Regulatory Updates

Brexit

A list of select Brexit updates compiled by the ISPE Regulatory Quality Harmonization Committee (RQHC)’s Europe-Middle East-Africa Regional Focus Group.

May 2019 Update

• MHRA procedures for paediatric investigational plans in event of ‘No Deal’ BREXIT
• MHRA guidance on No Deal Brexit arrangements
  • MHRA guidance and publications on a possible no deal scenario
  • European authorities working to avoid shortages of medicines due to Brexit – questions and answers

• January 2019 Update
  • Brexit plan rejected by UK parliament 15th January
    • Next steps not yet clear
    • Could increase the chances of UK leaving on ‘no deal’ basis
  • UK – MHRA Release response to consultation on No Deal 
  • EC – In event of No Deal – Implementing the Commission’s Contingency Action Plan
• September 2018 Update
  • UK Government re. pharmaceutical company concern on no-deal BREXIT
    • Whilst  “good progress has been made in negotiations”, Government asking for a contingency planning approach
    • Additional 6w supply of medicines – ensuring continuity of supply
    • Continue to accept products that have been batch tested and release in accordance with EU rules (no further testing requirement)
  • EU turns down support request to manage against staff loss
  • EMA – simplified transfer approach for some MAAs affected by BREXIT
• August 2018 Update
  • EU – EMA plans to suspend activities as part of BREXIT management
  • EU – Practical guidance for medicinal products approved via MRP or DCP
  • MHRA - Release advisory on Brexit implementation
• May 2018 Update
  • Unclear if/how UK may secure associate membership of EMA
  • EC warns MAHs not to ‘wait and see’ re preparing for Brexit
  • EMA and member states complete redistribution of UKs portfolio of CP products
  • Ireland’s HPRA surveys Irish medtech sector on impact of Brexit
  • EMA -  Issue guidance on MPs approved by MRP / DCP
  • UK commit to EU clinical trial regulation post-Brexit
  • UK government report encourages alignment of pharma industry to EU regulations
• April 2018 Update
  • A 21 month transition period (March 29th to end of 2020) is agreed for BREXIT implementation.
    • What level of MHRA participation in EMA will be agreed ?
      • ‘limited’ ; ‘close alignment’ ?
        • The EU have stated that the UK’s ‘red lines’ on leaving the single market and customs union would ‘inevitably’ limit the alignment
    • Still more work to be done, including on activities of notified bodies (devices)
  • EC posts minutes and presentations from technical expert seminar (8th March) on pharmaceutical matters following BREXIT
    • 80 experts from 27 states. Meeting to inform experts about the ‘overall state of play’, the preparedness measures taken and collect expert perspectives on these measures and identify and discuss gaps / action plan.
    • Comments on the ‘wait and see’ approach by MAHs… need to act swiftly “considering as a baseline for preparedness the withdrawal date of 30th march 2019” (not the transition period)
    • Another technical seminar ‘may be convened’ Q2’18
  • UK Health and Social Care Committee life science recommendations
    • Main recommendation is that the UK and EU should aim to secure the ‘closest possible regulatory alignment’ – e.g. ‘close’ associate membership of the EMA
• March 2018 Update
  • Industry stakeholder meeting on Brexit and operation of the Centralised procedure for human medicinal products
  • EU -  Position paper calls for Agency powers to apply to EU during BREXIT transition
    • UK Parliamentary Health Committee warns pharma will step up contingency plans unless Brexit transition agreed soon
• February 2018 Update
  • MHRA - Update to pharmaceutical companies on exit preparations (16th January)
    • As part of MHRA and making a success of Brexit
  • Some items seen as highlights here –
    • EMA survey of pharma companies on BREXIT preparedness
    • BREXIT talks restart
      • Potential for a transitional period
    • UK views on remaining part of EMA
• January 2018 Update
  • Post Brexit Licensing and Supply
  • EU – Practical guidance for procedures related to BREXIT (centralised procedure)
  • HPRA – Brexit Guidance for Stakeholders

Regulations, Guidelines & Other Documents

A select list of recently updated regulations, guidelines and other documents compiled by the ISPE Regulatory Quality Harmonization Committee (RQHC)’s Europe-Middle East-Africa Regional Focus Group

