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Which animal species did regulators accept for approved cell therapies?

From the FDA and EMA reviews of all 27 approved cell therapies. Each answer links to the regulator's own sentence.

Check my plan against these
Short answer
15 of 27 approved cell therapies ran pivotal tox in: no relevant species.
Monkey + rodent2/27
Rodent only5/27
Other species5/27
No relevant species15/27

Precedent by precedent

27 approved cell therapies, with the reviewers' own words.

Abecma

idecabtagene vicleucel · BCMA CAR-T
Species
No relevant species; NSG mouse xenografts and in vitro only
“The PK and biodistribution of ide-cel were evaluated in NSG mice with and without BCMA+ xenografts.”
✓ VerifiedEMA assessment report, p. 42Source ↗
Why that species
Human autologous T cells do not engraft in immunocompetent animals; no representative models
“Ide-cel comprises engineered human T cells, therefore there are no representative in vitro assays, ex vivo models, or in vivo models that can accurately address the toxicological characteristics of the human product.”
✓ VerifiedEMA assessment report, p. 47Source ↗

Alofisel

darvadstrocel · Allogeneic adipose MSC
Species
Immunocompromised athymic nude rats (GLP); nude mice for tumourigenicity
“The applicant has chosen immunocompromised athymic rats to perform the biodistribution, toxicology and tumourigenicity studies.”
✓ VerifiedEMA assessment report, p. 19Source ↗
Why that species
Athymic rats minimise rejection of human cells and extend persistence; immunocompetent rats rejected the cells
“in order to minimize the immune recognition and potential rejection of human eASC in the experimental animal models and to extend Cx601 persistence”
✓ VerifiedEMA assessment report, p. 19Source ↗

Amtagvi

lifileucel · TIL therapy
Species
No animal studies with product; published murine and human TIL literature only
“No nonclinical studies were conducted with AMTAGVI. Instead, the applicant cited published nonclinical data evaluating similar murine and human tumor-derived T lymphocytes to provide support for AMTAGVI.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Why that species
Omission of tox studies accepted given product characteristics and biological activity (autologous unmodified T cells)
“No toxicology studies were conducted for AMTAGVI. Given the characteristics and biological activity of AMTAGVI, this omission is acceptable.”
✓ VerifiedFDA pharmacology/toxicology review, p. 13Source ↗

Aucatzyl

obecabtagene autoleucel · CD19 CAR-T
Species
No relevant species; no in vivo tox. NSG xenograft (pharmacology) and human tissue cross-reactivity only
“Per the applicant, conventional nonclinical toxicology studies were not conducted because they do not yield clinically relevant information for a CAR T cell product.”
✓ VerifiedFDA pharmacology/toxicology review, p. 9Source ↗
Why that species
No pharmacologically responsive species; human autologous T cells will not engraft in immunocompetent animals; immunodeficient models uninformative
“Aucatzyl, a patient-specific product, is not appropriate for administration to immunocompetent animals, as the T cells will not engraft.”
✓ VerifiedEMA assessment report, p. 40Source ↗

Breyanzi

lisocabtagene maraleucel · CD19 CAR-T
Species
No relevant species; in vitro and NSG mouse xenograft only
“In particular, suitable animal models are not available for accurately assessing the non-clinical characteristics of a human cell-based product such as JCAR017.”
✓ VerifiedEMA assessment report, p. 37Source ↗
Why that species
FMC63 scFv binds human CD19 only; no mouse or NHP cross-reactivity
“The results support that JCAR017 is specific for human CD-19 binding and lacks species cross-reactivity, in particular towards mouse and non-human primate.”
✓ VerifiedEMA assessment report, p. 37Source ↗

Carvykti

ciltacabtagene autoleucel · BCMA CAR-T
Species
No relevant species; NCG mouse xenografts, non-GLP NHP pilot with autologous NHP CAR-T
“Therefore, animal studies evaluating the safety profile of CARVYKTI™ were limited due to lack of a pharmacologically relevant animal species.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Why that species
Binding domain does not bind mouse or NHP BCMA
“In vitro data indicate that does not significantly bind to recombinant mouse or NHP BCMA expressed on cells.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

