clinical trial has been notified to the TGA.

Instructions on how to obtain these print-outs is available in the 'Printing' section of the Clinical Trial Notification (CTN) form: User guide. We advise clinical trial sponsors to obtain and save a print-out of the CTN form at each stage of the submission process.

When multiple generic products with the same active ingredient are used, trial sponsors do not need to enter each trade/brand name separately on the CTN. In addition, an existing CTN does not need to be varied if additional generic versions are used of already notified products.

Trial sponsors should include the following information in the 'Medicine Details' sub-form of the online CTN form:

A generic product is defined in the Therapeutic Goods Regulations 1990, as a medicine that, in comparison with a registered medicine:

1. has the same quantitative composition of therapeutically active substances, being substances of similar quality to those used in the registered medicine or previously registered medicine; and
2. has the same pharmaceutical form; and
3. is bioequivalent; and
4. has the same safety and efficacy properties

See the Submitting section of the Clinical Trial Notification (CTN) form: User guide, for further assistance.

See the Printing section of the Clinical Trial Notification (CTN) form: User guide, for further assistance.

You will need to allow pop-ups and clear your browser cache.

• Please try clearing your browser cache and allowing pop ups on your internet browser.
• If you need assistance, please email clinical.trials@health.gov.au.

If you receive an error message please email clinical.trials@health.gov.au and provide:

• A screen shot of the error message
• Your CTN application ID
• A short description of any steps you have taken to try and resolve the problem.

The current fees for clinical trials can be found in the TGA Schedule of fees and charges.

A fee is charged for a CTN submitted by a different sponsor as a result of transfer of sponsor responsibility.

A higher fee is applicable to applications for clinical trials under the CTA scheme due to the more complex nature of the evaluation process.

It is important to appreciate that the TGA cannot treat subgroups of trialists differently according to their ability to pay.

What generates a fee for a CTN

A fee is charged for the following:

• a new CTN
• a CTN submitted under a different sponsor entity
• certain variations to an existing CTN. The following variations to a previously notified trial will incur a fee:
  • addition of new site(s) to a previously notified trial.
  • change to previously notified therapeutic goods that creates separate and distinct goods
  • addition of a new therapeutic good to a previously notified trial.

The applicable fee is the same amount as the fee for a new CTN in the current financial year.

Certain variations to existing CTNs may incur a fee. The applicable fee is that of a new CTN as published in the schedule of fees and charges.

The following variations to a previously notified trial will incur a fee:

• addition of a new site(s) to a previously notified trial
• change to previously notified therapeutic goods that creates separate and distinct goods
• addition of a new therapeutic good to a previously notified trial.

If you submit a CTN variation that incurs a fee, an invoice will be sent via email to the submitter of the CTN and to the billing contact of your organisation as provided to TGA Business Services. Please submit the relevant payment to TGA Accounts Receivable as per the information on the TGA payment options web page. Credit card or account details should not be sent to the clinical trials team.

Once you have submitted your CTN an invoice will be sent via email to the submitter of the CTN and to the billing contact of your organisation as provided to TGA Business Services. If you have a 'financial role' you will also be able to view and print the invoice in the online portal.

We recommend that you wait for the invoice before making payment as this ensures that there are no delays in matching payment.

Payment may be submitted through a range of options as described in our Payment options web page.

Payment through the online payment portal is the preferred option. To make a payment of an invoice:

• Select 'Biller code 1 - Payment of Invoice' from the drop down menu
• Enter your Client Identification Number (as shown on your invoice)
• Enter your Invoice Number(as shown on your invoice)
• Enter an email address for Tax receipt
• Enter the amount to be paid (this should correspond to the amount on your invoice)
• Select your payment option and follow the online prompts

Therapeutic goods may be imported and held under the direct control of the sponsor until the goods are included in a notification made to us through the CTN scheme. The goods must be kept in a warehouse or other properly secured area. The term 'sponsor' in these circumstances refers to the sponsor of therapeutic goods (the importer) as opposed to the sponsor of the clinical trial.

In other words, the importer does not require approval from the TGA prior to importation of the clinical trial goods; however the trial must be notified to the TGA through the CTN scheme prior to supply of the goods to the trial sites.

Sponsors are advised to contact other relevant agencies as there may be further restrictions on importation imposed through other legislation such as the Customs (Prohibited Imports) Regulation 1956, the Biosecurity Act 2015 and the Environment Protection and Biodiversity Conservation Act 1999.

You will need to apply for the TGA approval to export therapeutic goods overseas for use in clinical trials. Application forms and guidance are available on the Application forms and guidance are available on the Import/export of unapproved therapeutic goods for experimental purposes page of our website.

The TGA has adopted the PIC/S Guide for Good Manufacturing Practice for Medicinal Products, with Annex 13 of this guide referring to the manufacture of investigational medicinal products. Labelling requirements are outlined under items 26-33.

We do not require Australian clinical trial product importers/manufacturers to provide six monthly reports under regulation 47B of the Therapeutic Goods Regulations 1990. We understand that there are difficulties in determining the exact numbers supplied to health practitioners due to factors such as blinding and shipping of clinical trial supplies on a per site basis.

It is important to note that we can, from time to time, require information or documents relating to the supply (including quantity) of therapeutic goods that are exempt under the CTN scheme or approved under the CTA scheme, under sections 31A, 31B, 32JE, 32JG, 41JD, and 41JE of the Therapeutic Goods Act 1989.

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