May 2019 Update

• EU - Variations Guidance Updates with CMC / GMP significance
• EU - EC launches portal to ease transition to new regulations on Medical Devices and In vitro Diagnostic Devices
• EU - Medical Device database to adopt Italy’s CND codes for Eudamed Device Database nomenclature
• EU - Draft corrigendum to Medical Devices Regulation
• EU - Medical Device Coordination Group Issues EUDAMED guidance
• FDA - confirms Bulgaria and Cyprus for Mutual Recognition
• Variations Guidance Updates with CMC / GMP significance: A series of updates to variation management approaches are issued by the EMA. These cover:
  • Submission of changes to AUDIT DATES to verify GMP compliance for API manufacture
  • Introduction of NEW MANUFACTURING SITE for DS or DP and what changes can be submitted under a single Type II Variation (changes to process, batch size, IPCs to adapt to new site settings - other changes should be submitted as a separate variations)
  • Submission of change to Module 3.2.S or the update of an ASMF
  • Submission of an updated CERTIFICATE OF SUITABILITY
  • What is considered to be a 'non-significant IPC or specification parameter (does not include downgrade of CPP to non-CPP)
  • What is considered to be within / outside range when applying for a NEW PACK SIZE
  • Submission of NEW WORKING CELL BANK
  • Submission of a new REFERENCE STANDARD FOR A BIOLOGICAL PRODUCT
  • What changes in MANUFACTURING SITES, building, rooms and EQUIPMENT are covered by company quality system and GMP
  • What is needed if there are changes to a MEDICAL DEVICE?
  • How should one submit TRANSFER OF TEST METHODS for testing of BIOS products to a new or already authorised testing site; submission of editorial changes
  • What is considered a NEW or MODIFIED THERAPEUTIC INDICATION.

