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Term of the Day

Natural history study

A natural history study is a preplanned observational study intended to track the course of a disease over time, identifying demographic, genetic, environmental and other variables that correlate with its development and outcomes in the absence of intervention, or under standard of care. Designs may be retrospective (chart review of existing records) or prospective (longitudinal follow-up of a cohort or registry).

Natural history data is particularly important in rare and paediatric diseases, where randomised placebo-controlled trials may be infeasible or unethical. The FDA (guidance on rare disease natural history studies, 2019) and the EMA accept well-designed natural history studies to define endpoints and biomarkers, identify patient subgroups, estimate sample sizes and, in some cases, serve as external or historical control arms for single-arm trials supporting orphan products.

Because they are non-interventional, natural history studies fall outside the CTR and are governed by national law (for example France's MR-003 or MR-004 reference methodologies) and by the GDPR. They typically involve secondary use of medical records, long-term follow-up, genetic data and small populations in which anonymisation is rarely achievable, so pseudonymisation, a DPIA and a robust research legal basis under Art. 9(2)(j) are essential. Registries maintained by patient organisations or academic consortia raise additional questions of joint controllership and data access governance.

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Auxiliary medicinal product

An auxiliary medicinal product (AxMP) is a medicinal product used for the needs of a clinical trial as described in the protocol, but not as an investigational medicinal product (Art. 2(2)(8) EU Clinical Trials Regulation 536/2014). The term replaces the older "non-investigational medicinal product" (NIMP) used under Directive 2001/20/EC.

Typical examples are background or rescue medication given to all arms, challenge agents used to provoke a physiological response, diagnostic agents used to assess endpoints, and concomitant treatments required by the protocol. AxMPs may be authorised or unauthorised; unauthorised AxMPs require a simplified dossier in the CTIS application, and their labelling and traceability follow Chapter X of the Regulation and the Commission's AxMP guideline.

Data on AxMP administration is recorded in the eCRF and forms part of the trial's health data. It is handled under the same legal basis, retention (25 years for the trial master file under Art. 58 CTR) and pseudonymisation rules as the rest of the trial dataset.

Is a placebo an auxiliary medicinal product under the EU CTR?

No. A placebo used as a reference in a clinical trial falls within the definition of an investigational medicinal product. An auxiliary medicinal product serves the protocol’s needs without being an IMP, for example certain rescue treatments. Classify each product by its role in the study before preparing the relevant documentation.