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Document 52013XC0802(04)

Guidelines on the details of the various categories of variations, on the operation of the procedures laid down in Chapters II, IIa, III and IV of Commission Regulation (EC) No 1234/2008 of 24 November 2008 concerning the examination of variations to the terms of marketing authorisations for medicinal products for human use and veterinary medicinal products and on the documentation to be submitted pursuant to those procedures

OJ C 223, 2.8.2013, p. 1–79 (BG, ES, CS, DA, DE, ET, EL, EN, FR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)
OJ C 223, 2.8.2013, p. 1–1 (HR)

2.8.2013   

EN

Official Journal of the European Union

C 223/1


Guidelines on the details of the various categories of variations, on the operation of the procedures laid down in Chapters II, IIa, III and IV of Commission Regulation (EC) No 1234/2008 of 24 November 2008 concerning the examination of variations to the terms of marketing authorisations for medicinal products for human use and veterinary medicinal products and on the documentation to be submitted pursuant to those procedures

2013/C 223/01

Table of Contents

1.

INTRODUCTION

2.

PROCEDURAL GUIDANCE ON THE HANDLING OF VARIATIONS

2.1.

Minor variations of Type IA

2.1.1.

Submission of Type IA notifications

2.1.2.

Type IA variations review for mutual recognition procedure

2.1.3.

Type IA variations review for purely national procedure

2.1.4.

Type IA variations review for centralised procedure

2.2.

Minor variations of Type IB

2.2.1.

Submission of Type IB notifications

2.2.2.

Type IB variations review for mutual recognition procedure

2.2.3.

Type IB variations review for purely national procedure

2.2.4.

Type IB variations review for centralised procedure

2.3.

Major variations of Type II

2.3.1.

Submission of Type II applications

2.3.2.

Type II variations assessment for mutual recognition procedure

2.3.3.

Outcome of Type II variations assessment for mutual recognition procedure

2.3.4.

Type II variations assessment for purely national procedure

2.3.5.

Outcome of Type II variations assessment for purely national procedure

2.3.6.

Type II variations assessment for centralised procedure

2.3.7.

Outcome of Type II variations assessment in centralised procedure

2.4.

Extensions

2.4.1.

Submission of Extensions applications

2.4.2.

Extension assessment for national procedure

2.4.3.

Extension assessment for centralised procedure

2.5.

Human influenza vaccines

2.5.1.

Submission of variations for annual update of human influenza vaccines applications

2.5.2.

Variations assessment for mutual recognition procedure

2.5.3.

Variations assessment for purely national procedure

2.5.4.

Variations assessment in centralised procedure

2.6.

Urgent Safety Restrictions

2.7.

Statement of compliance under the Paediatric Regulation

3.

PROCEDURAL GUIDANCE ON WORKSHARING

3.1.

Submission of variation(s) application under worksharing

3.2.

Worksharing assessment not involving medicinal products authorised under the centralised procedure

3.3.

Outcome of the worksharing assessment not involving medicinal products authorised under the centralised procedure

3.4.

Worksharing assessment involving medicinal products authorised under the centralised procedure

3.5.

Outcome of the worksharing assessment involving medicinal products authorised under the centralised procedure

4.

ANNEX

1.   INTRODUCTION

Commission Regulation (EC) No 1234/2008 of 24 November 2008 concerning the examination of variations to the terms of marketing authorisations for medicinal products for human use and veterinary medicinal products (1) (‘the Variations Regulation’) governs the procedure for the variation of marketing authorisations. It has been amended by Commission Regulation (EU) No 712/2012 (2).

Article 4(1) of the Variations Regulation charges the Commission with the task of drawing up guidelines on the details of the various categories of variations, on the operation of the procedures laid down in Chapters II, IIa, III and IV of that Regulation as well as on the documentation to be submitted pursuant to these procedures.

These guidelines apply to the variations of marketing authorisations for medicinal products for human use and veterinary medicinal products granted in accordance with Regulation (EC) No 726/2004 of the European Parliament and of the Council (3), Directives 2001/82/EC (4) and 2001/83/EC (5) of the European Parliament and of the Council, and Council Directive 87/22/EEC (6). They are intended to facilitate the interpretation and application of the Variations Regulation. They provide details on the application of the relevant procedures, including a description of all the relevant steps from the submission of an application for a variation to the final outcome of the procedure on the application.

In addition, the Annex to these guidelines provides details of the classification of variations into the following categories as defined in Article 2 of the Variations Regulation: minor variations of Type IA, minor variations of Type IB and major variations of Type II and provides further details, where appropriate, on the scientific data to be submitted for specific variations and how this data should be documented. The Annex to these guidelines will be regularly updated, taking into account the recommendations provided in accordance with Article 5 of the Variations Regulation as well as scientific and technical progress.

Definitions relevant to these guidelines are provided in Directive 2001/82/EC, Directive 2001/83/EC, and Regulation (EC) No 726/2004 as well as in the Variations Regulation. In addition, for the purpose of these guidelines, marketing authorisation holders belonging to the same mother company or group of companies and marketing authorisation holders having concluded agreements or exercising concerted practices concerning the placing on the market of the relevant medicinal product have to be taken as the same marketing authorisation holder (7) (‘holder’).

Reference in these guidelines to the ‘centralised procedure’ is to be understood as the procedure for granting marketing authorisations set out in Regulation (EC) No 726/2004. Reference to the ‘mutual recognition procedure’ is to be understood as the procedure for granting marketing authorisations set out in Directive 87/22/EEC, Articles 32 and 33 of Directive 2001/82/EC, and Articles 28 and 29 of Directive 2001/83/EC. Marketing authorisations granted following a referral under Articles 36, 37 and 38 of Directive 2001/82/EC or Articles 32, 33 and 34 of Directive 2001/83/EC that has led to complete harmonisation are to be considered as marketing authorisations granted under the mutual recognition procedure also. Reference to the ‘purely national procedure’ is to be understood as the procedure for granting marketing authorisations by a Member State in accordance with the acquis outside the mutual recognition procedure.

Reference in this guideline to ‘Member States concerned’, in accordance with Article 2(6) of the Variations Regulation, is to be understood as each Member State whose competent authority has granted a marketing authorisation for the medicinal product in question. Reference to ‘concerned Member States’ is to be understood as all Member States concerned except the reference Member State. Reference to ‘national competent authority’ is to be understood as the authority that has granted a marketing authorisation under a purely national procedure.

Reference in these guidelines to the Agency means the European Medicines Agency.

2.   PROCEDURAL GUIDANCE ON THE HANDLING OF VARIATIONS

A marketing authorisation lays down the terms under which the marketing of a medicinal product is authorised in the EU. A marketing authorisation is composed of:

(i)

a decision granting the marketing authorisation issued by the relevant authority; and

(ii)

a technical dossier with the data submitted by the applicant in accordance with Article 12(3) to Article 14 of Directive 2001/82/EC and Annex I thereto, Article 8(3) to Article 11 of Directive 2001/83/EC and Annex I thereto, Articles 6(2) and 31(2) of Regulation (EC) No 726/2004, or Article 7 of Regulation (EC) No 1394/2007.

The Variations Regulation governs the procedures for the amendment of the decision granting the marketing authorisation and of the technical dossier.

However, in the case of medicinal products for human use, the introduction of changes to the labelling or package leaflet that is not connected with the summary of product characteristics is not governed by the procedures of the Variations Regulation. In accordance with Article 61(3) of Directive 2001/83/EC, these changes are to be notified to the relevant competent authorities and they may be implemented if the competent authority has not objected within 90 days.

These guidelines cover the following categories of variations, defined in Article 2 of the Variations Regulation:

Minor variations of Type IA

Minor variations of Type IB

Major variations of Type II

Extensions

Urgent safety restriction

The reference Member State, the national competent authority or the Agency (8) is available to address any questions which holders may have regarding a particular upcoming variation. Where appropriate, a pre-submission discussion may be organised with the reference Member State, the national competent authority or the Agency in order to obtain further regulatory and procedural advice.

It must be noticed that where a group of variations consists of different types of variations, the group must be submitted and will be handled according to the ‘highest’ variation type included in the group. For instance, a group consisting of an extension and a major variation of Type II will be handled as an extension application; a group consisting of minor variations of Type IB and Type IA will be handled as a Type IB notification.

Where reference is made in these guidelines to the submission of variations’ notifications or applications, the number of copies to be submitted will be made public for each type of procedure by the Agency as regards the centralised procedure; by the coordination groups established by Article 31 of Directive 2001/82/EC as regards veterinary medicinal products and Article 27 of Directive 2001/83/EC as regards medicinal products for human use (‘the coordination group’) as regards the mutual recognition procedure, and by the national competent authority as regards the purely national procedure.

The application form for variations to a marketing authorisation for medicinal products (human and veterinary) is available at http://ec.europa.eu/health/documents/eudralex/vol-2/index_en.htm

Any information related to the implementation of a given variation should be immediately provided by the holder upon the request of the relevant authority.

2.1.   Minor variations of Type IA

Hereby guidance is provided on the application of Articles 7, 8, 11, 13a, 13d, 13e, 14, 17, 23 and 24 of the Variations Regulation to minor variations of Type IA.

The Variations Regulation and the Annex to these guidelines set out a list of changes to be considered as minor variations of Type IA. Such minor variations do not require any prior approval, but must be notified by the holder within 12 months following implementation (‘Do and Tell’ procedure). However, certain minor variations of Type IA require immediate notification after implementation, in order to ensure the continuous supervision of the medicinal product.

The Annex to these guidelines clarifies the conditions which must be met in order for a change to follow a Type IA notification procedure, and specifies which minor variations of Type IA must be notified immediately following implementation.

2.1.1.   Submission of Type IA notifications

Minor variations of Type IA do not require prior examination by the authorities before they can be implemented by the holder. However, at the latest within 12 months from the date of the implementation, the holder must submit simultaneously to all Member States concerned, to the national competent authority, or to the Agency (as appropriate) a notification of the relevant variation(s). It is possible for a holder to include a minor variation of Type IA which is not subject to immediate notification in the submission of a minor variation of Type IA for immediate notification or with any other variation. The conditions laid down in Article 7(2)(a), 7(2)(b), 7(2)(c), 13d(2)(a), 13d(2)(b) or 13d(2)(c) of the Variations Regulation (as appropriate) should be fulfilled.

The holder may group several minor variations of Type IA under a single notification, as established in Articles 7(2) and 13d(2) of the Variations Regulation. Specifically, two possibilities exist for the grouping of variations of Type IA:

(1)

The holder may group several minor variations of Type IA regarding the terms of one single marketing authorisation provided that they are notified at the same time to the same relevant authority.

(2)

The holder may group one or more minor variations of Type IA to the terms of several marketing authorisations under a single notification provided that the variations are the same for all marketing authorisations concerned and they are notified at the same time to the same relevant authority.

The 12 months deadline to notify minor variations of Type IA allows holders to collect Type IA variations for their medicinal products during a year. However, the notification of these variations in a single submission is only possible where the conditions for grouping apply (same variations for all medicinal products concerned). Therefore, it may be the case that the submission of variations implemented over a period of 12 months (so called ‘annual report’) requires several submissions; e.g. one referring to a single minor variation of Type IA, another referring to group of minor variations of Type IA to the terms of one marketing authorisation, and another referring to group of the minor variations of Type IA to the terms of several marketing authorisations.

The notification must contain the elements listed in Annex IV to the Variations Regulation, presented as follows in accordance with the appropriate headings and numbering of ‘The rules governing medicinal products in the European Union’, Volume 2B, Notice to applicants (‘EU-CTD’) format or the Notice to applicants Volume 6B format (veterinary medicinal products when EU-CTD format is not available):

Cover letter.

The completed EU variation application form (published in the Notice to applicants), including the details of the marketing authorisation(s) concerned, as well as a description of all variations submitted together with their date of implementation as applicable. Where a variation is the consequence of, or related to, another variation, a description of the relation between these variations should be provided in the appropriate section of the application form.

Reference to the variation code as laid down in the Annex to these guidelines, indicating that all conditions and documentation requirements are met or, where applicable, reference to a classification recommendation published in accordance with Article 5 of the Variation Regulation used for the relevant application.

All documentation specified in the Annex to these guidelines.

In case that the variations affect the summary of product characteristics, labelling or package leaflet: the revised product information presented in the appropriate format, as well as the relevant translations. Where the overall design and readability of the outer and immediate packaging or package leaflet is affected by the minor variation of Type IA, mock-ups or specimens should be provided to the reference Member State, the national competent authority or the Agency.

For variations in the mutual recognition procedure, the reference Member State should additionally receive the list of dispatch dates indicating the Type IA Variation procedure number, the dates on which the applications have been sent to each Member State concerned and confirmation that the relevant fees have been paid as required by the competent authorities concerned.

For variations in the purely national procedure confirmation that the relevant fee has been paid as required by the national competent authority.

For variations in the centralised procedure, the relevant fee for the minor variation(s) of Type IA, as provided for in Council Regulation (EC) No 297/95 (9), should be paid in accordance with the Agency’s financial procedures.

For grouped minor variations of Type IA concerning several marketing authorisations from the same holder in accordance with Article 7 or 13d of the Variations Regulation, a common cover letter and application form should be submitted together with separate supportive documentation and revised product information (if applicable) for each medicinal product concerned. This will allow the relevant authorities to update the dossier of each marketing authorisation included in the group with the relevant amended or new information.

2.1.2.   Type IA variations review for mutual recognition procedure

The reference Member State will review the Type IA notification within 30 days following receipt.

By Day 30, the reference Member State will inform the holder and concerned Member States of the outcome of its review. In case the marketing authorisation requires any amendment to the decision granting the marketing authorisation, all Member States concerned will update the decision granting the marketing authorisation within 6 months following the receipt of the outcome of the review sent by the reference Member State, provided that the documents necessary for the amendment of the marketing authorisation have been submitted to the Member States concerned.

Where one or several minor variations of Type IA are submitted as part of one notification, the reference Member State will inform the holder which variation(s) have been accepted or rejected following its review. The marketing authorisation holder must not implement the rejected variation(s).

While in the case of minor variations of Type IA, failure to provide all necessary documentation in the application will not necessarily lead to the immediate rejection of the variation if the holder provides any missing documentation immediately upon the request of the relevant authority, it should be highlighted that a minor variation of Type IA may in specific circumstances be rejected with the consequence that the holder must immediately cease to apply already implemented variations concerned.

2.1.3.   Type IA variations review for purely national procedure

The national competent authority will review the Type IA notification within 30 days following receipt.

By Day 30, the national competent authority will inform the holder of the outcome of its review. In case the marketing authorisation requires any amendment to the decision granting the marketing authorisation, the national competent authority will update the decision granting the marketing authorisation within 6 months following the date of information to the holder of the outcome of the review, provided that the documents necessary for the amendment of the marketing authorisation have been submitted to the national competent authority.

Where one or several minor variations of Type IA are submitted as part of one notification, the national competent authority will inform the holder which variation(s) have been accepted or rejected following its review.

While in the case of minor variations of Type IA, failure to provide all necessary documentation in the application will not necessarily lead to the immediate rejection of the variation if the holder provides any missing documentation immediately on request of the relevant authority, it should be highlighted that a minor variation of Type IA may in specific circumstances be rejected with the consequence that the holder must immediately cease to apply already implemented variations concerned.

2.1.4.   Type IA variations review for centralised procedure

The Agency will review the Type IA notification within 30 days following receipt, without involvement of the rapporteur for the product concerned appointed by the Committee for Medicinal Products for Human Use or by the Committee for Veterinary Medicinal Products. However, a copy of the Type IA notification will be submitted by the Agency to the rapporteur for information.

