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Japan’s conditional approval pathway offers regenerative medicines earlier market access

Trends in Cell, Tissue, and Gene Therapies

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Japan continues to position itself as a global leader in regenerative medicine through its progressive regulatory framework tailored to the unique characteristics of cell, tissue, and gene therapy (CTGT) products. A cornerstone of this framework is the Conditional and Time-Limited Approval Pathway, established under the Pharmaceuticals and Medical Devices Act (PMD Act), which enables earlier market access for promising regenerative therapies based on preliminary clinical data.

The Conditional and Time-Limited Approval Pathway, which is similar to the accelerated approval pathway in the United States, allows Japan's Ministry of Health, Labour and Welfare (MHLW) to grant marketing approval for regenerative medicine products for a period of up to seven years, contingent upon confirmed safety and predicted efficacy. Developers must submit a robust post-marketing efficacy evaluation plan, with the understanding that full approval will require further data collection and reassessment.

Recent updates have reinforced Japan's commitment to balancing innovation with patient safety. The MHLW has issued new guidance clarifying the scope of products eligible for conditional and time-limited approval for regenerative medicine products, emphasizing the importance of heterogeneity in cell-based therapies and the need for statistically sound clinical trial designs.

Additionally, Japan has expanded its support for decentralized clinical trials and pediatric drug development, aligning its regulatory practices more closely with international standards.

Japan's regulatory authorities also continue to refine oversight mechanisms, including risk-based Good Clinical Practice (GCP) inspections and streamlined post-approval reporting for minor manufacturing changes. These reforms aim to reduce the country's historical drug lag and foster a more agile environment for the development of cutting-edge therapies including CTGT.

For global stakeholders, Japan offers a compelling regulatory landscape that supports early access, international collaboration, and long-term market sustainability. Legal and regulatory expertise is essential to navigate this evolving framework and capitalize on emerging opportunities in one of the world's most advanced health care markets.


Authored by Frederick Ch'en, Sayuri Mori, and Fumiko Ikeshiro

This article is the first in our new series, “Trends in Cell, Tissue, and Gene Therapies,” which aims to help you stay informed about the broad array of legal and regulatory issues affecting companies operating in the regenerative medicine space. From clinical studies, to obtaining patents, to scaling up manufacturing, our global team will discuss novel issues arising in all parts of the world, including unique deal-making, litigation, and inspections concerns for CTGT companies. Ensure you are subscribed to Our Thinking to receive these new insights weekly!

MHLW's “Guidance for Conditional and Time-Limited Approval for Regenerative Medical Products and the Development of Subsequent Efficacy Evaluation Plan” (PSB/MDED Notification No.0329-3) (see here)

Hakariya et al., “Japan's Conditional/Time-Limited Early Approval System in Regenerative Medicine: A Case Study of Rise and Falls of Autologous Skeletal Myoblast Sheets”, Clinical Pharmacology & Therapeutics, Volume 117, Issue 5, May 2025 (see here)

2025 Update: Japan's Pharma Regulation Trends (see here)

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