Investigational medicinal product (IMP)
An investigational medicinal product (IMP) means a medicinal product which is being tested or used as a reference, including as a placebo, in a clinical trial (Art. 2(2)(5) EU Clinical Trials Regulation 536/2014). The definition therefore covers the candidate drug itself, active comparators and placebos, whether or not the product already holds a marketing authorisation; an authorised product used outside its approved indication or formulation in a trial is also an IMP. Products used to support the trial without being tested are auxiliary medicinal products.
IMPs must be manufactured under good manufacturing practice (Chapter IX CTR and Commission Delegated Regulation (EU) 2017/1569), labelled according to Annex VI, released by a qualified person and traced from manufacturer through depots and sites to the subject, using systems such as IRT. Quality, non-clinical and clinical data on the IMP are compiled in the IMPD and summarised for investigators in the investigator's brochure. In the United States the equivalent concept is the investigational new drug governed by the IND regulations.
IMP accountability records link kit numbers to subject numbers and dispensing dates, which makes them pseudonymised personal data that must be retained in the trial master file for 25 years, protected against unauthorised unblinding, and covered by the trial's DPIA together with the supply-chain vendors involved.