By Day 30, the Agency will inform the holder of the outcome of its review. Where the outcome of the assessment is favourable and the Commission decision granting the marketing authorisation requires any amendment, the Agency will inform the Commission and transmit the revised documentation. In such case, the Commission will update the decision granting the marketing authorisation at the latest within 12 months.

Where one or several minor variations of Type IA are submitted as part of one notification, the Agency will clearly inform the holder which variation(s) have been accepted or rejected following its review.

While in the case of minor variations of Type IA, failure to provide all necessary documentation in the application will not necessarily lead to the immediate rejection of the variation if the holder provides any missing documentation immediately on request of the Agency, it should be highlighted that a minor variation of Type IA may in specific circumstances be rejected with the consequence that the holder must cease to apply already implemented variations concerned.

2.2.   Minor variations of Type IB

Hereby guidance is provided on the application of Articles 7, 9, 11, 13b, 13d, 13e, 15, 17, 23 and 24 of the Variations Regulation to minor variations of Type IB.

The Variations Regulation and the Annex to these guidelines set out a list of changes to be considered as minor variations of Type IB. Such minor variations must be notified before implementation. The holder must wait a period of 30 days to ensure that the notification is deemed acceptable by the relevant authorities before implementing the change (‘Tell, Wait and Do’ procedure).

2.2.1.   Submission of Type IB notifications

Notifications for minor variations of Type IB must be submitted by the holder simultaneously to all Member States concerned, to the national competent authority or to the Agency (as appropriate).

Holders may group under a single notification the submission of several minor variations of Type IB regarding the same marketing authorisation, or group the submission of one or more minor variation(s) of Type IB with other minor variations regarding the same marketing authorisation, provided that this corresponds to one of the cases listed in Annex III of the Variations Regulation, or when this has been agreed previously with the reference Member State, the national competent, authority or the Agency (as appropriate).

In addition, for medicinal products authorised under purely national procedures, the holder may also group several minor variations of Type IB affecting several marketing authorisations in a single Member State, or one or more minor variation(s) of Type IB with other minor variations affecting several marketing authorisations in a single Member State provided that (i) the variations are the same for all the marketing authorisations concerned, (ii) the variations are submitted at the same time to the national competent authority, and (iii) the national competent authority has previously agreed to the grouping.

Furthermore, where the same minor variation of Type IB or the same group of minor variations (as explained above) affect several marketing authorisations owned by the same holder, the holder may submit these variations as one application for ‘worksharing’ (see section 3 on ‘worksharing’).

The notification must contain the elements listed in Annex IV to the Variations Regulation, presented as follows in accordance with the appropriate headings and numbering of the EU-CTD format or the Notice to applicants Volume 6B format (veterinary medicinal products when EU-CTD format is not available):

Cover letter.

The completed EU variation application form (published in the Notice to applicants), including the details of the marketing authorisations(s) concerned. Where a variation is the consequence of or related to another variation, a description of the relation between these variations should be provided in the appropriate section of the application form. Where a variation is considered unclassified, a detailed justification for its submission as a Type IB notification must be included.

Reference to the variation code as laid down in the Annex to these guidelines, indicating that all conditions and documentation requirements are met or, where applicable, reference to a classification recommendation published in accordance with Article 5 of the Variation Regulation used for the relevant application.

Relevant documentation in support of the proposed variation including any documentation specified in the Annex to these guidelines.

For variations requested by the competent authority resulting from new data submitted, e.g. pursuant to post authorisation conditions or in the framework of pharmacovigilance obligations, a copy of the request should be annexed to the cover letter.

In case that the variations affect the summary of product characteristics, labelling or package leaflet: the revised product information presented in the appropriate format, as well as the relevant translations. Where the overall design and readability of the outer and immediate packaging or package leaflet is affected by the minor variation of Type IB, mock-ups or specimens should be provided to the reference Member State, the national competent authority or the Agency.

For variations in the mutual recognition procedure, the reference Member State should additionally receive the list of dispatch dates indicating the Type IB Variation procedure number, the dates on which the applications have been sent to each Member States concerned and confirmation that the relevant fees have been paid as required by the competent authorities concerned.

For variations in the purely national procedure confirmation that the relevant fee has been paid as required by the national competent authority.

For variations in the centralised procedure, the relevant fee for the minor variation(s) of Type IB, as provided for in Council Regulation (EC) No 297/95, should be paid in accordance with the Agency’s financial procedures.

2.2.2.   Type IB variations review for mutual recognition procedure

Upon receipt of a Type IB notification, the notification will be handled as follows:

 

The reference Member State will check within 7 calendar days whether the proposed change can be considered a minor variation of Type IB, and whether the notification is correct and complete (‘validation’) before the start of the evaluation procedure.

 

When the proposed variation is not considered a minor variation of Type IB following the Annex to these guidelines or has not been classified as a minor variation of Type IB in a recommendation pursuant to Article 5 of the Variations Regulation, and the reference Member State is of the opinion that it may have a significant impact on the quality, safety or efficacy of the medicinal product, the reference Member State will inform the concerned Member States and the holder immediately.

 

If the concerned Member States do not disagree within further 7 calendar days, the holder will be requested to revise its application and to complete it in accordance with the requirements for a major variation of Type II application. Following receipt of the valid revised variation application, a Type II assessment procedure will be initiated (see section 2.3.2).

 

If the concerned Member States disagree with the reference Member State, the reference Member State must take the final decision on the classification of the proposed variation having taken into account the comments received.

 

When the reference Member State is of the opinion that the proposed variation can be considered a minor variation of Type IB, the holder will be informed of the outcome of the validation and of the start date of the procedure.

 

Within 30 days following the acknowledgement of receipt of a valid notification, the reference Member State will notify the holder of the outcome of the procedure. If the reference Member State has not sent the holder its opinion on the notification within 30 days following the acknowledgement of receipt of a valid notification, the notification will be deemed acceptable.

 

In case of an unfavourable outcome, the holder may amend the notification within 30 days to take due account of the grounds for the non-acceptance of the variation. If the holder does not amend the notification within 30 days as requested, the variation will be deemed rejected by all concerned Member States.

 

Within 30 days of receipt of the amended notification, the reference Member State will inform the holder of its final acceptance or rejection of the variation(s) (including the grounds for the unfavourable outcome). Concerned Member States will be informed accordingly.

 

Where a group of minor variations were submitted as part of one notification, the reference Member State will inform the holder and the concerned Member States which variation(s) have been accepted or rejected following its review.

 

Where necessary, the relevant authorities will update the marketing authorisation within 6 months following closure of the procedure by the reference Member State, provided that the documents necessary for the amendment of the marketing authorisation have been submitted to the Member States concerned. However, the accepted minor variations of Type IB variation may be implemented without awaiting the update of the marketing authorisation.

2.2.3.   Type IB variations review for purely national procedure

Upon receipt of a Type IB notification, the notification will be handled as follows:

 

The national competent authority will check whether the proposed change can be considered a minor variation of Type IB, and whether the notification is correct and complete (‘validation’) before the start of the evaluation procedure.

 

When the proposed variation is not considered a minor variation of Type IB following the Annex to these guidelines or has not been classified as a minor variation of Type IB in a recommendation pursuant to Article 5 of the Variations Regulation, and the national competent authority is of the opinion that it may have a significant impact on the quality, safety or efficacy of the medicinal product, the holder will be requested to revise its application and to complete it in accordance with the requirements for a major variation of Type II application. Following receipt of the valid revised variation application, a Type II assessment procedure will be initiated (see section 2.3.4).

 

When the national competent authority is of the opinion that the proposed variation can be considered a minor variation of Type IB, the holder will be informed of the outcome of the validation and of the start date of the procedure.

 

Within 30 days following the acknowledgement of receipt of a valid notification, the national competent authority will notify the holder of the outcome of the procedure. If the national competent authority has not sent the holder its opinion on the notification within 30 days following the acknowledgement of receipt of a valid notification, the notification will be deemed acceptable.

 

In case of an unfavourable outcome, the holder may amend the notification within 30 days to take due account of the grounds for the non-acceptance of the variation. If the holder does not amend the notification within 30 days as requested, the variation will be deemed rejected by the national competent authority.

 

Within 30 days of receipt of the amended notification, the national competent authority will inform the holder of its final acceptance or rejection of the variation(s) (including the grounds for the unfavourable outcome).

 

Where a group of minor variations were submitted as part of one notification, the national competent authority will inform the holder which variation(s) have been accepted or rejected following its review.

 

Where necessary, the national competent authority will update the marketing authorisation within 6 months following closure of the procedure, provided that the documents necessary for the amendment of the marketing authorisation have been submitted to the national competent authority. However, the accepted minor variations of Type IB may be implemented without awaiting the update of the marketing authorisation.

2.2.4.   Type IB variations review for centralised procedure

Upon receipt of a Type IB notification, the Agency will handle the notification as follows:

 

The Agency will check within 7 calendar days whether the proposed change can be considered a minor variation of Type IB, and whether the notification is correct and complete (‘validation’) before the start of the evaluation procedure.

 

When the proposed variation is not considered a minor variation of Type IB following the Annex to these guidelines or has not been classified as a minor variation of Type IB in a recommendation pursuant to Article 5 of the Variations Regulation, and the Agency is of the opinion that it may have a significant impact on the quality, safety or efficacy of the medicinal product, the holder will be requested to revise its application and to complete it in accordance with the requirements for a major variation of Type II application. Following receipt of the valid revised variation application, a Type II assessment procedure will be initiated (see section 2.3.6).

 

When the Agency is of the opinion that the proposed variation can be considered a minor variation of Type IB, the holder will be informed of the outcome of the validation and of the start date of the procedure.

 

The rapporteur will be involved in the review of the Type IB notification.

 

Within 30 days following the acknowledgement of receipt of a valid notification, the Agency will notify the holder of the outcome of the procedure. If the Agency has not sent the holder its opinion on the notification within 30 days following the acknowledgement of receipt of a valid notification, the notification will be deemed acceptable.

 

In case of an unfavourable outcome, the holder may amend the notification within 30 days to take due account of the grounds for the non-acceptance of the variation. If the holder does not amend the notification within 30 days as requested, the notification will be rejected.

 

Within 30 days of receipt of the amended notification, the Agency will inform the holder of its final acceptance or rejection of the variation(s) (including the grounds for the unfavourable outcome).

 

Where a group of minor variations are submitted as part of one notification, the Agency will clearly inform the holder which variation(s) have been accepted or rejected following its review.

 

Where the opinion of the Agency is positive and the variation(s) affect(s) the terms of the Commission decision granting the marketing authorisation, the Agency will inform the Commission accordingly and transmit the relevant documentation. Where necessary, the Commission will update the marketing authorisation at the latest within 12 months. However, the accepted minor variation(s) of Type IB may be implemented without awaiting the update of the Commission decision granting the marketing authorisation and the agreed change(s) will be included in the annexes of any subsequent Regulatory Procedure.

2.3.   Major variations of Type II

Hereby guidance is provided on the application of Articles 7, 10, 11, 13, 13c, 13d, 13e, 16, 17, 23 and 24 of the Variations Regulation to major variations of Type II.

The Variations Regulation and the Annex to these guidelines set out a list of changes to be considered as major variations of Type II. Such major variations require approval of the relevant competent authority before implementation.

2.3.1.   Submission of Type II applications

Notifications for major variations of Type II must be submitted by the holder simultaneously to all Member States concerned, to the national competent authority or to the Agency (as appropriate).

Holders may group under a single notification the submission of several major variations of Type II regarding the same marketing authorisation, or group the submission of one or more major variation(s) of Type II with other minor variations regarding the same marketing authorisation, provided that this corresponds to one of the cases listed in Annex III of the Variations Regulation, or when this has been agreed previously with the reference Member State, the national competent, authority or the Agency (as appropriate).

In addition, for medicinal products authorised under purely national procedures, the holder may also group several major variations of Type II affecting several marketing authorisations in a single Member State, or one or more major variation(s) of Type II with other minor variations affecting several marketing authorisations in a single Member State, provided that (i) the variations are the same for all the marketing authorisations concerned, (ii) the variations are submitted at the same time to the national competent authority, and (iii) the national competent authority has previously agreed to the grouping.

Furthermore, where the same major variation of Type II or the same group of variations (as explained above) affect several marketing authorisations owned by the same holder, the holder may submit these variations as one application for ‘worksharing’ (see section 3 on ‘worksharing’).

The application must contain the elements listed in Annex IV to the Variations Regulation, presented as follows in accordance with the appropriate headings and numbering of the EU-CTD format or the Notice to applicants Volume 6B format (veterinary medicinal products when the EU-CTD format is not available):

Cover letter.

The completed EU variation application form (published in the Notice to Applicants), including the details of the marketing authorisation(s) concerned. Where a variation is the consequence of or related to another variation, a description of the relation between these variations should be provided in the appropriate section of the application form.

Reference to the variation code as laid down in the Annex to these guidelines, indicating that all conditions and documentation requirements are met or, where applicable, reference to a classification recommendation published in accordance with Article 5 of the Variation Regulation used for the relevant application.

Supporting data relating to the proposed variation(s).

Update or Addendum to quality summaries, non-clinical overviews and clinical overviews (or expert reports for veterinary medicinal products) as relevant. When non-clinical or clinical study reports are submitted, even if only one, their relevant summary(ies) should be included in Module 2.

For variations requested by the competent authority resulting from new data submitted, e.g. pursuant to post authorisation conditions or in the framework of pharmacovigilance obligations, a copy of the request should be annexed to the cover letter.

In case that the variations affect the summary of product characteristics, labelling or package leaflet, the revised product information presented in the appropriate format, as well as the relevant translations. Where the overall design and readability of the outer and immediate packaging or package leaflet is affected by the major variation of Type II, mock-ups or specimens should be provided to the reference Member State, the national competent authority or the Agency.

For variations in the mutual recognition procedure, the reference Member State should additionally receive the list of dispatch dates indicating the Type II Variation procedure number, the dates on which the applications have been sent to each Member State concerned and confirmation that the relevant fee has been paid as required by the competent authorities concerned.

For variations in the purely national procedure confirmation that the relevant fee has been paid as required by the national competent authority.

For variations in the centralised procedure, the relevant fee for the Type II variation(s), as provided for in Council Regulation (EC) No 297/95, should be paid in accordance with the Agency’s financial procedures.

2.3.2.   Type II variations assessment for mutual recognition procedure

Upon receipt of a Type II application, the reference Member State will handle the application as follows:

 

If the application has been submitted simultaneously to all the Member States concerned and contains the elements listed in point 2.3.1, the reference Member State will acknowledge receipt of a valid application of a major variation of Type II. The procedure starts from the date of acknowledgement of the receipt of a valid application by the reference Member State. The holder and the concerned Member States will be informed of the timetable at the start of the procedure.

 

As a general rule, for major variations of Type II, a 60-day evaluation period will apply. This period may be reduced by the reference Member State having regard to the urgency of the matter, particularly for safety issues, or may be extended by the reference Member State to 90 days for variations listed in Part I of Annex V or for grouping of variations in accordance with Article 7(2)(c) of the Variations Regulation. For variations for veterinary medicinal products listed in Part 2 of Annex V of the Variations Regulation a 90-day period will apply.

 

The reference Member State will prepare a draft assessment report and a decision on the application according to the communicated timetable and will circulate them to the concerned Member States for comments as well as to the holder for information. The concerned Member States will send to the reference Member State their comments within the deadlines set out in the timetable.

 

Within the evaluation period, the reference Member State may request the marketing authorisation holder to provide supplementary information. The request for supplementary information will be sent to the holder together with a timetable stating the date by when the holder should submit the requested data and where appropriate the extended evaluation period. In general, a suspension of 1 month will typically apply. For longer suspension the holder should send a justified request to the reference Member State for agreement.

 

The procedure will be suspended until the receipt of the supplementary information. The evaluation of responses may take up to 30 or 60 days depending on the complexity and amount of data requested to the holder.

