Can Improvements Be Made To The Readability of Package Leaflets?

We look at the possible changes that could be made to package leaflets to improve their comprehension and readability.

Directive 2001/83/EC, as amended, includes the following requirements in relation to the medicinal product package leaflet;

  • It must be written and designed to be clear and understandable
  • It shall reflect the results of consultations with target patient groups to ensure that it is legible, clear and easy to use.

The results of these assessments are required to be provided to the competent authority at the time of a marketing authorisation application (MAA) in module 1.3.4 of the dossier, but when is the best time to carry out the testing on the package leaflet to support an MAA?

Before submission of an MAA, the type of user consultation to be carried out may be discussed with the Agency / Reference Member State (RMS) to determine if a full test, a bridging report or focused testing is applicable.  If the User Test Outcome Report has not been included in the initial submission, the results of user consultation should be submitted as part of the answers to questions at Day 121 for mutual-recognition procedure applications. For applications via the decentralised procedure, the user consultation can be carried out within the clock-off period and results submitted with the response to the Day 105 list of questions.

If during the MAA assessment, comments have been made on the package leaflet, the user consultation should be performed on the updated package leaflet taking into account the comments received.  User testing aims to identify whether or not the information as presented in the package leaflet conveys the correct messages to those who read it. It is therefore preferable to test a more mature version of the leaflet.

In accordance with Article 59(4) of Directive 2001/83/EC as amended, the Commission published an assessment report last year on current shortcomings in the package leaflet (and summary of product characteristics (SmPC)) and how they could be improved. The initial deadline (January 2013) was delayed due to the need to obtain additional evidence through an external expert study.  As part of this report, outcomes and recommendations have been identified as follows. [1]

  • There should be more focus on improving the package leaflet rather than the SmPC. Language used is often too complex and the design and lay-out are not always user-friendly.
  • Consider amendments of Guidelines and QRD templates to enhance readability of package leaflet
  • Further improve the input from patients during the user testing process and the related methodology e.g. ensure that a sufficiently mature version of the package leaflet is user-tested.
  • Best practice examples of aspects of the package leaflet design could be made available for companies.
  • Explore the use of electronic media to provide the information included in the package leaflet (and SmPC) in the future (complementary to paper)
  • Potential introduction of the “key information” section with the objective to allow rapid identification key safety messages.

As per the Readability Guideline [2], if the package leaflet is well designed and clearly worded, this maximises the number of people who can use the information. The Commission and the European Medicines Agency will now work towards implementation of the above mentioned recommendations to better meet the needs of patients and healthcare professionals and support the safe and effective use of medicinal products.

If you would like to discuss a package leaflet related issue with any of our expert staff, then simply complete the webform below or call us on 00353 52 61 76706.

[1] REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL in accordance with Article 59(4) of Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the Community code relating to medicinal products for human use

[2] GUIDELINE ON THE READABILITY OF THE LABELLING AND PACKAGE LEAFLET OF MEDICINAL PRODUCTS FOR HUMAN USE Revision 1, 12 January 2009

About the Author
Eileen Shortiss
Senior Regulatory Affairs Advisor - Pharmacovigilance
Eileen Shortiss joined Acorn Regulatory in 2006. During her time with Acorn Regulatory, Eileen has worked on a vast array of projects for clients all over the world. Eileen is extensively involved with pharmacovigilance KPIs and driving continuous improvement measures across the department. Furthermore, she has considerable expertise and experience in the area of patient information leaflets. You can read other articles by Eileen Shortiss by clicking the link below.
Other articles by Eileen Shortiss