• Feburary 2019 Update
  • EU - GMP Annex 2 Updated
  • EU - Draft Guideline on Quality and Equivalence of Topical Products
  • EU -  EDQM survey on Dissolution Test attribute in Ph.Eur.
  • EU - Collated comments on ICH Q12
  • EU - Q&A on safety features
  • EU - Regulator’s Template for FMD Safety Features
  • EU - Electronic product information for human medicines
  • EU - EDQM guide for the elaboration and use of monographs on vaccines and immunosera
• January 2019 Update
  • EU – Consultation on EMA Regulatory Science Plans to 2025
  • EU – Mobile Scanning for Labelling and Product Leaflet
  • EU – Draft revised BSE / TSE Guideline
  • EU – Medicinal Products containing Genetically-Modified Organisms
  • EU – Revision of Environmental Risk Assessment of Human Medicines
  • EU –US Mutual Recognition Agreement
  • PIC/S - DRAFT guidance on Good Practices for Data Integrity released
  • ICH met in Charlotte NC, US in November
    • Q12 – CMC Lifecycle management - EWG did not meet in Charlotte - public comment phase nearing completion. Comments now being collated. EWG will have an interim meet to consolidate comments in Japan in February
    • M9 – BCS Based Biowaivers – EWG did not meet in Charlotte – public comment phase nearing completion. Comments now being collated.
    • M7 – Mutagenic Impurities – EWG reconvened to deliver clarification Q&As to the M7 guidance
    • Q13 – Continuous Manufacturing – EWG met for first time (FDA rapporteur) – concept paper finalised and constituents now engaged in providing ‘outline’ content of desired guidance
    • Q14 / Q2 – Analytical Development and Validation – early stages
    • Quality Discussion Group – Re-established to determine next wave of potential Quality topics
      • At present topics such as Extractables / leachables (proposed by PhRMA) are pre- any agreement to establish working group
• November 2018 Update
  • EU – Workshop on Accelerating CMC for PRIME / Breakthrough programs
  • EU – Reflection Paper on Impurity Qualification Approaches
  • EU – Draft guideline on Quality of Water
  • EU – Updates on Excipient Packaging and Labelling Expectations
  • EU – Update on EU / US MRA
  • EU – Overview of comments received for guideline on quality aspects included in the product information for Vaccines
  • EU – Guideline on requirements for Quality documentation for biological investigational medicinal products​
  • EU – Guideline on equivalence studies for locally-acting products in the GI tract
  • EU – Revised guideline on BSE
  • EU – Workshop on Product Shortage​
  • EU – Reflection Paper on (animal) tests used for product quality
  • EU – EMA Workshop on Advancing Regulatory Science
  • EU – EC letter on FMD Safety features implementation
  • EU – Consultations on medicines for children and rare diseases
  • EU – EC new guidance documents on Unique Device Identification System
  • UK – MHRA Update on health-based exposure limits
  • Swiss – Guidance document on Variations and Extensions
  • ICH – Update to Q3C residual solvents
  • PIC/S – New guidance on classification of GMP deficiencies
• October 2018 Update
  • EU – Dossier requirements for ancillary medicinal substances in a medical device
  • EU – Updated Q&A on Safety Features – wholesaler and parallel importers / distributors
  • EU – Concept paper for Neonate product development
  • EU – New website for EMA
  • EU – US Mutual Recognition – Portugal now recognised (15th country)
  • Ireland – HPRA – Medicines Shortage Framework
  • Russia – Draft Guideline on Data Integrity
  • ICH – EWG presentation materials on ICH M9 BCS-based biowaivers
  • WHO – Guidelines on Validation of Computerised Systems
  • WHO – Appendix 6 Validation – Qualification
  • WHO – Guideline on Analytical Validation
  • PIC/S – Bulgaria applies for membership
  • ISTM – Revision of E2891 Multi-variant data analysis standard
  • FDA – Release of draft guidance on post-approval changes for drug substances
• September 2018 Update
  • EU – Medicines Supply Task Force – Workplan and Workshop
  • EU – Update on EDQM’s actions on valsartan impurity management
  • EU – Quality of Herbal Medicinal Products
  • EU – Draft guideline on Quality, Safety and Efficacy of Medicines containing Genetically-Modified Organisms
  • EU - Outcome of consultation on Health-based exposure limits Q&As
  • PIC/S – Bulgaria applies to PIC/S and Jordan applies for pre-accession
  • WHO – Guidelines on Import Procedures for Medical Products
  • Saudi Arabia – Difficulties with acceptance of German manufactured products into Saudi Arabia
    • Various news reports. And also reports of EFPIA / PhRMA letter to Saudi Arabia on the topic.
• August 2018 Update
  • EMA – Updated application form for certificate of medicinal product
  • EU – Revised (final) GMP Annex 2 on Manufacture of Biologicals
  • EU – Revised (final) Annex 17 on Real Time Release Testing and Parametric release
  • EU – Final GMO requirements for Investigational Products
  • EU – Final guideline on the Quality, Preclinical and Clinical aspects of Gene Therapy Products
  • EU – Updated Q&A guidance on Safety Features
  • EU – Update on impurity-driven recall (valsartan)
  • EMA - Annual Report 2017
  • EU – Annual Report of the Inspectors Working Group
  • EU - EMA Action plan on Advanced Therapy Medicinal Products
  • EU / US Mutual Recognition Update – Lithuania and Ireland added
  • EU / Japan – Updated Mutual Recognition agreement
  • EU / US - Reinforced collaboration on medicines
  • EU – Commission meeting on Medicines shortages
  • MHRA (UK) – Updates GDMP and preparation for inspection guide
  • ICH – revision of ICH Q3D (elemental impurities) – updated PDE for cadmium (3ug/day from 2ug/day)
  • ICH – Release of ICH M9 draft guidance on BCS-based biowaivers for public comment
  • PIC/S – Revision of PIC/S GMP guide
  • PIC/S – New guidance documents (essentially based on EU guidance on these topics)
    • Cross-contamination in shared facilities
    • Health-based limits
    • Risk assessment for GMP for excipients
    • Good Distribution Practices
    • Inspection reliance
  • WHO Q&As – Similar Biotherapeutic products
  • WHO – Protocol for solubility measurements (draft)
  • WHO – Drugs on essential medicines list eligible for biowaivers (draft)
  • WHO – Proposal for revision of the WHO Certification Scheme
  • WHO -  Technical Report series 1010
    • Including Annex 3 – final guideline on procedures and data requirements for changes to approved biotherapeutic products
    • Annex 5 – Final guideline on testing of suspect falsified medicines
    • Annex 8 – Final Guidance on HVAC systems for non-sterile pharmaceutical products
    • Annex 9 – final guidance on good practice for desk assessment of compliance with GMPs
    • Annex 10 – Stability Testing of APIs and FPs
    • Annex 11 – National registration of pharmaceutical products and vaccines approved by stringent regulatory authorities
    • Appendix 5 - Validation of Computerised systems (draft)
• May 2018 Update
  • EMA – 2017 Annual Report
  • EMA – Report on Prior Knowledge Workshop
  • EMA – Final Q&As on Health-based exposure limits
  • EMA – Requirements for Quality Documentation for Biological investigational products
  • EMA – Revision of template for Serious GMP non-compliance
  • EMA – Variation classifications
  • EMA – Certificates of Medicinal Products issued by the EMA
  • EC – Q&As on Clinical Trials regulation (largely administrative)
  • MHRA – Updated Out-Of-Specification Guidance
  • WHO – Proposed revision of the WHO Certification Scheme
  • WHO – Guidelines on Import Procedures
  • Australia – Consultation on adoption of EU guidelines