 

After receipt of the holder’s response, the reference Member State will finalise the draft assessment report and the decision on the application and will circulate them to the concerned Member States for comments as well as to the holder for information.

2.3.3.   Outcome of Type II variations assessment for mutual recognition procedure

By the end of the evaluation period, the reference Member State will finalise and submit the assessment report and its decision on the application to the concerned Member States.

Within 30 days following receipt of the assessment report and the decision, the concerned Member States will recognise the decision and inform the reference Member State accordingly, unless a potential serious risk to public health or a potential serious risk to human or animal health or to the environment (in the case of veterinary medicinal products) is identified that prevents a Member State from recognising the decision of the reference Member State. The Member State that, within 30 days following receipt of the assessment report and the decision of the reference Member State, identifies such a potential serious risk must inform the reference Member State and give a detailed statement of the reasons for its position.

The reference Member State will then refer the application to the corresponding coordination group for application of Article 33(3), (4) and (5) of Directive 2001/82/EC or Article 29(3), (4) and (5) of Directive 2001/83/EC to the matter of disagreement and will inform the holder and the concerned Member States accordingly. The holder is not entitled to trigger a referral.

Where an application concerning a grouping of variations that includes at least a variation Type II is referred to the coordination group, the decision on the variations not subject to the referral will be suspended until the referral procedure has concluded (including, where relevant, the referral to the Committee for Medicinal Products for Human Use under Articles 32 to 34 of Directive 2001/83/EC, or the Committee for Veterinary Medicinal Products pursuant to Articles 36 to 38 of Directive 2001/82/EC). However, only the variation(s) in respect of which a potential serious risk to human or animal health or to the environment has been identified will be discussed by the coordination group and eventually by the Committee for Medicinal Products for Human use or the Committee for Veterinary Medicinal Products, not the whole group.

The reference Member State will inform the concerned Member States and the holder about the approval or rejection of the variation(s) (including the grounds for the unfavourable outcome). Where several Type II variations, or a group of Type II variation(s) with other minor variations have been submitted as one application, the reference Member State will inform the holder and the concerned Member States which variation(s) have been accepted or rejected. The holder may withdraw single variations from the grouped application during the procedure (prior to the finalisation of the assessment of the reference Member State).

After a positive decision is communicated regarding variations with changes to the summary of product characteristics, labelling or package leaflet, the holder should submit, within 7 days, translations of the product information texts to all Member States concerned.

After approval of the variation(s), the competent authorities of the Member States concerned will, where necessary, amend the marketing authorisation to reflect the variation(s) within 2 months, provided that the documents necessary for the amendment of the marketing authorisation have been submitted to the Member States concerned.

The accepted major variation(s) of Type II can be implemented 30 days after the holder has been informed about the acceptance of the variation(s) by the reference Member State, provided that the necessary documents to amend the marketing authorisation have been submitted to the Member State concerned. In those cases where the application has been the object of a referral, the variation(s) must not be implemented until the referral procedure has concluded that the variation(s) is accepted. However, the variations in the group not subject to the referral may be implemented if so indicated by the reference Member State.

Variations related to safety issues must be implemented within a time-frame agreed between the reference Member State and the holder.

2.3.4.   Type II variations assessment for purely national procedure

Upon receipt of a Type II application, the national competent authority will handle the application as follows:

 

If the application contains the elements listed in point 2.3.1, the national competent authority will acknowledge receipt of a valid application of a major variation of Type II. The procedure starts from the date of acknowledgement of the receipt of a valid application. The holder will be informed of the timetable at the start of the procedure.

 

As a general rule, for major variations of Type II, a 60-day evaluation timetable will apply. This period may be reduced by the national competent authority having regard to the urgency of the matter, particularly for safety issues, or may be extended to 90 days for variations listed in Part I of Annex V or for grouping of variations in accordance with Article 13d(2)(c) of the Variations Regulation. For variations for veterinary medicinal products listed in Part 2 of Annex V of the Variations Regulation a 90-day timetable will apply.

 

Within the evaluation period, the national competent authority may request the holder to provide supplementary information. The request for supplementary information will be sent to the holder together with a timetable stating the date by when the holder should submit the requested data and where appropriate the extended evaluation period.

 

The procedure will be suspended until the receipt of the supplementary information. As a general rule, a suspension of 1 month will apply. For longer suspension the holder should send a justified request to the national competent authority for agreement.

 

The evaluation of responses may take up to 30 or 60 days depending on the complexity and amount of data requested to the holder.

2.3.5.   Outcome of Type II variations assessment for purely national procedure

By the end of the evaluation period, the national competent authority will finalise the evaluation including its decision on the application and inform the holder about the approval or rejection of the variation(s) (including the grounds for the unfavourable outcome).

Where several Type II variations, or a group of Type II variation(s) with other minor variations have been submitted as one application, the national competent authority will inform the holder which variation(s) have been accepted or rejected. The holder may withdraw single variations from the grouped application during the procedure (prior to the finalisation of the assessment by the national competent authority).

After approval of the variation(s), the national competent authorities will, where necessary, amend the marketing authorisation(s) to reflect the variation(s) within 2 months provided that the documents necessary for the amendment of the marketing authorisation have been submitted to the national competent authority.

The accepted major variation(s) of Type II can be implemented after the holder has been informed about the acceptance of the variation(s) by the national competent authority, provided that the necessary documents to amend the marketing authorisation(s) have been submitted.

Variations related to safety issues must be implemented within a time-frame agreed between the national competent authority and the holder.

2.3.6.   Type II variations assessment for centralised procedure

Upon receipt of a Type II application, the Agency will handle the application as follows:

 

If the application submitted to the Agency contains the elements listed in point 2.3.1, the Agency will acknowledge receipt of a valid application of a major variation of Type II. By the date of acknowledgement of the receipt of a valid application, the Agency will start the procedure. The marketing authorisation holder will be informed of the adopted timetable at the start of the procedure.

 

As a general rule, for major variations of Type II, a 60-day evaluation timetable will apply. This period may be reduced by the Agency having regard to the urgency of the matter, particularly for safety issues, or may be extended by the Agency to 90 days for variations listed in Part I of Annex V or for grouping of variations in accordance with Articles 7(2)(c) of the Variations Regulation. For variations for veterinary medicinal products listed in Part 2 of Annex V of the Variations Regulation a 90-day timetable will apply.

 

Within the evaluation period, the Committee for Medicinal Products for Human Use or the Committee for Veterinary Medicinal Products may request supplementary information. The request for supplementary information or follow-on request will be sent to the holder together with the timetable stating the date by when the holder should submit the requested data and where appropriate the extended evaluation period.

 

The procedure will be suspended until the receipt of the supplementary information. In general, a suspension of up to 1 month will typically apply. For suspension longer than 1 month the holder should send a justified request to the Agency for agreement by the corresponding Committee. For any follow-on request for supplementary information, an additional procedural suspension of up to 1 month will be applied in general; a maximum of 2 months may be applied when justified.

 

The Committee assessment of responses may take up to 30 or 60 days depending on the complexity and amount of data to be requested to the marketing authorisation holder.

 

An oral explanation to the Committee for Medicinal Products for Human Use or the Committee for Veterinary Medicinal Products may be held at the request of the Committee or the holder, where appropriate.

2.3.7.   Outcome of Type II variations assessment in centralised procedure

Upon adoption of an opinion of the Committee for Medicinal Products for Human Use or the Committee for Veterinary Medicinal Products, the Agency will inform the marketing authorisation holder within 15 days as to whether the opinion is favourable or unfavourable (including the grounds for the unfavourable outcome).

Where several Type II variations, or a group of Type II variation(s) with other minor variations have been submitted as one application, the Agency will issue an opinion reflecting the final outcome of the procedure. Such opinion will also list any variations which are not considered approvable. The holder may withdraw single variations from the grouped application during the procedure (prior to the finalisation of the opinion of the Agency).

The re-examination procedure set-out in Articles 9(2) and 34(2) of Regulation (EC) No 726/2004 also applies to the opinions adopted for major variations of Type II applications.

Where the final opinion of the Agency is favourable and the variation(s) affects the terms of the Commission decision granting the marketing authorisation, the Agency will transmit to the Commission its opinion and the grounds for its opinion as well as the necessary documents to amend the marketing authorisation.

Upon receipt of the final opinion and the relevant information, the Commission will, where necessary, amend the marketing authorisation within 2 months in the following cases:

(i)

variations related to the addition of a new therapeutic indication or to the modification of an existing one;

(ii)

variations related to the addition of a new contraindication;

(iii)

variations related to a change in posology;

(iv)

variations related to the addition of a non-food producing target species or the modification of an existing one for veterinary medicinal products;

(v)

variations concerning the replacement or addition of a serotype, strain, antigen or combination of serotypes, strains or antigens for a veterinary vaccine;

(vi)

variations related to changes to the active substance of a seasonal, pre-pandemic or pandemic vaccine against human influenza;

(vii)

variations related to changes to the withdrawal period for a veterinary medicinal product;

(viii)

other type II variations that are intended to implement changes to the decision granting the marketing authorisation due to a significant public health concern or significant animal health or environmental concern in the case of veterinary medicinal products.

In the case of other variations, the Commission will, where necessary, amend the decision granting the marketing authorisation at the latest within 12 months.

The approved major variation(s) of Type II requiring amendment of the Commission decision granting the marketing authorisation within 2 months may only be implemented once the holder has been informed by the Commission accordingly. Where amendment of the decision granting the marketing authorisation is not required within 2 months, or where the approved variation(s) does not affect the terms of the Commission decision granting the marketing authorisation, the variation(s) may be implemented once the holder has been informed by the Agency that its opinion is favourable.

Variations related to safety issues must be implemented within a time-frame agreed between the Commission and the holder.

2.4.   Extensions

Annex I of the Variations Regulation sets out a list of changes to be considered as extensions. As established in Article 19 of the Variations Regulation, such applications will be evaluated in accordance with the same procedure as for the granting of the initial marketing authorisation to which it relates. The extension can either be granted as a new marketing authorisation or will be included in the initial marketing authorisation to which it relates.

2.4.1.   Submission of Extensions applications

Extension applications must be submitted to all Member States concerned, to the national competent authority, or to the Agency (as appropriate).

Holders may group under a single notification the submission of several extensions, or one or more extensions with one or more other variations, regarding the same marketing authorisation provided that this corresponds to one of the cases listed in Annex III of the Variations Regulation, or when this has been agreed previously with the reference Member State, the national competent, authority or the Agency (as appropriate). However, no worksharing of extensions applications is foreseen in the Variations Regulation.

The application must be presented as follows, in accordance with the appropriate headings and numbering of the EU-CTD format or the Notice to applicants Volume 6B format (veterinary medicinal products when the EU-CTD format is not available):

Cover letter.

The completed EU application form (published in the Notice To Applicants)

Supporting data relating to the proposed extension. Some guidance on the appropriate additional studies required for extension applications is available in Appendix IV to Chapter 1 of Volume 2A or 6A of the Notice to applicants.

A full Module 1 (Part 1 for veterinary medicinal products) should be provided, with justifications for absence of data or documents included in the relevant section(s) of Module 1 or Part 1.

Update or Addendum to quality summaries, non-clinical overviews and clinical overviews (or expert reports for veterinary medicinal products) as relevant. When non-clinical or clinical study reports are submitted, even if only one, their relevant summary(ies) should be included in Module 2.

In case that the extension affects the summary of product characteristics, labelling or package leaflet: the revised product information, presented in the appropriate format.

For extension applications in the mutual recognition procedure, the reference Member State should additionally receive the list of dispatch dates indicating the procedure number, the dates on which the applications have been sent to each Member State concerned and confirmation that the relevant fees have been paid as required by the competent authorities concerned.

For extension applications in the purely national procedure confirmation that the relevant fee has been paid as required by the national competent authority.

For extension applications in the centralise procedure, the relevant fee for the extension(s), as provided for in Council Regulation (EC) No 297/95, should be paid in accordance with the Agency’s financial procedures.

2.4.2.   Extension assessment for national procedure

Upon receipt of an extension application under the mutual recognition or the purely national procedure, it will be handled as an initial marketing authorisation application in accordance with Directive 2001/82/EC or Directive 2001/83/EC.

2.4.3.   Extension assessment for centralised procedure

Upon receipt of an extension application, the Agency will handle the application as for an initial marketing authorisation application in accordance with Regulation (EC) No 726/2004.

2.5.   Human influenza vaccines

Hereby guidance is provided on the application of Articles 12, 13f and 18 of the Variations Regulation to the annual update of human influenza vaccines.

Because of the specificities inherent in the manufacturing of human influenza vaccines, a special ‘fast track’ variation procedure is applicable for the annual change in active substance for the purpose of the annual update of a human influenza vaccine in order to meet the EU recommendation for human influenza virus strain(s) vaccine composition for the coming season. In addition, a special urgent procedure is foreseen in Article 21 of the Variations Regulation for cases of pandemic situation.

Any other variations to human influenza vaccines follow the variation procedures foreseen in other sections of these Guidelines.

The ‘fast track’ procedure consists of two steps. The first step concerns the assessment of the administrative and quality data elements (summary of product characteristics, labelling and package leaflet, and the chemical, pharmaceutical and biological documentation). The second step concerns the assessment of additional data where necessary.

Marketing authorisation holders are advised to discuss the annual update submissions in advance with the reference Member State, the national competent authority or the Agency.

2.5.1.   Submission of variations for annual update of human influenza vaccines applications

Variations concerning changes to the active substance for the annual update of human influenza vaccines applications must be submitted to the reference Member State and to all concerned Member States, to the national competent authority or to the Agency (as appropriate).

The application must be presented in accordance with the appropriate headings and numbering of the EU-CTD format:

Cover letter.

The completed EU application form (published in the Notice to applicants)

Update or Addendum to quality summaries, non-clinical overviews and clinical overviews as relevant. When non-clinical or clinical study reports are submitted, even if only one, their relevant summary(ies) should be included in Module 2.

Supporting data relating to the proposed variation(s).

The revised product information, presented in the appropriate format.

In the case of applications for the annual update of human influenza vaccines under the mutual recognition procedure, the reference Member State should additionally receive the list of dispatch dates indicating the procedure number, the dates on which the applications have been sent to each Member States concerned and confirmation that the relevant fees have been paid as required by the competent authorities concerned.

In the case of applications for the annual update of human influenza vaccines under the purely national procedure confirmation that the relevant fee has been paid as required by the national competent authority.

In the case of applications for the annual update of human influenza vaccines under the centralised procedure, the relevant fee for the variation as provided for in Council Regulation (EC) No 297/95 should be paid in accordance with the Agency’s financial procedures.

2.5.2.   Variations assessment for mutual recognition procedure

Upon receipt of an application for the annual update, the reference Member State will handle the application as follows:

 

The reference Member State will acknowledge receipt of a valid application within 7 days and inform the holder and the Member States concerned of the start of the procedure.

 

The reference Member State will prepare an assessment report and a decision on the application. To this end, the reference Member State will consider first the administrative and quality data. As the reference Member State must sent the assessment and the draft Decision within the maximum deadline of 45 days foreseen in the Regulation, it is expected that, in order to allow for sufficient time for the assessment of additional data (notably clinical and stability data) where necessary, the reference Member State will typically conclude its assessment of the administrative and quality data within 30 days of the reception of a valid application.

 

The reference Member State may request the holder to submit additional information (notably clinical or stability data); in such a case, it will inform the concerned Member States. When a request for additional information is sent to the holder, the 45 days deadline is stopped until the requested information has been submitted by the holder.

 

The reference Member State will transmit its assessment report and draft Decision to the concerned Member States. Within 12 days from the reception date, the concerned Member States will adopt a decision accordingly and inform the holder and the reference Member State thereof.