ChondroCelect

characterised viable autologous cartilage cells · Autologous chondrocytes
Species
Nude mouse (ectopic), sheep and goat (orthotopic); non-GLP combined PD/PK/tox
“Non-clinical studies were performed as combined pharmacodynamic / pharmacokinetic (distribution) / toxicological studies in the ectopic mouse (nu/nu model) and in orthotopic models in sheep and goats.”
✓ VerifiedEMA assessment report, p. 10Source ↗
Why that species
Orthotopic large-animal cartilage defect models; nude mice to avoid rejection of human cells
“orthotropic animal model showed that implantation of human or allogeneic chondrocytes causes an immune response to the CBMP, resulting in poor repair.”
✓ VerifiedEMA assessment report, p. 13Source ↗

Ebvallo

tabelecleucel · EBV-specific allogeneic T cells
Species
SCID mice (EBV+ lymphoma xenograft, literature/PD); no tox species
“Safety pharmacology studies were not conducted due to the species-specific nature of tabelecleucel and the limited applicability of non-human toxicology models.”
✓ VerifiedEMA assessment report, p. 27Source ↗
Why that species
Species-specific HLA-restricted human T cell product; SCID mice permit human lymphocyte engraftment
“Because SCID mice are unable to generate functional lymphocytes, engraftment and growth of human lymphocytes and several human tumours are possible.”
✓ VerifiedEMA assessment report, p. 26Source ↗

Encelto

revakinagene taroretcel · CNTF (encapsulated RPE cell implant)
Species
Minipig, pig and rabbit (ocular tox/PK); rcd1 dog for pharmacology; rat and rabbit for rhCNTF DART
“The effect of long-term ITV implantation of NT-501 was evaluated in a 3-part toxicology study in 4–8-month-old minipigs, 4–10-year-old pigs”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Why that species
Disease-relevant animal models support CNTF photoreceptor protection; no explicit species rationale for tox species
“Histopathologic studies in naturally occurring and genetically engineered animal models of photoreceptor dysfunction that phenotypically model retinitis pigmentosa support a role for rhCNTF”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗

Gintuit

allogeneic cultured keratinocytes and fibroblasts in bovine collagen · Allogeneic keratinocytes + fibroblasts
Species
Athymic (nude) mice for pharmacology; rabbits, guinea pigs, mice for biocompatibility
“Species: Athymic mice, 6-8 weeks old; the number, strain and sex were not provided in the study report”
✓ VerifiedFDA pharmacology/toxicology review, p. 17Source ↗
Why that species
Immunodeficient mice used so human cells could engraft and persist; no species rationale stated
“The transplanted Apligraf® remained durable, as demonstrated by the persistence of human keratinocytes and fibroblasts, for at least one year in the nude mice.”
✓ VerifiedFDA pharmacology/toxicology review, p. 48Source ↗

Holoclar

autologous corneal epithelial cells containing limbal stem cells · Autologous limbal stem cells
Species
No animal species; abridged programme of in vitro tumorigenicity assays and literature
“Conventional non-clinical studies were generally not considered appropriate for Holoclar as a cell-based medicinal product (CBMP).”
✓ VerifiedEMA assessment report, p. 17Source ↗
Why that species
Lack of relevant animal models due to differences in ocular structure; xenograft and primate concerns
“the lack of relevant animal models due to differences in the ocular structure of most other mammals.”
✓ VerifiedEMA assessment report, p. 18Source ↗

Kymriah

tisagenlecleucel · CD19 CAR-T
Species
No relevant species; immunodeficient mouse B-ALL xenograft (non-GLP) only
“The absence of GLP compliance is acceptable since standard single or repeat-dose toxicity studies could not be performed due to lack of a relevant animal model.”
✓ VerifiedEMA assessment report, p. 28Source ↗
Why that species
Patient-specific human T-cell product cannot be given to immunocompetent animals
“The lack of single-dose toxicity studies is acceptable, since tisagenlecleucel is a patient specific product, which is not appropriate to administer to immune competent animals.”
✓ VerifiedEMA assessment report, p. 40Source ↗

