Participation in SoHO and ATMP public consultations: a fragmented institutional landscape

Abstract In the European Union (EU), the recent adoption of the Substances of Human Origin (SoHO) Regulation in June 2024 brings into force new harmonised rules for human cells, tissues and blood. This legislation interacts with the pre-existing Advanced Therapy Medicinal Products (ATMP) Regulation....

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Main Authors: Michael Morrison, Valentin Brunel, Aurélie Mahalatchimy
Format: Article
Language:English
Published: Springer Nature 2025-02-01
Series:Humanities & Social Sciences Communications
Online Access:https://doi.org/10.1057/s41599-025-04552-1
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author Michael Morrison
Valentin Brunel
Aurélie Mahalatchimy
author_facet Michael Morrison
Valentin Brunel
Aurélie Mahalatchimy
author_sort Michael Morrison
collection DOAJ
description Abstract In the European Union (EU), the recent adoption of the Substances of Human Origin (SoHO) Regulation in June 2024 brings into force new harmonised rules for human cells, tissues and blood. This legislation interacts with the pre-existing Advanced Therapy Medicinal Products (ATMP) Regulation. This paper looks at the recent EU public consultations on the proposed SoHO Regulation and compares them with the prior consultations on the ATMP Regulation given the interplay between these two Acts. Information on each contributor to the three most recent consultations on SoHO and the two available consultations on the ATMP was collected, analysed, and used to develop a novel typology of entities participating in the consultations. This data set included the country of origin of each entity making a contribution and the type of entity involved (Academic/Research institutions, National Bodies, Companies, Business organizations, Patient and Consumer organizations, Learned Societies, Individual citizens, Networks/Innovation organizations, and Other Non-Governmental Organizations). The results show that the SoHO consultations attracted a far greater total volume of participants and displayed a greater variety of organizations from more distinct countries compared to the ATMP consultations. The most significant finding is the very low overlap in organisations making a contribution to both a SoHO and an ATMP consultations. This strongly suggests that there is significant institutional fragmentation between organisations collecting human biomaterials and organisations developing ATMP for market. Given that collection of biomaterials is a necessary first step in the development of most ATMP, European policy makers wishing to support ‘homegrown’ innovation with ATMP should give greater consideration to building better links between organisations collecting biomaterials and ATMP developers.
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spelling doaj-art-f7e409da5be24f22a8e06dd68fa1cf1c2025-08-20T02:16:40ZengSpringer NatureHumanities & Social Sciences Communications2662-99922025-02-0112111410.1057/s41599-025-04552-1Participation in SoHO and ATMP public consultations: a fragmented institutional landscapeMichael Morrison0Valentin Brunel1Aurélie Mahalatchimy2Centre for Health, Law and Emerging Technologies, Faculty of Law, University of OxfordMaison des Sciences de l’Homme SUD, Institut de Recherche pour le DéveloppementAix Marseille Univ, CNRS, DICE, CERICAbstract In the European Union (EU), the recent adoption of the Substances of Human Origin (SoHO) Regulation in June 2024 brings into force new harmonised rules for human cells, tissues and blood. This legislation interacts with the pre-existing Advanced Therapy Medicinal Products (ATMP) Regulation. This paper looks at the recent EU public consultations on the proposed SoHO Regulation and compares them with the prior consultations on the ATMP Regulation given the interplay between these two Acts. Information on each contributor to the three most recent consultations on SoHO and the two available consultations on the ATMP was collected, analysed, and used to develop a novel typology of entities participating in the consultations. This data set included the country of origin of each entity making a contribution and the type of entity involved (Academic/Research institutions, National Bodies, Companies, Business organizations, Patient and Consumer organizations, Learned Societies, Individual citizens, Networks/Innovation organizations, and Other Non-Governmental Organizations). The results show that the SoHO consultations attracted a far greater total volume of participants and displayed a greater variety of organizations from more distinct countries compared to the ATMP consultations. The most significant finding is the very low overlap in organisations making a contribution to both a SoHO and an ATMP consultations. This strongly suggests that there is significant institutional fragmentation between organisations collecting human biomaterials and organisations developing ATMP for market. Given that collection of biomaterials is a necessary first step in the development of most ATMP, European policy makers wishing to support ‘homegrown’ innovation with ATMP should give greater consideration to building better links between organisations collecting biomaterials and ATMP developers.https://doi.org/10.1057/s41599-025-04552-1
spellingShingle Michael Morrison
Valentin Brunel
Aurélie Mahalatchimy
Participation in SoHO and ATMP public consultations: a fragmented institutional landscape
Humanities & Social Sciences Communications
title Participation in SoHO and ATMP public consultations: a fragmented institutional landscape
title_full Participation in SoHO and ATMP public consultations: a fragmented institutional landscape
title_fullStr Participation in SoHO and ATMP public consultations: a fragmented institutional landscape
title_full_unstemmed Participation in SoHO and ATMP public consultations: a fragmented institutional landscape
title_short Participation in SoHO and ATMP public consultations: a fragmented institutional landscape
title_sort participation in soho and atmp public consultations a fragmented institutional landscape
url https://doi.org/10.1057/s41599-025-04552-1
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