2.5.3.   Variations assessment for purely national procedure

Upon receipt of an annual variation human influenza vaccines application, the national competent authority will handle the application as follows:

 

The national competent authority will acknowledge receipt of a valid application of an annual variation human influenza vaccine and inform the holder accordingly.

 

Within the evaluation period, the national competent authority may send the holder a request for supplementary information (notably clinical or stability data); in such a case, the 45 days deadline is stopped until the requested information has been submitted by the holder.

 

Within 45 days from the receipt of a valid application, the national competent authority will finalise the evaluation including its decision on the application and inform the holder about the approval or rejection of the variation(s) (including the grounds for the unfavourable outcome).

2.5.4.   Variations assessment in centralised procedure

Upon receipt of an annual variation human influenza vaccines application, the Agency will handle the application as follows:

 

The Agency will acknowledge receipt of a valid application of an annual variation human influenza vaccine within 7 days and inform the holder of the start of the procedure.

 

The Committee for Medicinal Products for Human Use has a maximum of 55 days from the start of the procedure to assess the application. The Committee may request the holder to submit additional information (notably clinical or stability data); in such a case, the 55 days deadline is stopped until the requested information has been submitted by the holder.

 

Where necessary and based on the final opinion from the Committee, the Commission will amend the decision granting the marketing authorisation and update the Community Register of Medicinal Products.

2.6.   Urgent Safety Restrictions

Article 22 of the Variations Regulation foresees that in the event of a risk to public health in the case of medicinal products for human use or in the event of a risk to human or animal health or to the environment in the case of veterinary medicinal products, the holder may take provisional ‘urgent safety restrictions’.

Urgent safety restrictions concern interim change(s) in the terms of the marketing authorisation due to new information having a bearing on the safe use of the medicinal product. These urgent changes must be subsequently introduced via a corresponding variation in the marketing authorisation.

The holder must immediately notify all Member States concerned, the national competent authority or the Agency (as appropriate) of the restrictions to be introduced.

If no objections have been raised by the relevant authority or the Agency (for centrally authorised medicinal products) within 24 hours following receipt of that information, the urgent safety restrictions are deemed accepted. They must be implemented within a time frame agreed between the reference Member State, the national competent authority or the Agency (as appropriate) and the holder.

Urgent safety restrictions may also be imposed by the Commission (for centrally authorised medicinal products) or by the national competent authorities (for nationally authorised medicinal products) in the event of a risk to public health in the case of medicinal products for human use or in the event of a risk to human or animal health in the case of veterinary medicinal products.

The corresponding variation application reflecting the urgent safety restrictions (whether requested by the holder or imposed by the Commission or the national competent authorities) must be submitted by the holder as soon as possible within 15 days.

2.7.   Statement of compliance under the Paediatric Regulation

Regulation (EC) No 1901/2006 of the European Parliament and of the Council of 12 December 2006 on medicinal products for paediatric use and amending Regulation (EEC) No 1768/92, Directive 2001/20/EC, Directive 2001/83/EC and Regulation (EC) No 726/2004 (10) (‘Paediatric Regulation’) provides for rewards:

Under Article 36(1) of Regulation (EC) No 1901/2006, the holder of a patent or supplementary protection certificate is entitled to a 6-month extension of the period referred to in Article 13(1) and (2) of Regulation (EEC) No 1768/92 (11) (now: Regulation (EC) No 469/2009) under certain conditions, including the addition to the marketing authorisation of the statement referred to in Article 28(3) of the Paediatric Regulation (‘compliance statement’).

Under Article 37 of Regulation (EC) No 1901/2006, the holder of a marketing authorisation for an orphan medicinal product is entitled to an extension of the 10-year period referred to in Article 8(1) of Regulation (EC) No 141/2000 to 12 years under certain conditions, including the addition of the compliance statement to the marketing authorisation.

It follows that, for the purposes of benefiting from the rewards provided for under Articles 36 and 37 of the Paediatric Regulation, a variation to add the compliance statement in the marketing authorisation may be required.

Article 23a of the Variations Regulation simplifies the procedure to add the compliance statement in the marketing authorisation so that the rewards foreseen under Regulation (EC) No 1901/2006 may be sought as soon as possible once the requirements foreseen in the Paediatric Regulation have been complied with. Specifically, in order to include the compliance statement holders should submit a variation request to the relevant authority. After verification that all relevant conditions are met, the compliance statement is to be included by the relevant authority in the technical dossier of the marketing authorisation.

For the purposes of legal certainty, the relevant authority will provide the holder with a confirmation that the compliance statement has been included in the technical dossier within 30 days after the relevant assessment has been concluded. In the case of marketing authorisations granted under the centralised procedure, the confirmation that the compliance statement has been included in the marketing authorisation will be issued by the European Medicines Agency.

3.   PROCEDURAL GUIDANCE ON WORKSHARING

Article 20 of the Variations Regulation allows a holder to submit in one application the same Type IB, the same Type II variation, or the same group of variations corresponding to one of the cases listed in Annex III of the Regulation or agreed with the reference Member State, the national competent authority or the Agency (as appropriate) which does not contain any extension affecting

(i)

more than one purely national marketing authorisation of the same holder in more than one Member State; or

(ii)

more than one mutual recognition marketing authorisation of the same holder; or

(iii)

more than one centralised marketing authorisation of the same holder; or

(iv)

one or several purely national marketing authorisation(s) and one or several centralised marketing authorisation(s) of the same holder; or

(v)

one or several purely national marketing authorisation(s) and one or several mutual recognition marketing authorisation(s) of the same holder; or

(vi)

one or several mutual recognition marketing authorisation(s) and one or several centralised marketing authorisation(s) of the same holder; or

(vii)

one or several purely national marketing authorisation(s), one or several mutual recognition marketing authorisation(s) and one or several centralised marketing authorisation(s) of the same holder.

In order to avoid duplication of work in the evaluation of such variations, a worksharing procedure has been established under which one authority (the ‘reference authority’), chosen amongst the competent authorities of the Member States and the Agency, will examine the variation on behalf of the other concerned authorities.

Where at least one of the concerned marketing authorisations has been authorised via the centralised procedure, the Agency will be the reference authority (section 3.4). In all other cases, a national competent authority chosen by the coordination group, taking into account the recommendation of the holder, will act as the reference authority (section 3.2).

In order to facilitate the planning of the procedure, holders are encouraged to inform the Agency or the coordination group and the proposed reference authority in advance of the submission of a variation or group of variations to be subject to a worksharing procedure.

In order to benefit from a worksharing procedure, it is necessary that the same change(s) will apply to the different medicinal products concerned with no need (or limited need) for assessment of a potential product-specific impact. Therefore, where the ‘same’ change(s) to different marketing authorisations require the submission of individual supportive data for specific medicinal products concerned or separate product-specific assessment, such changes cannot benefit from worksharing.

3.1.   Submission of variation(s) application under worksharing

A variation or group of variations presented for worksharing must be submitted as explained in sections 2.2-2.3 above and must be transmitted as one integrated submission package covering all variations for all medicinal products. This must include a common cover letter and application form, together with separate supportive documentation for each medicinal product concerned and revised product information (if applicable) for each medicinal product concerned. This will allow the Agency and the national competent authorities to update the dossier of each marketing authorisation included in the worksharing procedure with the relevant amended or new information.

The worksharing application must be submitted to all relevant authorities, i.e. all Member States where the products concerned are authorised and the Agency (for the centralised procedure).

3.2.   Worksharing assessment not involving medicinal products authorised under the centralised procedure

When the holder informs the coordination group of an upcoming worksharing procedure that does not affect any centralised marketing authorisation, the coordination group will at the next meeting decide on the reference authority, taking into account the proposal of the holder and, if applicable pursuant to the third subparagraph of Article 20(3) of the Variations Regulation, another relevant authority to assist the reference authority. The holder will be informed by the coordination group of the decision of which national competent authority will act as reference authority.

Upon receipt of a worksharing application, the reference authority will handle the application as follows:

 

The reference authority will acknowledge receipt of a valid application for worksharing. Immediately after acknowledging receipt of a valid application, the reference authority will start the procedure. The holder and the Member States concerned will be informed of the timetable at the start of the procedure.

 

As a general rule, worksharing procedures will follow a 60-day period or a 90-day evaluation period for variations listed in Part 2 of Annex V of the Variations Regulation. This period may however be reduced by the reference authority having regard to the urgency of the matter, particularly for safety issues, or may be extended to 90 days for variations listed in Part 1 of Annex V or for grouping of variations in accordance with Article 7(2)(c) or 13d(2)(c) of the Variations Regulation.

 

The reference authority will prepare an opinion according to the communicated timetable and will circulate it to the concerned Member States for comments as well as to the holder for information. Concerned Member States will send their comments within the deadlines set out in the timetable.

 

Within the evaluation period, the reference Member State may request the marketing authorisation holder to provide supplementary information. The request for supplementary information will be sent to the holder together with a timetable stating the date by when the holder should submit the requested data and, where appropriate, the extended evaluation period. In general, a suspension of 1 month will typically apply. For longer suspension the holder should send a justified request to the reference Member State for agreement.

 

The procedure will be suspended until the receipt of the supplementary information. The assessment of responses may take up to 30 or 60 days depending on the complexity and amount of data requested to the holder.

 

After receipt of the holder’s response, the reference Member State will finalise the draft opinion and will circulate it to the concerned Member States for comments as well as to the holder for information.

3.3.   Outcome of the worksharing assessment not involving medicinal products authorised under the centralised procedure

By the end of the evaluation period, the reference authority will issue its opinion on the application and inform the concerned Member States and the holder.

In case of a favourable opinion, the list of variations that are not considered approvable should be attached in the Opinion (if applicable). Variations may be considered approvable for some of the concerned products only. In case of an unfavourable outcome, the grounds for the unfavourable outcome should be explained.

Within 30 days following receipt of the opinion, the concerned Member States will recognise the opinion and inform the reference Member State accordingly, unless a potential serious risk to public health or a potential serious risk to human or animal health or to the environment (in the case of veterinary medicinal products) is identified that prevents a Member State from recognising the opinion of the reference Member State. The Member State that, within 30 days following receipt of the opinion of the reference Member State, identifies such a potential serious risk should inform the reference Member State and give a detailed statement of the reasons for its position.

The reference authority will then refer the application to the coordination group for application of Article 33(3), (4) and (5) of Directive 2001/82/EC or Article 29(3), (4) and (5) of Directive 2001/83/EC to the matter of disagreement and will inform the holder and the Member States concerned accordingly. The holder is not entitled to trigger a referral.

Where a referral to the coordination group is made, the procedure concerning the decision on the worksharing application will be suspended until a decision has been adopted on the referral procedure (including, where relevant, the referral to the Committee for Medicinal Products for Human Use under Articles 32 to 34 of Directive 2001/83/EC, or the Committee for Veterinary Medicinal Products pursuant to Articles 36 to 38 of Directive 2001/82/EC).

After a positive opinion is communicated regarding variations with changes to the summary of product characteristics, labelling or package leaflet, the holder should submit, within 7 days, translations of the product information texts to all Member States concerned.

Within 30 days following the approval of the opinion or, where a referral has been triggered, the notification of the agreement of the coordination group or the Commission decision (as applicable), the Member States concerned will amend the marketing authorisation(s) accordingly, provided that the documents necessary for the amendment of the marketing authorisation have been submitted to the Member States concerned.

Minor variation(s) of Type IB approved via a worksharing procedure, may be implemented upon receipt of the favourable opinion of the reference authority.

Major variation(s) of Type II (including those which contain grouped minor variation(s) of Type IB) approved via a worksharing procedure may be implemented 30 days after receipt of the favourable opinion from the reference authority provided that the necessary documentation to amend the marketing authorisation has been submitted to the Member States concerned. In those cases where the application has been the object of a referral, the variation(s) must not be implemented until the referral procedure has concluded that the variation(s) is accepted.

Variations related to safety issues must be implemented within a time-frame agreed between the marketing authorisation holder and the reference authority.

3.4.   Worksharing assessment involving medicinal products authorised under the centralised procedure

Upon receipt of a worksharing application that affects at least one centralised marketing authorisation, the Agency will handle the application as follows:

 

The Agency will acknowledge receipt of a valid worksharing application. Immediately after acknowledging the receipt of a valid application, the Agency will start the procedure. The holder will be informed of the adopted timetable at the start of the procedure.

 

The Agency will appoint a rapporteur (and in some cases also a co-rapporteur) to lead the assessment procedure.

 

In general, worksharing procedures will follow a 60-day evaluation timetable or a 90-day evaluation timetable for variations listed in Part 2 of Annex V of the Variations Regulation. This period may however be reduced by the reference authority having regard to the urgency of the matter, particularly for safety issues, or may be extended to 90 days for variations listed in Part 1 of Annex V or for grouping of variations in accordance with Article 7(2)(c) or 13d(2)(c).

 

Within the evaluation period, the Committee for Medicinal Products for Human Use or the Committee for Veterinary Medicinal Products may request supplementary information. The request for supplementary information or follow-on request will be sent to the holder together with the timetable stating the date by when the holder should submit the requested data and where appropriate the extended evaluation period.

 

The procedure will be suspended until the receipt of the supplementary information. In general, a suspension of up to 1 month will typically apply. For suspension longer than 1 month the holder should send a justified request to the Agency for agreement by the Committee for Medicinal Products for Human or the Committee for Veterinary Medicinal Products.

 

For any follow-on request for supplementary information, an additional clock-stop of up to 1 month will be applied in general; a maximum of 2 months may be applied when justified.

 

The Committee assessment of responses may take up to 30 or 60 days depending on the complexity and amount of data provided by the marketing authorisation holder.

 

An oral explanation to the Committee for Medicinal Products for Human Use or the Committee for Veterinary Medicinal Products can be held at the request of the relevant Committee or the marketing authorisation holder, where appropriate.

3.5.   Outcome of the worksharing assessment involving medicinal products authorised under the centralised procedure

By the end of the evaluation period, the Agency will adopt an opinion on the application, including the assessment report. The Agency will inform the holder and Member States concerned (if applicable). In case of disagreement with the opinion, holders may request a re-examination thereof in accordance with the procedure set out in Articles 9(2) and 34(2) of Regulation (EC) No 726/2004.

Where the opinion of the Agency is favourable and the variation(s) affects the terms of the Commission decision(s) granting the marketing authorisation, the Agency will transmit to the Commission its opinion and the grounds for its opinion as well as the necessary documents to amend the marketing authorisation.

If the Agency considers that some variations are not approvable, the list of variations that are not considered approvable should be attached in the Opinion. Variations may be considered approvable for some of the concerned products only.

Upon receipt of a favourable opinion by the Member States concerned or the Commission, the following steps apply:

For medicinal products authorised under the mutual recognition procedure or purely national procedures, the Member States concerned must approve the opinion, inform the Agency accordingly and, where necessary, amend the national marketing authorisations within 60 days provided that the necessary documents to amend the marketing authorisation(s) have been submitted.

Minor variation(s) of Type IB (with the exception of those grouped with major variation(s) of Type II) may be implemented upon receipt of the favourable opinion of the Agency.

Major variation(s) of Type II (and those minor variation(s) of Type IB grouped with the Type II variation) may be implemented 30 days after receipt of the favourable opinion from the Agency provided that (i) the documents necessary for the amendment of the marketing authorisation(s) have been submitted to the Member States concerned, and (ii) the application has not been the object of a referral.

