Investigational New Drug (IND) application
An Investigational New Drug (IND) application is the regulatory submission to the US Food and Drug Administration under 21 CFR Part 312 that a sponsor must file before shipping an unapproved drug across state lines and administering it to humans in a clinical trial. It is the US counterpart of the EU clinical trial application under the CTR.
An IND contains animal pharmacology and toxicology data, manufacturing information (CMC), clinical protocols, investigator information and the investigator's brochure. The FDA has 30 days to review the initial submission; if it does not impose a clinical hold, the trial may proceed. The IND remains open throughout development, with protocol amendments, safety reports, and annual reports submitted against it. Commercial INDs are distinguished from research INDs and from expanded-access INDs for treatment use.
For European sponsors, an IND brings EU trial data within the FDA's reach: individual patient data in SDTM and ADaM format, safety reports and, during Bioresearch Monitoring inspections, source documents at EU sites. These disclosures to a US federal agency are international transfers under the GDPR without an adequacy decision, generally justified under Art. 49(1)(d), and must be disclosed to participants in the informed consent form. Conversely, US sites enrolled under an IND in an EU-sponsored trial operate under HIPAA and the Common Rule, requiring a HIPAA authorisation in the consent package.
No. An IND supports investigational use under the applicable US requirements; it is not marketing approval. The submission provides information on areas such as manufacturing, non-clinical safety and the proposed clinical investigation. Keep the investigational pathway separate from the later evidence and application needed to seek commercial authorisation.