  • EU GMP guide annexes: Supplementary requirements: Annex 16 (Updated May 2018)
    1. Can a site have more than one QP performing certification of batches?
    2. Can there be more than one QP involved in the certification of a given batch?
    3. In the context of handling unexpected deviations, what is included in the scope of registered specifications for medicinal products?
    4. What is an ‘unexpected’ deviation?
    5. Does Annex 16 permit QP certification of more than one batch affected by the same unexpected deviation?
  • ANSM – Guidelines of follow-up actions after an inspection
• April 2018 Update
  • EU – Excipients in the labelling and package leaflet of medicinal products
  • EU – Updated Q&A on Falsified Medicines Directive Safety Features
  • MHRA – GXP data integrity
  • WHO – Guideline on Validation
  • WHO – Revised draft guidance on HVAC for Non-sterile products (part 2)
  • WHO – Report on substandard and falsified medicines
  • WHO – Production of Water for Injections
  • Qatar – Guidelines for Variations
• March 2018 Update
  • EU – Guidance on safety and efficacy follow-up for Advanced Therapy Medicinal Products
  • EU – Certificate of Suitability – TSE Risk assessment
  • EU – Q/A on Flu Vaccine Preparations
  • EU – Quality Aspects in Product Information for Vaccines
  • EU – Q/As on BSE and Vaccines
  • EU – Vaccines testing and reduction of animal tests
  • EU – EMA Workshop on Paediatric Regulatory Framework
  • US – FDA Publication on the Quality Overall Summary
• February 2018 Update
  • EU – In Use Shelf-life Studies – solid oral dosage forms
  • EDQM – Revised guidance and application forms for electronic submissions of CEPs
  • EU – Workplan for the Biosimilar Working Party
  • EU – New monograph for Infliximab solution
  • Australia – Implementation of PIC/S GMP guide
  • ICH – New member and observer countries
  • UAE – Registration of Innovative Medicines
• January 2018 Update
  • EU – Issue of revision of Annex 1 – GMP for Sterile Manufacture
  • EU – Working Parties – 2018 Workplans (Quality, Biologicals, Vaccines, Safety)
    • 2018 Workplans (Quality & Vaccines) 
    • 2018 Workplans (Biologicals)
    • 2018 Workplans (Safety)
  • EU – Annual Report of the GMP-GDP Inspectors Working group
  • EU – Final revised guidance on Clinical Trial Products
  • EU / ICH – Publication of Step 2 draft of ICH Q12 – CMC Lifecycle Management
  • EU – Variations expectations 
    • Changes to API manufacturing site and DP packaging 1
    • Changes to API manufacturing site and DP packaging 2 
  • EU – Recommendations on improvements to package leaflets
  • WHO – Q&A on Biosimilars
  • Ethiopia – Guidelines for registration of biotherapeutics, vaccines and similar biologic products

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