For centrally authorised products, the Commission will, where necessary and provided that the necessary documents to amend the marketing authorisation(s) have been submitted, amend the relevant authorisation(s) within 2 months in the following cases:

(i)

variations related to the addition of a new therapeutic indication or to the modification of an existing one;

(ii)

variations related to the addition of a new contraindication;

(iii)

variations related to a change in posology;

(iv)

variations related to the addition of a non-food producing target species or the modification of an existing one for veterinary medicinal products;

(v)

variations concerning the replacement or addition of a serotype, strain, antigen or combination of serotypes, strains or antigens for a veterinary vaccine;

(vi)

variations related to changes to the active substance of a seasonal, pre-pandemic or pandemic vaccine against human influenza;

(vii)

variations related to changes to the withdrawal period for a veterinary medicinal product;

(viii)

other type II variations that are intended to implement changes to the decision granting the marketing authorisation due to a significant public health concern or significant animal health or environmental concern in the case of veterinary medicinal products.

In the case of other variations, the Commission will amend the decision granting the marketing authorisation at the latest within 12 months.

Minor variation(s) of Type IB (with the exception of those grouped with major variation(s) of Type II) may be implemented upon receipt of the favourable opinion of the Agency.

Major variation(s) of Type II (and those minor variation(s) of Type IB grouped with the Type II variation), with the exception of variations that require the adoption of a Commission decision within 2 months, may be implemented 30 days after receipt of the favourable opinion from the Agency, provided that the necessary documents to amend the marketing authorisation(s) have been submitted.

4.   ANNEX

This Annex consists of four chapters classifying variations related to: A) Administrative changes; B) Quality changes; C) Safety, Efficacy and Pharmacovigilance changes and D) Specific changes to Plasma Master Files and Vaccine Antigen Master Files.

Where reference has to be made to specific variations in this Annex, the variation in question should be quoted using the following structure: X.N.x.n (‘variation code’).

X refers to the capital letter of the chapter in this Annex where the variation is included (e.g. A, B, C or D)

N refers to the roman number of the section inside a chapter where the variation is included (e.g. I, II, III, etc.)

x refers to the letter of the subsection inside a chapter where the variation is included (e.g. a, b, c, etc.)

n refers to the number given in this Annex to a specific variation (e.g. 1, 2, 3, etc.)

For each chapter this Annex contains:

A list of variations which should be classified as minor variations of Type IA or major variations of Type II in accordance with the definitions of Article 2 and Annex II to the Variations Regulation. It is also indicated which minor variations of Type IA require immediate notification as established in Article 8(1) of the Variations Regulation

A list of variations that should be considered as minor variations of Type IB,. It is noted that, in accordance with Article 3 of the Variations Regulation, this category applies by default. Accordingly, this Annex does not attempt to establish an exhaustive list for this category of variations.

This Annex does not deal with the classification of extensions as they are exhaustively listed in Annex I of the Variations Regulation. All changes specified in Annex I of the Variations Regulation must be considered extensions of the marketing authorisations; any other change can not be classified as such.

When one or more of the conditions established in this Annex for a minor variation of Type IA are not met, the concerned change may be submitted as a Type IB variation (‘Type IB by default’) unless the change is specifically classified as a major variation of Type II in this Annex or in a recommendation pursuant to Article 5 of the Variations Regulation, or unless the applicant considers that the changes may have a significant impact on the quality, safety or efficacy of the medicinal product.

If the competent authority considers that a variation submitted as a Type IB by default may have a significant impact on the quality, safety or efficacy of the medicinal product, it may request that the application be upgraded and processed as a Type II variation.

For the purpose of this Annex ‘test procedure’ has the same meaning as ‘analytical procedure’; ‘limits’ has the same meaning as ‘acceptance criteria’. ‘Specification parameter’ means the quality attribute for which a test procedure and limits are set, e.g. assay, identity, water content. The addition or deletion of a specification parameter therefore includes its corresponding test method and limits.

When several minor changes are taking place (e.g. to the same method or process or material) at the same time or in cases of a major update of the quality information for the active substance or the finished product, the applicant should take into account the overall impact of these changes on the quality, safety or efficacy of the medicinal product when considering the appropriate classification and submit them accordingly.

Specific supporting data for Type IB and Type II variations will depend on the specific nature of the change.

Furthermore, if a variation leads to a revision of the summary of product characteristics, labelling or package leaflet (jointly referred to as ‘the product information’), this change is considered part of that variation. In such cases updated product information has to be submitted as part of the application with the relevant translations. Mock-ups or specimens should be provided to the reference Member State, the national competent authority or the Agency.

There is no need to notify the competent authorities of an updated monograph of the European pharmacopoeia or a national pharmacopoeia of a Member State in the case that reference is made to the ‘current edition’ in the dossier of an authorised medicinal product. Applicants are reminded that compliance with the updated monograph should be implemented within 6 months.

Any change to the content of the dossier that supports a European Pharmacopoeia Certificate of Suitability, should be submitted to the European Directorate for the Quality of Medicines (EDQM). However, if the certificate is revised following EDQM evaluation of this change, any marketing authorisation concerned must be updated accordingly.

With reference to Part III point 1 of Annex I of Directive 2001/83/EC, changes to Plasma Master Files (hereinafter PMFs) and Vaccine Antigen Master Files (VAMFs) follow the evaluation procedures for variations set-out in the Variations Regulation. Therefore, Chapter D in this guideline provides a list of variations which are specific to such PMFs or VAMFs. Following review of these variations, any marketing authorisation concerned must be updated in accordance with Chapter B.V of this guideline. In case the documentation of the human plasma used as starting material for a plasma derived medicinal product is not submitted as a PMF, variations to this starting material as described in the marketing authorisation dossier should also be handled in accordance with this Annex.

References in this Annex to changes to the marketing authorisation dossier mean addition, replacement or deletion, unless specifically indicated. If amendments to the dossier only concern editorial changes, such changes should generally not be submitted as a separate variation, but they can be included in a variation concerning that part of the dossier. In such cases the changes should be clearly identified in the application form as editorial changes and a declaration that the content of the concerned part of the dossier has not been changed by the editorial changes beyond the scope of the variation submitted should be provided. It should be noted that editorial changes include the removal of obsolete or redundant text but not the removal of specification parameters or manufacturing descriptions.


(1)  OJ L 334, 12.12.2008, p. 7.

(2)  OJ L 209, 4.8.2012, p. 4.

(3)  OJ L 136, 30.4.2004, p. 1.

(4)  OJ L 311, 28.11.2001, p. 1.

(5)  OJ L 311, 28.11.2001, p. 67.

(6)  OJ L 15, 17.1.1987, p. 38.

(7)  OJ C 229, 22.7.1998, p. 4.

(8)  In this context, where reference is made to ‘reference Member State’, this applies to products approved via the mutual recognition procedure; where reference is made to ‘national competent authority’, this applies to products approved via purely national procedure; and where reference is made to the Agency, this applies to products approved via the centralised procedure.

(9)  OJ L 35, 15.2.1995, p. 1.

(10)  OJ L 378, 27.12.2006, p. 1.

(11)  From 6 July 2009, this Regulation has been repealed by Regulation (EC) No 469/2009.


ANNEX

Topic/Scope of changes

Variation

Page

A.

ADMINISTRATIVE CHANGES

1-8

21

B.

QUALITY CHANGES

23

I.

Active Substance

23

a)

Manufacture …

1-5

23

b)

Control of active substance …

1-2

28

c)

Container closure system …

1-3

30

d)

Stability …

1

33

e)

Design Space and post approval change management protocol …

1-5

34

II.

Finished Product

35

a)

Description and composition …

1-6

35

b)

Manufacture …

1-5

40

c)

Control of excipients …

1-4

47

d)

Control of finished product …

1-3

50

e)

Container closure system …

1-7

52

f)

Stability …

1

57

g)

Design Space and post approval change management protocol …

1-5

59

h)

Adventitious Agents Safety …

1

60

III.

CEP/TSE/monographs

1-2

61

IV.

Medical Devices

1-3

64

V.

Changes to a marketing authorisation resulting from other regulatory procedures

66

a)

PMF/VAMF …

1-2

66

b)

Referral …

1

67

C.

SAFETY, EFFICACY, PHARMACOVIGILANCE CHANGES

68

I.

Human and Veterinary medicinal products

1-13

68

II.

Veterinary medicinal product — specific changes

1-8

73

D.

PMF/VAMF

1-23

74

A.   ADMINISTRATIVE CHANGES

A.1

Change in the name and/or address of the marketing authorisation holder

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

1

1, 2

IAIN

Conditions

1.

The marketing authorisation holder must remain the same legal entity.

Documentation

1.

A formal document from a relevant official body (e.g. Chamber of Commerce) in which the new name or new address is mentioned.

2.

Revised product information.

A.2

Change in the (invented) name of the medicinal product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

for Centrally Authorised products

1

1, 2

IAIN

b)

for Nationally Authorised Products

 

2

IB

Conditions

1.

The check by the EMA on the acceptability of the new name has been finalised and was positive.

Documentation

1.

Copy of the EMA letter of acceptance of the new (invented) name.

2.

Revised product information.

A.3

Change in name of the active substance or of an excipient

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

1, 2

1, 2

IAIN

Conditions

1.

The active substance/excipient must remain the same.

2.

For veterinary medicinal products for food-producing species, the new name has been published in Regulation (EC) No 470/2009 of the European Parliament and of the Council of 6 May 2009 laying down Community procedures for the establishment of residue limits of pharmacologically active substances in foodstuffs of animal origin, repealing Council Regulation (EEC) No 2377/90 and amending Directive 2001/82/EC of the European Parliament and of the Council and Regulation (EC) No 726/2004 of the European Parliament and of the Council before implementation of this change.

Documentation

1.

Proof of acceptance by WHO or copy of the INN list. If applicable, proof that the change is in line with the Ph. Eur. For herbal medicinal product, declaration that the name is in accordance with the Note for Guidance on Quality of Herbal Medicinal Products, and with the guideline on declaration of herbal substances and herbal preparations in (traditional) herbal medicinal products.

2.

Revised product information

A.4

Change in the name and/or address of: a manufacturer (including where relevant quality control testing sites); or an ASMF holder; or a supplier of the active substance, starting material, reagent or intermediate used in the manufacture of the active substance (where specified in the technical dossier) where no Ph. Eur. Certificate of Suitability is part of the approved dossier; or a manufacturer of a novel excipient (where specified in the technical dossier)

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

1

1, 2, 3

IA

Conditions

1.

The manufacturing site and all manufacturing operations must remain the same.

Documentation

1.

A formal document from a relevant official body (e.g. Chamber of Commerce) in which the new name and/or address is mentioned.

2.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

3.

In case of change in the name of the holder of the Active Substance Master File holder, updated ‘letter of access’.

A.5

Change in the name and/or address of a manufacturer/importer of the finished product (including batch release or quality control testing sites)

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

The activities for which the manufacturer/importer is responsible include batch release

1

1, 2

IAIN

b)

The activities for which the manufacturer/importer is responsible do not include batch release

1

1, 2

IA

Conditions

1.

The manufacturing site undergoing the name and/or address change and all manufacturing operations must remain the same.

Documentation

1.

Copy of the modified manufacturing authorisation, if available; or a formal document from a relevant official body (e.g. Chamber of Commerce, or if not available, from a Regulatory Agency) in which the new name and/or address is mentioned.

2.

If applicable, amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including revised product information as appropriate.

A.6

Change in ATC Code/ATC Vet Code

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

1

1, 2

IA

Conditions

1.

Change following granting of or amendment to ATC Code by WHO/ATC Vet Code.

Documentation

1.

Proof of acceptance (by WHO) or copy of the ATC (Vet) Code list.

2.

Revised product information

A.7

Deletion of manufacturing sites for an active substance, intermediate or finished product, packaging site, manufacturer responsible for batch release, site where batch control takes place, or supplier of a starting material, reagent or excipient (when mentioned in the dossier)  (1)

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

1, 2

1, 2

IA

Conditions

1.

There should at least remain one site/manufacturer, as previously authorised, performing the same function as the one(s) concerned by the deletion. Where applicable at least one manufacturer responsible for batch release that is able to certify the product testing for the purpose of batch release within the EU/EEA remains in the EU/EEA.

2.

The deletion should not be due to critical deficiencies concerning manufacturing.

Documentation

1.

The variation application form should clearly outline the ‘present’ and ‘proposed’ manufacturers as listed in section 2.5 of the application form for marketing authorisations.

2.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including revised product information as appropriate.

A.8

Changes to date of the audit to verify GMP compliance of the manufacturer of the active substance  (2)

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

 

 

IA

Documentation

1.

Written confirmation from the manufacturer of the finish product stating verification of compliance of the manufacturer of the active substance with principles and guidelines of good manufacturing practices.

B.   QUALITY CHANGES

B.I   ACTIVE SUBSTANCE

B.I.a)   Manufacture

B.I.a.1

Change in the manufacturer of a starting material/reagent/intermediate used in the manufacturing process of the active substance or change in the manufacturer (including where relevant quality control testing sites) of the active substance, where no Ph. Eur. Certificate of Suitability is part of the approved dossier

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

The proposed manufacturer is part of the same pharmaceutical group as the currently approved manufacturer

1, 2, 3

1, 2, 3, 4, 5, 6, 7

IAIN

b)

Introduction of a manufacturer of the active substance supported by an ASMF

 

 

II

c)

The proposed manufacturer uses a substantially different route of synthesis or manufacturing conditions, which may have a potential to change important quality characteristics of the active substance, such as qualitative and/or quantitative impurity profile requiring qualification, or physico-chemical properties impacting on bioavailability

 

 

II

d)

New manufacturer of material for which an assessment is required of viral safety and/or TSE risk

 

 

II

e)

The change relates to a biological active substance or a starting material/reagent/intermediate used in the manufacture of a biological/immunological product

 

 

II

f)

Changes to quality control testing arrangements for the active substance-replacement or addition of a site where batch control/testing takes place

2, 4

1, 5

IA

g)

Introduction of a new manufacturer of the active substance that is not supported by an ASMF and requires significant update to the relevant active substance section of the dossier

 

 

II

h)

Addition of an alternative sterilisation site for the active substance using a Ph.Eur. method

 

1, 2, 4, 5, 8

IB

i)

Introduction of a new site of micronisation

2, 5

1, 4, 5, 6

IA

j)

Changes to quality control testing arrangements for a biological active substance: replacement or addition of a site where batch control/testing including a biological/immunological/immunochemical method takes place

 

 

II

k)

New storage site of Master Cell Bank and/or Working Cell Banks

 

1, 5

IB

Conditions

1.

For starting materials and reagents the specifications (including in process controls, methods of analysis of all materials), are identical to those already approved. For intermediates and active substances the specifications (including in process controls, methods of analysis of all materials), method of preparation (including batch size) and detailed route of synthesis are identical to those already approved.

2.

The active substance is not a biological/immunological substance or sterile.

3.

Where materials of human or animal origin are used in the process, the manufacturer does not use any new supplier for which assessment is required of viral safety or of compliance with the current Note for Guidance on Minimising the Risk of Transmitting Animal Spongiform Encephalopathy Agents via Human and Veterinary Medicinal Products.

4.

Method transfer from the old to the new site has been successfully completed.

5.

The particle size specification of the active substance and the corresponding analytical method remain the same.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), if applicable.

2.

A declaration from the marketing authorisation holder or the ASMF holder, where applicable, that the synthetic route (or in case of herbal medicinal products, where appropriate the method of preparation, geographical source, production of herbal drug and manufacturing route) quality control procedures and specifications of the active substance and of the starting material/reagent/intermediate in the manufacturing process of the active substance (if applicable) are the same as those already approved.

3.

Either a TSE Ph. Eur. Certificate of Suitability for any new source of material or, where applicable, documentary evidence that the specific source of the TSE risk material has previously been assessed by the competent authority and shown to comply with the current Note for Guidance on Minimising the Risk of Transmitting Animal Spongiform Encephalopathy Agents via Human and Veterinary Medicinal Products. The information should include the following: Name of manufacturer, species and tissues from which the material is a derivative, country of origin of the source animals, its use and previous acceptance. For the Centralised Procedure, this information should be included in an updated TSE table A (and B, if relevant).