Lantidra

donislecel · Allogeneic pancreatic islets
Species
No studies with product; literature only (diabetic mice, rats, NHP, pigs)
“No nonclinical studies were conducted with LANTIDRA.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Why that species
Published diabetic rodent and NHP islet transplant models used to support activity, liver distribution and need for immunosuppression
“The findings of these studies support inclusion of immunosuppression as a critical component for successful islet engraftment and survival following transplant in diabetic animals.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Laviv

azficel-T · Autologous fibroblasts
Species
No preclinical or toxicology studies conducted with the product
“No preclinical studies were conducted with this product.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Why that species
No suitable animal model for rhytids; prior human commercial experience cited instead
“The BLA states that due to this previous commercial experience in humans, and due to the lack of a”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

MACI

autologous cultured chondrocytes on porcine collagen membrane · Autologous chondrocytes
Species
Rabbit and horse, with analogous MACI (species-matched autologous cells on ACI-Maix)
“Studies conducted in horses and rabbits compared ACI-Maix or empty defects to analogous products consisting of ACI-Maix seeded with rabbit or horse cells.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Why that species
Critical-sized knee/stifle defect models in load-bearing species; no further rationale stated
“Implantation of MACI secured with a commercially available fibrin sealant resulted in improved repair of critical-sized defects in the knee/stifle”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Omisirge

omidubicel · Expanded cord blood HPC
Species
Immunodeficient irradiated NOD/SCID mouse only (xenogeneic human cells)
“In vivo pharmacology, pharmacokinetic, and toxicology studies were conducted to evaluate the activity, distribution, and safety of the product in immunocompromised, irradiated mice.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Why that species
NOD/SCID chosen for human cell engraftment over other strain in pilot; limited relevance to human homing
“Results showed that NOD/SCID mice were preferable over mice based on cell engraftment levels.”
✓ VerifiedFDA pharmacology/toxicology review, p. 30Source ↗

Provenge

sipuleucel-T · PAP-GM-CSF (autologous APC)
Species
No conventional tox species; rat and mouse proof-of-concept studies with rodent surrogate products
“The immunogenicity and anti-tumour properties of these surrogate products were evaluated in rats and mice.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Why that species
Autologous human product cannot be tested in animals; species-specific rodent equivalents used (rat/mouse PAP and GM-CSF)
“Animal models using species-specific variations of the human cell therapy product have been used.”
✓ VerifiedEMA assessment report, p. 25Source ↗

Rethymic

allogeneic processed thymus tissue · Allogeneic thymus tissue
Species
No relevant species; nude rat pharmacology studies only, no tox
“Based on the acceptable clinical safety profile of RVT-802 and the lack of relevant animal species/models, no nonclinical toxicology studies with RVT-802 were performed.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Why that species
Nude rats used to model engraftment and thymopoiesis of allogeneic thymus; no relevant tox species
“Studies were conducted in nude rats to to identify potentially optimal culture conditions of allogeneic neonatal thymus that result in engraftment and development of an endogenous T cell population”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Ryoncil

remestemcel-L · Allogeneic BM-MSC
Species
Rat, baboon and pig using species-specific surrogate ceMSC
“The nonclinical program utilized multiple surrogate animal-derived ceMSC manufactured similarly to the clinical product.”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗
Why that species
Species-matched allogeneic MSC model allogeneic administration and recipient immune interaction
“This approach was taken to model administration of allogeneic ceMSCs in humans and evaluate the interactions between the cell product and recipient immune system.”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗

Spherox

spheroids of autologous matrix-associated chondrocytes · Autologous chondrocyte spheroids
Species
Immunodeficient (SCID/NSG) mice, Goettingen minipig, Merino sheep; no conventional tox
“Comparative analyses of chondrocytes from different species showed that only a limited number of animals including Göttinger mini-pig and Merino sheep were capable of producing stable spheroids.”
✓ VerifiedEMA assessment report, p. 29Source ↗
Why that species
Only minipig and Merino sheep chondrocytes form stable spheroids; large orthotopic joint models
“These species were then selected for proof-of-concept studies.”
✓ VerifiedEMA assessment report, p. 29Source ↗

StrataGraft

allogeneic cultured keratinocytes and dermal fibroblasts in murine collagen · Allogeneic keratinocytes + fibroblasts
Species
Athymic nude mice only (immunodeficient wound model)
“The following toxicology study was conducted to evaluate the safety profile of STRATAGRAFT® following administration in an athymic (immunodeficient) murine wound model:”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗
Why that species
Human cells would elicit xenogeneic response in immunocompetent animals; nude mice have reduced T-cell response
“STRATAGRAFT® is composed of human cells, thus the potential for elicitation of a xenogeneic response following administration in immune competent animals exists.”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗

Tecartus

brexucabtagene autoleucel · CD19 CAR-T
Species
No relevant species; in vitro and syngeneic mouse surrogate CAR-T only
“Since the anti-CD19 scFv utilised for KTE-X19 does only recognise human CD19, a murine surrogate model was engineered for non-clinical proof-of-concept studies in immune competent mice.”
✓ VerifiedEMA assessment report, p. 32Source ↗
Why that species
scFv recognizes only human CD19; no relevant animal model
“Similar as the pharmacology evaluation, also the non-clinical safety evaluation of KTE-X19 has been severely limited due to the lack of a relevant animal model.”
✓ VerifiedEMA assessment report, p. 35Source ↗

Tecelra

afamitresgene autoleucel · MAGE-A4 TCR-T
Species
No relevant species; in vitro cross-reactivity/alloreactivity and murine xenograft pharmacology only
“Standard in vivo single-dose or repeat-dose toxicity studies were not conducted with afamitresgene autoleucel due to the lack of appropriate animal models for testing of human TCR engineered T-cells.”
✓ VerifiedFDA multi-discipline review, p. 39Source ↗
Why that species
HLA-restricted human TCR: MHC mismatch with animals; humanized mice develop lethal xeno-GvHD within 8 weeks
“Because afamitresgene autoleucel is an autologous engineered-TCR T-cell therapy, there is a mismatch of MHC antigens between animal and human TCRs, so specificity cannot be assessed.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗

Tregzi

allogeneic Treg immunotherapy with HSPC and T cells (Orca-T) · Allogeneic Treg + HSPC + Tcon
Species
No tox species; sublethally irradiated immunodeficient mice (xenogeneic GVHD proof-of-concept) plus published murine literature
“In the applicant’s POC studies using xenogeneic models, co-administration of human donor Tregs with Tcons demonstrated dose-dependent GVHD inhibition in sub-lethally irradiated immunodeficient mice.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Why that species
Immunodeficient mice allow human Tcon-induced xenogeneic GVHD and Treg mitigation; no relevant tox species stated
“evaluating the ability of human Tcons to induce xenogeneic GVHD”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Yescarta

axicabtagene ciloleucel · CD19 CAR-T
Species
No relevant species; syngeneic mouse lymphoma model with murine surrogate CAR-T (published, non-GLP)
“Single-dose toxicology studies in animals were not performed by the Applicant due to the lack of a relevant animal model.”
✓ VerifiedEMA assessment report, p. 27Source ↗
Why that species
FMC63 scFv recognizes only human CD19; engineered human T cells not modelable in animals
“Since the anti-CD19 scFv utilized for KTE-C19 does only recognize human CD19, a murine surrogate was engineered for non-clinical proof-of-concept studies in immune competent mice.”
✓ VerifiedEMA assessment report, p. 30Source ↗

Zalmoxis

allogeneic T cells modified with HSV-TK / dLNGFR (nalotimagene carmaleucel) · HSV-TK suicide-gene T cells
Species
Immunodeficient NOD/SCID mice (GvHD xenograft models); no conventional tox species
“Two studies in two different GvHD animal models both based on the NOD/SCID system were performed to evaluate the PK and primary PD of MM-TK.”
✓ VerifiedEMA assessment report, p. 24Source ↗
Why that species
Product is species specific; NOD/SCID mice permit human T cell engraftment and GvHD readout
“The MM-TK DP is a species specific product and therefore standard carcinogenicity studies using rodents or non-human primates as described in the ICH guidelines are not appropriate.”
✓ VerifiedEMA assessment report, p. 22Source ↗

Zemcelpro

dorocubicel · UM171-expanded cord blood CD34+
Species
Female sub-lethally irradiated NSG mice (human cells); UM171 compound PK/tox in NSG mouse, rat, cynomolgus monkey
“All in vivo studies have been conducted with female NSG mice.”
✓ VerifiedEMA assessment report, p. 40Source ↗
Why that species
UM171 has no activity on mouse HSCs; human cells in immunocompromised NSG mice needed (homologous murine product not possible)
“because the applicant explained that UM171 had no activity on mouse HSCs (i.e. homologous murine product not possible).”
✓ VerifiedEMA assessment report, p. 30Source ↗