4.

Batch analysis data (in a comparative tabular format) for at least two batches (minimum pilot scale) of the active substance from the current and proposed manufacturers/sites.

5.

The variation application form should clearly outline the ‘present’ and ‘proposed’ manufacturers as listed in section 2.5 of the application form for marketing authorisation.

6.

A declaration by the Qualified Person (QP) of each of the manufacturing authorisation holders listed in the application where the active substance is used as a starting material and a declaration by the Qualified Person (QP) of each of the manufacturing authorisation holders listed in the application as responsible for batch release. These declarations should state that the active substance manufacturer(s) referred to in the application operate in compliance with the detailed guidelines on good manufacturing practice for starting materials. A single declaration may be acceptable under certain circumstances — see the note under variation No B.II.b.1.

7.

Where relevant, a commitment of the manufacturer of the active substance to inform the MA holder of any changes to the manufacturing process, specifications and test procedures of the active substance.

8.

Proof that the proposed site is appropriately authorised for the pharmaceutical form or product or manufacturing operation concerned, i.e.:

 

For a manufacturing site within the EU/EEA: a copy of the current manufacturing authorisation. A reference to the EudraGMP database will suffice.

 

For a manufacturing site outside the EU/EEA where an operational GMP mutual recognition agreement (MRA) exists between the country concerned and the EU: a GMP certificate issued within the last 3 years by the relevant competent authority.

 

For a manufacturing site outside the EU/EEA where no such mutual recognition agreement exists: a GMP certificate issued within the last 3 years by an inspection service of one of the Member States of the EU/EEA. A reference to the EudraGMP database will suffice.

B.I.a.2

Changes in the manufacturing process of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor change in the manufacturing process of the active substance

1, 2, 3, 4, 5, 6, 7

1, 2, 3

IA

b)

Substantial change to the manufacturing process of the active substance which may have a significant impact on the quality, safety or efficacy of the medicinal product

 

 

II

c)

The change refers to a biological/immunological substance or use of a different chemically derived substance in the manufacture of a biological/immunological substance, which may have a significant impact on the quality, safety and efficacy of the medicinal product and is not related to a protocol

 

 

II

d)

The change relates to a herbal medicinal product and there is a change to any of the following: geographical source, manufacturing route or production

 

 

II

e)

Minor change to the restricted part of an Active Substance Master File

 

1, 2, 3, 4

IB

Conditions

1.

No adverse change in qualitative and quantitative impurity profile or in physico-chemical properties.

2.

The synthetic route remains the same, i.e. intermediates remain the same and there are no new reagents, catalysts or solvents used in the process. In the case of herbal medicinal products, the geographical source, production of the herbal substance and the manufacturing route remain the same.

3.

The specifications of the active substance or intermediates are unchanged.

4.

The change is fully described in the open (‘applicant’s’) part of an Active Substance Master File, if applicable.

5.

The active substance is not a biological/immunological substance.

6.

The change does not refer to the geographical source, manufacturing route or production of a herbal medicinal product.

7.

The change does not refer to the restricted part of an Active Substance Master File.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), and of the approved Active Substance Master File (where applicable), including a direct comparison of the present process and the new process.

2.

Batch analysis data (in comparative tabular format) of at least two batches (minimum pilot scale) manufactured according to the currently approved and proposed process.

3.

Copy of approved specifications of the active substance.

4.

A declaration from the marketing authorisation holder or the ASMF Holder, where applicable, that there is no change in qualitative and quantitative impurity profile or in physico-chemical properties, that the synthetic route remains the same and that the specifications of the active substance or intermediates are unchanged.

Note:

for B.I.a.2.b), for chemical active substances, this refers to substantial changes to the synthetic route or manufacturing conditions which may have a potential to change important quality characteristics of the active substance, such as qualitative and/or quantitative impurity profile requiring qualification, or physico-chemical properties impacting on bioavailability.

B.I.a.3

Change in batch size (including batch size ranges) of active substance or intermediate used in the manufacturing process of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Up to 10-fold increase compared to the originally approved batch size

1, 2, 3, 4, 6, 7, 8

1, 2, 5

IA

b)

Downscaling down to 10-fold

1, 2, 3, 4, 5

1, 2, 5

IA

c)

The change requires assessment of the comparability of a biological/immunological active substance

 

 

II

d)

More than 10-fold increase compared to the originally approved batch size

 

1, 2, 3, 4

IB

e)

The scale for a biological/immunological active substance is increased/decreased without process change (e.g. duplication of line)

 

1, 2, 3, 4

IB

Conditions

1.

Any changes to the manufacturing methods are only those necessitated by scale-up or downscaling, e.g. use of different-sized equipment.

2.

Test results of at least two batches according to the specifications should be available for the proposed batch size.

3.

The product concerned is not a biological/immunological medicinal product.

4.

The change does not adversely affect the reproducibility of the process.

5.

The change should not be the result of unexpected events arising during manufacture or because of stability concerns.

6.

The specifications of the active substance/intermediates remain the same.

7.

The active substance is not sterile.

8.

The batch size is within the 10-fold range of the batch size foreseen when the marketing authorisation was granted or following a subsequent change not agreed as a Type IA variation.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

The batch numbers of the tested batches having the proposed batch size.

3.

Batch analysis data (in a comparative tabulated format) on a minimum of one production batch of the active substance or intermediate as appropriate, manufactured to both the currently approved and the proposed sizes. Batch data on the next two full production batches should be made available upon request and reported by the marketing authorisation holder if outside specification (with proposed action).

4.

Copy of approved specifications of the active substance (and of the intermediate, if applicable).

5

A declaration from the marketing authorisation holder or the ASMF holder as appropriate that the changes to the manufacturing methods are only those necessitated by scale-up or downscaling, e.g. use of different-sized equipment, that the change does not adversely affect the reproducibility of the process, that it is not the result of unexpected events arising during manufacture or because of stability concerns and that the specifications of the active substance/intermediates remain the same.

B.I.a.4

Change to in-process tests or limits applied during the manufacture of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Tightening of in-process limits

1, 2, 3, 4

1, 2

IA

b)

Addition of a new in-process test and limits

1, 2, 5, 6

1, 2, 3, 4, 6

IA

c)

Deletion of a non-significant in-process test

1, 2, 7

1, 2, 5

IA

d)

Widening of the approved in-process test limits, which may have a significant effect on the overall quality of the active substance

 

 

II

e)

Deletion of an in-process test which may have a significant effect on the overall quality of the active substance

 

 

II

f)

Addition or replacement of an in-process test as a result of a safety or quality issue

 

1, 2, 3, 4, 6

IB

Conditions

1.

The change is not a consequence of any commitment from previous assessments to review specification limits (e.g. made during the procedure for the marketing authorisation application or a type II variation procedure).

2.

The change does not result from unexpected events arising during manufacture, e.g. new unqualified impurity; change in total impurity limits.

3.

Any change should be within the range of currently approved limits.

4.

The test procedure remains the same, or changes in the test procedure are minor.

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

6.

The new test method is not a biological/immunological/immunochemical method or a method using a biological reagent for a biological active substance (does not include standard pharmacopoeial microbiological methods).

7.

The specification parameter does not concern a critical parameter for example any of the following: assay, impurities (unless a particular solvent is definitely not used in the manufacture of the active substance), any critical physical characteristics, e.g. particle size, bulk or tapped density, identity test, water, any request for changing the frequency of testing.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Comparative table of current and proposed in-process tests.

3.

Details of any new non-pharmacopoeial analytical method and validation data, where relevant.

4.

Batch analysis data on two production batches (3 production batches for biologicals, unless otherwise justified) of the active substance for all specification parameters.

5.

Justification/risk assessment from the marketing authorisation holder or the ASMF Holder, as appropriate, that the in-process tests are non-significant, or that the in-process tests are obsolete.

6.

Justification from the MAH or ASMF Holder as appropriate for the new in-process test and limits.

B.I.a.5

Changes to the active substance of a seasonal, pre-pandemic or pandemic vaccine against human influenza

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Replacement of the strain(s) in a seasonal, pre-pandemic or a pandemic vaccine against human influenza

 

 

II


B.I.b)   Control of active substance

B.I.b.1

Change in the specification parameters and/or limits of an active substance, starting material/intermediate/reagent used in the manufacturing process of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Tightening of specification limits for medicinal products subject to Official Control Authority Batch Release

1, 2, 3, 4

1, 2

IAIN

b)

Tightening of specification limits

1, 2, 3, 4

1, 2

IA

c)

Addition of a new specification parameter to the specification with its corresponding test method

1, 2, 5, 6, 7

1, 2, 3, 4, 5, 7

IA

d)

Deletion of a non-significant specification parameter (e.g. deletion of an obsolete parameter)

1, 2, 8

1, 2, 6

IA

e)

Deletion of a specification parameter which may have a significant effect on the overall quality of the active substance and/or the finished product

 

 

II

f)

Change outside the approved specifications limits range for the active substance

 

 

II

g)

Widening of the approved specifications limits for starting materials/intermediates, which may have a significant effect on the overall quality of the active substance and/or the finished product

 

 

II

h)

Addition or replacement (excluding biological or immunological substance) of a specification parameter with its corresponding test method as a result of a safety or quality issue

 

1, 2, 3, 4, 5, 7

IB

i)

Where there is no monograph in the European Pharmacopoeia or the national pharmacopoeia of a Member State for the active substance, a change in specification from in-house to a non-official Pharmacopoeia or a Pharmacopoeia of a third country

 

1, 2, 3, 4, 5, 7

IB

Conditions

1.

The change is not a consequence of any commitment from previous assessments to review specification limits (e.g. made during the procedure for the marketing authorisation application or a type II variation procedure).

2.

The change does not result from unexpected events arising during manufacture, e.g. new unqualified impurity; change in total impurity limits.

3.

Any change should be within the range of currently approved limits.

4.

The test procedure remains the same, or changes in the test procedure are minor.

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

6.

The test method is not a biological/immunological/immunochemical method or a method using a biological reagent for a biological active substance (does not include standard pharmacopoeia microbiological methods).

7.

For any material, the change does not concern a genotoxic impurity. If it involves the final active substance, other than for residual solvents which must be in line with ICH/VICH limits, any new impurity control should be in line with the Ph. Eur. or National Pharmacopoeia of a Member State.

8.

The specification parameter does not concern a critical parameter, for example any of the following: assay, impurities (unless a particular solvent is definitely not used in the manufacture of the active substance), any critical physical characteristics, e.g. particle size, bulk or tapped density, identity test, water, any request for skip testing.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Comparative table of current and proposed specifications.

3.

Details of any new analytical method and validation data, where relevant.

4.

Batch analysis data on two production batches (3 production batches for biologicals, unless otherwise justified) of the relevant substance for all specification parameters.

5.

Where appropriate, comparative dissolution profile data for the finished product on at least one pilot batch containing the active substance complying with the current and proposed specification. For herbal medicinal products, comparative disintegration data may be acceptable.

6.

Justification/risk assessment from the marketing authorisation holder or the ASMF Holder, as appropriate, that the in-process parameter is non-significant, or that the in-process parameter is obsolete.

7.

Justification from the MAH or ASMF Holder as appropriate of the new specification parameter and the limits.

B.I.b.2

Change in test procedure for active substance or starting material/reagent/intermediate used in the manufacturing process of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor changes to an approved test procedure

1, 2, 3, 4

1, 2

IA

b)

Deletion of a test procedure for the active substance or a starting material/reagent/intermediate, if an alternative test procedure is already authorised.

7

1

IA

c)

Other changes to a test procedure (including replacement or addition) for a reagent, which does not have a significant effect on the overall quality of the active substance

1, 2, 3, 5, 6

1, 2

IA

d)

Substantial change to or replacement of a biological/immunological/immunochemical test method or a method using a biological reagent for a biological active substance

 

 

II

e)

Other changes to a test procedure (including replacement or addition) for the active substance or a starting material/intermediate

 

1, 2

IB

Conditions

1.

Appropriate validation studies have been performed in accordance with the relevant guidelines and show that the updated test procedure is at least equivalent to the former test procedure.

2.

There have been no changes of the total impurity limits; no new unqualified impurities are detected.

3.

The method of analysis should remain the same (e.g. a change in column length or temperature, but not a different type of column or method).

4.

The test method is not a biological/immunological/immunochemical method, or a method using a biological reagent for a biological active substance (does not include standard pharmacopoeial microbiological methods).

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

6.

The active substance is not biological/immunological.

7

An alternative test procedure is already authorised for the specification parameter and this procedure has not been added through IA/IA(IN) notification.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a description of the analytical methodology, a summary of validation data, revised specifications for impurities (if applicable).

2.

Comparative validation results, or if justified comparative analysis results showing that the current test and the proposed one are equivalent. This requirement is not applicable in case of an addition of a new test procedure.


B.I.c)   Container closure system

B.I.c.1

Change in immediate packaging of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Qualitative and/or quantitative composition

1, 2, 3

1, 2, 3, 4, 6

IA

b)

Qualitative and/or quantitative composition for sterile and non-frozen biological/immunological active substances

 

 

II

c)

Liquid active substances (non-sterile)

 

1, 2, 3, 5, 6

IB

Conditions

1.

The proposed packaging material must be at least equivalent to the approved material in respect of its relevant properties.

2

Relevant stability studies have been started under ICH/VICH conditions and relevant stability parameters have been assessed in at least two pilot scale or industrial scale batches and at least 3 months satisfactory stability data are at the disposal of the applicant at time of implementation. However, if the proposed packaging is more resistant than the existing packaging, the 3 months’ stability data do not yet have to be available. These studies must be finalised and the data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the shelf-life/retest period (with proposed action).

3

Sterile, liquid and biological/immunological active substances are excluded.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Appropriate data on the new packaging (e.g. comparative data on permeability, e.g. for O2, CO2 moisture), including a confirmation that the material complies with relevant pharmacopoeial requirements or legislation of the Union on plastic materials and objects in contact with foodstuffs.

3.

Where appropriate, proof must be provided that no interaction between the content and the packaging material occurs (e.g. no migration of components of the proposed material into the content and no loss of components of the product into the pack), including confirmation that the material complies with relevant pharmacopoeia requirements or legislation of the Union on plastic material and objects in contact with foodstuffs.

4.

A declaration from the marketing authorisation holder or the ASMF holder as appropriate that the required stability studies have been started under ICH/VICH conditions (with indication of the batch numbers concerned) and that, as relevant, the required minimum satisfactory stability data were at the disposal of the applicant at time of implementation and that the available data did not indicate a problem. Assurance should also be given that the studies will be finalised and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

5.

The results of stability studies that have been carried out under ICH/VICH conditions, on the relevant stability parameters, on at least two pilot or industrial scale batches, covering a minimum period of 3 months, and an assurance is given that these studies will be finalised, and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved retest period (with proposed action).

6.

Comparison of the current and proposed immediate packaging specifications, if applicable.

B.I.c.2

Change in the specification parameters and/or limits of the immediate packaging of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Tightening of specification limits

1, 2, 3, 4

1, 2

IA

b)

Addition of a new specification parameter to the specification with its corresponding test method

1, 2, 5

1, 2, 3, 4, 6

IA

c)

Deletion of a non-significant specification parameter (e.g. deletion of an obsolete parameter)

1, 2

1, 2, 5

IA

d)

Addition or replacement of a specification parameter as a result of a safety or quality issue

 

1, 2, 3, 4, 6

IB

Conditions

1.

The change is not a consequence of any commitment from previous assessments to review specification limits (e.g. made during the procedure for the marketing authorisation application or a type II variation procedure) unless it has been previously assessed and agreed as part of a follow-up measure.

2.

The change does not result from unexpected events arising during manufacture of the packaging material or during storage of the active substance.

3.

Any change should be within the range of currently approved limits.

4.

The test procedure remains the same, or changes in the test procedure are minor.

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Comparative table of current and proposed specifications.

3.

Details of any new analytical method and validation data, where relevant.

4.

Batch analysis data on two batches of the immediate packaging for all specification parameters.

5

Justification/risk assessment from the marketing authorisation holder or the ASMF Holder, as appropriate, that the in-process parameter is non-significant, or that the in-process parameter is obsolete.

6.

Justification from the marketing authorisation holder or the ASMF Holder, as appropriate, of the new specification parameter and the limits.

B.I.c.3

Change in test procedure for the immediate packaging of the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor changes to an approved test procedure

1, 2, 3,

1, 2

IA

b)

Other changes to a test procedure (including replacement or addition)

1, 3, 4

1, 2

IA

c)

Deletion of a test procedure if an alternative test procedure is already authorised

5

1

IA

Conditions

1.

Appropriate validation studies have been performed in accordance with the relevant guidelines and show that the updated test procedure is at least equivalent to the former test procedure.

2.

The method of analysis should remain the same (e.g. a change in column length or temperature, but not a different type of column or method).

3.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

4.

The active substance/finished product is not biological/immunological.

5.

There is still a test procedure registered for the specification parameter and this procedure has not been added through a IA/IA(IN) notification.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a description of the analytical methodology, a summary of validation data.

2.

Comparative validation results or if justified comparative analysis results showing that the current test and the proposed one are equivalent. This requirement is not applicable in case of an addition of a new test procedure.


B.I.d)   Stability

B.I.d.1

Change in the retest period/storage period or storage conditions of the active substance where no Ph. Eur. Certificate of Suitability covering the retest period is part of the approved dossier

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)   Retest period/storage period

1.

Reduction

1

1, 2, 3

IA

2.

Extension of the retest period based on extrapolation of stability data not in accordance with ICH/VICH guidelines  (3)

 

 

II

3.

Extension of storage period of a biological/immunological active substance not in accordance with an approved stability protocol

 

 

II

4.

Extension or introduction of a retest period/storage period supported by real time data

 

1, 2, 3

IB

b)   Storage conditions

1.

Change to more restrictive storage conditions of the active substance

1

1, 2, 3

IA

2.

Change in storage conditions of biological/immunological active substances, when the stability studies have not been performed in accordance with a currently approved stability protocol

 

 

II

3.

Change in storage conditions of the active substance

 

1, 2, 3

IB

c)

Change to an approved stability protocol

1, 2

1, 4

IA

Conditions

1.

The change should not be the result of unexpected events arising during manufacture or because of stability concerns.

2.

The changes do not concern a widening of the acceptance criteria in the parameters tested, a removal of stability indicating parameters or a reduction in the frequency of testing.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate). This must contain results of appropriate real time stability studies,conducted in accordance with the relevant stability guidelines on at least two (three for biological medicinal products) pilot or production scale batches of the active substance in the authorised packaging material and covering the duration of the requested retest period or requested storage conditions.

2.

Confirmation that stability studies have been done to the currently approved protocol. The studies must show that the agreed relevant specifications are still met.

3.

Copy of approved specifications of the active substance.

4.

Justification for the proposed changes.


B.I.e)   Design Space and post-approval change management protocols

B.I.e.1

Introduction of a new design space or extension of an approved design space for the active substance, concerning:

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

One unit operation in the manufacturing process of the active substance including the resulting in-process controls and/or test procedures

 

1, 2, 3

II

b)

Test procedures for starting materials/reagents/intermediates and/or the active substance

 

1, 2, 3

II

Documentation

1.

The design space has been developed in accordance with the relevant European and international scientific guidelines. Results from product, process and analytical development studies (e.g. interaction of the different parameters forming the design space have to be studied, including risk assessment and multivariate studies, as appropriate) demonstrating where relevant that a systematic mechanistic understanding of material attributes and process parameters to the critical quality attributes of the active substance has been achieved.

2.

Description of the Design space in tabular format, including the variables (material attributes and process parameters, as appropriate) and their proposed ranges.

3.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

B.I.e.2

Introduction of a post approval change management protocol related to the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

 

1, 2, 3

II

Documentation

1.

Detailed description for the proposed change.

2.

Change management protocol related to the active substance.

3.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

B.I.e.3

Deletion of an approved change management protocol related to the active substance

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

1

1, 2

IAIN

Conditions

1.

The deletion of the approved change management protocol related to the active substance is not a result of unexpected events or out of specification results during the implementation of the change(s) described in the protocol and does not have any effect on the already approved information in the dossier.

Documentation

1.

Justification for the proposed deletion.

2.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

B.I.e.4

Changes to an approved change management protocol

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Major changes to an approved change management protocol

 

 

II

b)

Minor changes to an approved change management protocol that do not change the strategy defined in the protocol

 

1

IB

Documentation

1.

Declaration that any change should be within the range of currently approved limits. In addition, declaration that an assessment of comparability is not required for biological/immunological medicinal products.

B.I.e.5

Implementation of changes foreseen in an approved change management protocol

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

The implementation of the change requires no further supportive data

1

1, 2, 4

IAIN

b)

The implementation of the change requires further supportive data

 

1, 2, 3, 4

IB

c)

Implementation of a change for a biological/immunological medicinal product

 

1, 2, 3, 4, 5

IB

Conditions

1.

The proposed change has been performed fully in line with the approved change management protocol.

Documentation

1.

Reference to the approved change management protocol.

2.

Declaration that the change is in accordance with the approved change management and that the study results meet the acceptance criteria specified in the protocol. In addition, declaration that an assessment of comparability is not required for biological/immunological medicinal products.

3.

Results of the studies performed in accordance with the approved change management protocol.

4.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

5.

Copy of approved specifications of the active substance.

B.II.   FINISHED PRODUCT

B.II.a)   Description and composition

B.II.a.1

Change or addition of imprints, bossing or other markings including replacement, or addition of inks used for product marking.

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Changes in imprints, bossing or other markings

1, 2, 3, 4

1, 2

IAIN

b)

Changes in scoring/break lines intended to divide into equal doses

 

1, 2, 3

IB

Conditions

1.

Finished product release and end of shelf life specifications have not been changed (except for appearance).

2.

Any ink must comply with the relevant pharmaceutical legislation.

3.

The scoring/break lines are not intended to divide into equal doses.

4.

Any product markings used to differentiate strengths should not be completely deleted.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a detailed drawing or written description of the current and new appearance, and including revised product information as appropriate.

2.

Samples of the finished product where applicable (see NTA, Requirements for samples in the Member States).

3

Results of the appropriate Ph. Eur tests demonstrating equivalence in characteristics/correct dosing.

B.II.a.2

Change in the shape or dimensions of the pharmaceutical form

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Immediate release tablets, capsules, suppositories and pessaries

1, 2, 3, 4

1, 4

IAIN

b)

Gastro-resistant, modified or prolonged release pharmaceutical forms and scored tablets intended to be divided into equal doses

 

1, 2, 3, 4, 5

IB

c)

Addition of a new kit for a radiopharmaceutical preparation with another fill volume

 

 

II

Conditions

1.

If appropriate, the dissolution profile of the reformulated product is comparable to the old one. For herbal medicinal products, where dissolution testing may not be feasible, the disintegration time of the new product compared to the old one.

2.

Release and end of shelf-life specifications of the product have not been changed (except for dimensions).

3.

The qualitative or quantitative composition and mean mass remain unchanged.

4.

The change does not relate to a scored tablet that is intended to be divided into equal doses.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a detailed drawing of the current and proposed situation, and including revised product information as appropriate.

2.

Comparative dissolution data on at least one pilot batch of the current and proposed dimensions (no significant differences regarding comparability see the relevant (Human or Veterinary) guidance on Bioavailability). For herbal medicinal product comparative disintegration data may be acceptable.

3.

Justification for not submitting a new bioequivalence study according to the relevant (Human or Veterinary) guidance on Bioavailability.

4.

Samples of the finished product where applicable (see NTA, Requirements for samples in the Member States).

5.

Results of the appropriate Ph. Eur tests demonstrating equivalence in characteristics/correct dosing.

Note:

for B.II.a.2.c), applicants are reminded that any change to the ‘strength’ of the medicinal product requires the submission of an Extension application.

B.II.a.3

Changes in the composition (excipients) of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)   Changes in components of the flavouring or colouring system

1.

Addition, deletion or replacement

1, 2, 3, 4, 5, 6, 7, 9, 11

1, 2, 4, 5, 6

IAIN

2.

Increase or reduction

1, 2, 3, 4, 11

1, 2, 4

IA

3.

Biological veterinary medicinal products for oral use for which the colouring or flavouring agent is important for the uptake by target animal species

 

 

II

b)   Other excipients

1.

Any minor adjustment of the quantitative composition of the finished product with respect to excipients

1, 2, 4, 8, 9, 10

1, 2, 7

IA

2.

Qualitative or quantitative changes in one or more excipients that may have a significant impact on the safety, quality or efficacy of the medicinal product

 

 

II

3.

Change that relates to a biological/immunological product

 

 

II

4.

Any new excipient that includes the use of materials of human or animal origin for which assessment is required of viral safety data or TSE risk

 

 

II

5.

Change that is supported by a bioequivalence study

 

 

II

6.

Replacement of a single excipient with a comparable excipient with the same functional characteristics and at a similar level

 

1, 3, 4, 5, 6, 7, 8, 9, 10

IB

Conditions

1.

No change in functional characteristics of the pharmaceutical form, e.g. disintegration time, dissolution profile.

2.

Any minor adjustment to the formulation to maintain the total weight should be made by an excipient which currently makes up a major part of the finished product formulation.

3.

The finished product specification has only been updated in respect of appearance/odour/taste and if relevant, deletion of an identification test.

4.

Stability studies have been started under ICH/VICH conditions (with indication of batch numbers) and relevant stability parameters have been assessed in at least two pilot scale or industrial scale batches and at least 3 months satisfactory stability data are at the disposal of the applicant (at time of implementation for Type IAsand at time of notification for Type IBs) and that the stability profile is similar to the currently registered situation. Assurance is given that these studies will be finalised and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specification at the end of the approved shelf life (with proposed action). In addition, where relevant, photo-stability testing should be performed.

5.

Any new proposed components must comply with the relevant Directives (e.g. Directive 94/36/EC of the European Parliament and of the Council (4) and Commission Directive 2008/128/EC (5) for colours for use in foodstuffs and Council Directive 88/388/EEC (6) for flavours).

6.

Any new component does not include the use of materials of human or animal origin for which assessment is required of viral safety data or compliance with the current Note For Guidance on Minimising the Risk of Transmitting Animal Spongiform Encephalopathy Agents via Human and Veterinary Medicinal Products.

7.

Where applicable, the change does not affect the differentiation between strengths and does not have a negative impact on taste acceptability for paediatric formulations.

8.

The dissolution profile of the new product determined on a minimum of two pilot scale batches is comparable to the old one (no significant differences regarding comparability, see the relevant (Human or Veterinary) guidance on Bioavailability). For herbal medicinal products where dissolution testing may not be feasible, the disintegration time of the new product is comparable to the old one.

9.

The change is not the result of stability issues and/or should not result in potential safety concerns, i.e. differentiation between strengths.

10.

The product concerned is not a biological/immunological medicinal product.

11.

For veterinary medicinal products for oral use, the change does not affect the uptake by target animal species.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including identification method for any new colorant, where relevant, and including revised product information as appropriate.

2.

A declaration that the required stability studies have been started under ICH/VICH conditions (with indication of the batch numbers concerned) and that, as relevant, the required minimum satisfactory stability data were at the disposal of the applicant at time of implementation and that the available data did not indicate a problem. Assurance should also be given that the studies will be finalised and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

3.

The results of stability studies that have been carried out under ICH/VICH conditions, on the relevant stability parameters, on at least two pilot or industrial scale batches, covering a minimum period of 3 months, and an assurance is given that these studies will be finalised, and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

4.

Sample of the new product, where applicable (see Notice to Applicants Requirements for samples in the Member States).

5.

Either a Ph. Eur. Certificate of Suitability for any new component of animal susceptible to TSE risk or where applicable, documentary evidence that the specific source of the TSE risk material has been previously assessed by the competent authority and shown to comply with the scope of the current Note for Guidance on Minimising the Risk of Transmitting Animal Spongiform Encephalopathies via Human and Veterinary Medicinal Products. The following information should be included for each such material: Name of manufacturer, species and tissues from which the material is a derivative, country of origin of the source animals and its use.

For the Centralised Procedure, this information should be included in an updated TSE table A (and B, if relevant).

6.

Data to demonstrate that the new excipient does not interfere with the finished product specification test methods, if appropriate.

7

Justification for the change/choice of excipients etc. must be given by appropriate development pharmaceutics (including stability aspects and antimicrobial preservation where appropriate).

8.

For solid dosage forms, comparative dissolution profile data of at least two pilot scale batches of the finished product in the new and old composition. For herbal medicinal products, comparative disintegration data may be acceptable.

9.

Justification for not submitting a new bioequivalence study according to the current Note for Guidance on The Investigation of Bioavailability and Bioequivalence.

10.

For veterinary medicines intended for use in food producing animal species, proof that the excipient is classified according to Article 14(2)(c) of Regulation (EC) No 470/2009 or, if not, justification that the excipient does not have pharmacological activity at the dose at which it is administered to the target animal.

B.II.a.4

Change in coating weight of oral dosage forms or change in weight of capsule shells

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Solid oral pharmaceutical forms

1, 2, 3, 4

1, 2

IA

b)

Gastro-resistant, modified or prolonged release pharmaceutical forms where the coating is a critical factor for the release mechanism

 

 

II

Conditions

1.

The dissolution profile of the new product determined on a minimum of two pilot scale batches is comparable to the old one. For herbal medicinal products where dissolution testing may not be feasible, the disintegration time of the new product is comparable to the old one.

2.

The coating is not a critical factor for the release mechanism.

3.

The finished product specification has only been updated in respect of weight and dimensions, if applicable.

4.

Stability studies in accordance with the relevant guidelines have been started with at least two pilot scale or industrial scale batches and at least 3 months satisfactory stability data are at the disposal of the applicant at the time of implementation and assurance that these studies will be finalised. Data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

A declaration that the required stability studies have been started under ICH/VICH conditions (with indication of the batch numbers concerned) and that, as relevant, the required minimum satisfactory stability data were at the disposal of the applicant at time of implementation and that the available data did not indicate a problem. Assurance should also be given that the studies will be finalised and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action). In addition, where relevant, photo-stability testing should be performed.

B.II.a.5

Change in concentration of a single-dose, total use parenteral product, where the amount of active substance per unit dose (i.e. the strength) remains the same

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

 

 

II

B.II.a.6

Deletion of the solvent/diluent container from the pack

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

 

1, 2

IB

Documentation

1.

Justification for the deletion, including a statement regarding alternative means to obtain the solvent/diluent as required for the safe and effective use of the medicinal product.

2.

Revised product information.


B.II.b)   Manufacture

B.II.b.1

Replacement or addition of a manufacturing site for part or all of the manufacturing process of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Secondary packaging site

1, 2

1,3, 8

IAIN

b)

Primary packaging site

1, 2, 3, 4, 5

1, 2, 3, 4, 8, 9

IAIN

c)

Site where any manufacturing operation(s) take place, except batch release, batch control, and secondary packaging, for biological/immunological medicinal products, or for pharmaceutical forms manufactured by complex manufacturing processes

 

 

II

d)

Site which requires an initial or product specific inspection

 

 

II

e)

Site where any manufacturing operation(s) take place, except batch-release, batch control, primary and secondary packaging, for non-sterile medicinal products

 

1, 2, 3, 4, 5, 6, 7, 8, 9

IB

f)

Site where any manufacturing operation(s) take place, except batch release, batch control, and secondary packaging, for sterile medicinal products (including those that are aseptically manufactured) excluding biological/immunological medicinal products

 

1, 2, 3, 4, 5, 6, 7, 8

IB

Conditions

1.

Satisfactory inspection in the last 3 years by an inspection service of one of the Member States of the EU/EEA or of a country where an operational Good Manufacturing Practice (GMP) mutual recognition agreement (MRA) exists between the country concerned and the EU.

2.

Site appropriately authorised (to manufacture the pharmaceutical form or product concerned).

3.

Product concerned is not a sterile product.

4.

Where relevant, for instance for suspensions and emulsions, validation scheme is available or validation of the manufacture at the new site has been successfully carried out according to the current protocol with at least three production scale batches.

5.

Product concerned is not a biological/immunological medicinal product.

Documentation

1.

Proof that the proposed site is appropriately authorised for the pharmaceutical form or product concerned, i.e.:

 

For a manufacturing site within the EU/EEA: a copy of the current manufacturing authorisation. A reference to the EudraGMP database will suffice;

 

For a manufacturing site outside the EU/EEA where an operational GMP mutual recognition agreement (MRA) exists between the country concerned and the EU: a GMP certificate issued within the last 3 years by the relevant competent authority;

 

For a manufacturing site outside the EU/EEA where no such mutual recognition agreement exists: a GMP certificate issued within the last 3 years by an inspection service of one of the Member States of the EU/EEA. A reference to the EudraGMP database will suffice.

2.

Where relevant, the batch numbers, corresponding batch size and the manufacturing date of batches (≥ 3) used in the validation study should be indicated and the validation data presented, or validation protocol (scheme) to be submitted.

3.

The variation application form should clearly outline the ‘present’ and ‘proposed’ finished product manufacturers as listed in section 2.5 of the application form.

4.

Copy of approved release and end-of-shelf life specifications if relevant.

5.

Batch analysis data on one production batch and two pilot-scale batches simulating the production process (or two production batches) and comparative data on the last three batches from the previous site; batch data on the next two production batches should be available on request or reported if outside specifications (with proposed action).

6.

For semisolid and liquid formulations in which the active substance is present in non-dissolved form, appropriate validation data including microscopic imaging of particle size distribution and morphology or any other appropriate imaging technique.

7.

i)

If the new manufacturing site uses the active substance as a starting material — A declaration by the Qualified Person (QP) at the site responsible for batch release that the active substance is manufactured in accordance with the detailed guidelines on good manufacturing practice for starting materials as adopted by the Union.

ii)

In addition, if the new manufacturing site is located within the EU/EEA and uses the active substance as a starting material — A declaration by the Qualified Person (QP) of the new manufacturing site that the active substance used is manufactured in accordance with the detailed guidelines on good manufacturing practice for starting materials as adopted by the Union.

8.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

9.

If the manufacturing site and the primary packaging site are different, conditions of transport and bulk storage should be specified and validated.

Notes:

In case of a change in or a new manufacturing site in a country outside the EU/EEA without an operational GMP mutual recognition agreement with the EU, marketing authorisation holders are advised to consult the relevant competent authorities first before making the submission of the notification and to provide information about any previous EU/EEA inspection in the last 2-3 years and/or any planned EU/EEA inspection(s) including inspection dates, product category inspected, Supervisory Authority and other relevant information. This will facilitate the arrangement for a GMP inspection by an inspection service of one of the Member States if needed.

QP Declarations in relation to active substances

Manufacturing authorisation holders are obliged to only use as starting materials active substances that have been manufactured in accordance with GMP so a declaration is expected from each of the manufacturing authorisation holders that use the active substance as a starting material. In addition, as the QP responsible for batch certification takes overall responsibility for each batch, a further declaration from the QP responsible for batch certification is expected when the batch release site is a different site from the above.

In many cases only one manufacturing authorisation holder is involved and therefore only one declaration will be required. However, when more than one manufacturing authorisation holder is involved rather than provide multiple declarations it may be acceptable to provide a single declaration signed by one QP. This will be accepted provided that:

The declaration makes it clear that it is signed on behalf of all the involved QPs.

The arrangements are underpinned by a technical agreement as described in Chapter 7 of the GMP Guide and the QP providing the declaration is the one identified in the agreement as taking specific responsibility for the GMP compliance of the active substance manufacturer(s). Note: these arrangements are subject to inspection by the competent authorities.

Applicants are reminded that a Qualified Person is at the disposal of a manufacturing authorisation holder according to Article 41 of Directive 2001/83/EC and Article 45 of Directive 2001/82/EC and located in the EU/EEA. Therefore declarations from personnel employed by manufacturers in third countries, including those located within MRA partner countries are not acceptable.

According to Article 46a(1) of Directive 2001/83/EC and Article 50a(1) of Directive 2001/82/EC, manufacture includes complete or partial manufacture, import, dividing up, packaging or presentation prior to its incorporation into a medicinal product, including repackaging or relabeling as carried out by a distributor.

A declaration is not required for blood or blood components they are subject to the requirements of Directive 2002/98/EC of the European Parliament and of the Council (7).

B.II.b.2

Change to importer, batch release arrangements and quality control testing of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Replacement or addition of a site where batch control/testing takes place

2, 3, 4, 5

1, 2, 5

IA

b)

Replacement or addition of a site where batch control/testing takes place for a biological/immunological product and any of the test methods performed at the site is a biological/immunological method

 

 

II

c)   Replacement or addition of a manufacturer responsible for importation and/or batch release

1.

Not including batch control/testing

1, 2,5

1, 2, 3, 4, 5

IAIN

2.

Including batch control/testing

1, 2, 3, 4, 5

1, 2, 3, 4, 5

IAIN

3.

Including batch control/testing for a biological/immunological product and any of the test methods performed at that site is a biological/immunological/immunochemical method

 

 

II

Conditions

1.

The manufacturer responsible for batch release must be located within the EU/EEA. At least one batch release site remains within the EU/EEA that is able to certify the product testing for the purpose of batch release within the EU/EEA.

2.

The site is appropriately authorised.

3.

The product is not a biological/immunological medicinal product.

4.

Method transfer from the old to the new site or new test laboratory has been successfully completed.

5.

At least one batch control/testing site remains within the EU/EEA or in a country where an operational and suitably scoped GMP mutual recognition agreement (MRA) exists between the country concerned and the EU, that is able to carry out product testing for the purpose of batch release within the EU/EEA.

Documentation

1.

For a site within the EU/EEA: Attach copy of manufacturing authorisation(s) or where no manufacturing authorisation exists a certificate of GMP compliance issued within the last 3 years by the relevant competent authority.

For a manufacturing site outside the EEA where an operational GMP mutual recognition agreement (MRA) exists between the country concerned and the EU: a GMP certificate, issued within the last 3 years by the relevant competent authority. Where no such agreement exists a GMP certificate issued within the last 3 years by a EU/EEA competent authority.

2.

The variation application form should clearly outline the ‘present’ and ‘proposed’ finished product manufacturers, importer, batch control/testing and batch release sites as listed in section 2.5 of the application form for marketing authorisation.

3.

For centralised procedure only: contact details of new contact person in the EU/EEA for product defects and recalls, if applicable.

4.

A declaration by the Qualified Person (QP) responsible for batch certification stating that the active substance manufacturer(s) referred to in the marketing authorisation operate in compliance with the detailed guidelines on good manufacturing practice for starting materials. A single declaration may be acceptable under certain circumstances — see the note under variation No B.II.b.1.

5

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including revised product information as appropriate.

B.II.b.3

Change in the manufacturing process of the finished product, including an intermediate used in the manufacture of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor change in the manufacturing process

1, 2, 3, 4, 5, 6, 7

1, 2, 3, 4, 5, 6, 7, 8

IA

b)

Substantial changes to a manufacturing process that may have a significant impact on the quality, safety and efficacy of the medicinal product

 

 

II

c)

The product is a biological/immunological medicinal product and the change requires an assessment of comparability

 

 

II

d)

Introduction of a non-standard terminal sterilisation method

 

 

II

e)

Introduction or increase in the overage that is used for the active substance

 

 

II

f)

Minor change in the manufacturing process of an aqueous oral suspension

 

1, 2, 4, 6, 7,8

IB

Conditions

1.

No change in qualitative and quantitative impurity profile or in physico-chemical properties.

2.

Either the change relates to an immediate release solid oral dosage form/oral solution and the medicinal product concerned is not a biological/immunological or herbal medicinal product;

or the change relates to process parameter(s) that, in the context of a previous assessment, have been considered to have no impact on the quality of the finished product (regardless of the type of product and/or dosage form).

3.

The manufacturing principle including the single manufacturing steps remain the same, e.g. processing intermediates and there are no changes to any manufacturing solvent used in the process.

4

The currently registered process has to be controlled by relevant in-process controls and no changes (widening or deletion of limits) are required to these controls.

5.

The specifications of the finished product or intermediates are unchanged.

6.

The new process must lead to an identical product regarding all aspects of quality, safety and efficacy.

7.

Relevant stability studies in accordance with the relevant guidelines have been started with at least one pilot scale or industrial scale batch and at least 3 months stability data are at the disposal of the applicant. Assurance is given that these studies will be finalised and that the data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a direct comparison of the present process and the new process.

2.

For semi-solid and liquid products in which the active substance is present in non-dissolved form: appropriate validation of the change including microscopic imaging of particles to check for visible changes in morphology; comparative size distribution data by an appropriate method.

3.

For solid dosage forms: dissolution profile data of one representative production batch and comparative data of the last three batches from the previous process; data on the next two full production batches should be available on request or reported if outside specification (with proposed action). For herbal medicinal products, comparative disintegration data may be acceptable.

4.

Justification for not submitting a new bioequivalence study according to the relevant (Human or Veterinary) guidance on Bioavailability.

5.

For changes to process parameter(s) that have been considered to have no impact on the quality of the finished product, declaration to this effect reached in the context of the previously approved risk assessment.

6.

Copy of approved release and end-of-shelf life specifications.

7.

Batch analysis data (in a comparative tabulated format) on a minimum of one batch manufactured to both the currently approved and the proposed process. Batch data on the next two full production batches should be made available upon request and reported by the marketing authorisation holder if outside specification (with proposed action).

8.

Declaration that relevant stability studies have been started under ICH/VICH conditions, as appropriate, (with indication of the batch numbers concerned) and relevant stability parameters have been assessed in at least one pilot scale or industrial scale batch and at least 3 months satisfactory stability data are at the disposal of the applicant at time of notification and that the stability profile is similar to the currently registered situation. Assurance is given that these studies will be finalised and that the data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

B.II.b.4

Change in the batch size (including batch size ranges) of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Up to 10-fold compared to the originally approved batch size

1, 2, 3, 4, 5, 7

1, 4

IA

b)

Downscaling down to 10-fold

1, 2, 3, 4, 5, 6

1, 4

IA

c)

The change requires assessment of the comparability of a biological/immunological medicinal product or the change in batch size requires a new bioequivalence study

 

 

II

d)

The change relates to all other pharmaceutical forms manufactured by complex manufacturing processes

 

 

II

e)

More than 10-fold increase compared to the originally approved batch size for immediate release (oral) pharmaceutical forms

 

1, 2, 3, 4, 5, 6

IB

f)

The scale for a biological/immunological medicinal product is increased/decreased without process change (e.g. duplication of line)

 

1, 2, 3, 4, 5, 6

IB

Conditions

1.

The change does not affect reproducibility and/or consistency of the product.

2.

The change relates to conventional immediate release oral pharmaceutical forms or to non-sterile liquid based pharmaceutical forms.

3.

Any changes to the manufacturing method and/or to the in-process controls are only those necessitated by the change in batch-size, e.g. use of different sized equipment.

4.

Validation scheme is available or validation of the manufacture has been successfully carried out according to the current protocol with at least three batches at the proposed new batch size in accordance with the relevant guidelines.

5.

The product concerned is not a biological/immunological medicinal product.

6.

The change should not be the result of unexpected events arising during manufacture or because of stability concerns.

7.

The batch size is within the 10-fold range of the batch size foreseen when the marketing authorisation was granted or following a subsequent change not agreed as a Type IA variation.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Batch analysis data (in a comparative tabulated format) on a minimum of one production batch manufactured to both the currently approved and the proposed sizes. Batch data on the next two full production batches should be made available upon request and reported by the MAH if outside specifications (with proposed action).

3.

Copy of approved release and end-of-shelf life specifications.

4.

Where relevant the batch numbers, corresponding batch size and the manufacturing date of batches (≥ 3) used in the validation study should be indicated or validation protocol (scheme) be submitted.

5.

The validation results should be provided

6.

The results of stability studies that have been carried out under ICH/VICH conditions, on the relevant stability parameters, on at least one pilot or industrial scale batch, covering a minimum period of 3 months, and an assurance is given that these studies will be finalised, and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action). For biologicals/immunologicals: a declaration that an assessment of comparability is not required.

B.II.b.5

Change to in-process tests or limits applied during the manufacture of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Tightening of in-process limits

1, 2, 3, 4

1, 2

IA

b)

Addition of a new test(s) and limits

1, 2, 5, 6

1, 2, 3, 4, 5, 7

IA

c)

Deletion of a non-significant in-process test

1, 2, 7

1, 2, 6

IA

d)

Deletion of an in-process test which may have a significant effect on the overall quality of the finished product

 

 

II

e)

Widening of the approved IPC limits, which may have a significant effect on overall quality of the finished product

 

 

II

f)

Addition or replacement of an in-process test as a result of a safety or quality issue

 

1, 2, 3, 4, 5, 7

IB

Conditions

1.

The change is not a consequence of any commitment from previous assessments to review specification limits (e.g. made during the procedure for the marketing authorisation application or a type II variation procedure).

2.

The change does not result from unexpected events arising during manufacture, e.g. new unqualified impurity; change in total impurity limits.

3.

Any change should be within the range of currently approved limits.

4.

The test procedure remains the same, or changes in the test procedure are minor.

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

6.

The new test method is not a biological/immunological/immunochemical method or a method using a biological reagent for a biological active substance (does not include standard pharmacopoeial microbiological methods).

7.

The in-process test does not concern the control of a critical parameter, e.g.:

 

assay,

 

impurities (unless a particular solvent is definitely not used in the manufacture)

 

any critical physical characteristics (particle size, bulk, tapped density, etc.)

 

identity test (unless there is a suitable alternative control already present)

 

microbiological control (unless not required for the particular dosage form)

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Comparative table of current and proposed in-process tests and limits.

3.

Details of any new analytical method and validation data, where relevant.

4.

Batch analysis data on two production batches (3 production batches for biologicals, unless otherwise justified) of the finished product for all specification parameters.

5.

Where appropriate, comparative dissolution profile data for the finished product on at least one pilot batch manufactured using the current and new in-process tests. For herbal medicinal products, comparative disintegration data may be acceptable.

6

Justification/risk assessment showing that the in-process test is non-significant or that it is obsolete.

7.

Justification of the new in-process test and limits.


B.II.c)   Control of excipients

B.II.c.1

Change in the specification parameters and/or limits of an excipient

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Tightening of specification limits

1, 2, 3, 4

1, 2

IA

b)

Addition of a new specification parameter to the specification with its corresponding test method

1, 2, 5, 6, 7

1, 2, 3, 4, 6, 8

IA

c)

Deletion of a non-significant specification parameter (e.g. deletion of an obsolete parameter)

1, 2, 8

1, 2, 7

IA

d)

Change outside the approved specifications limits range

 

 

II

e)

Deletion of a specification parameter which may have a significant effect on the overall quality of the finished product

 

 

II

f)

Addition or replacement (excluding biological or immunological product) of a specification parameter with its corresponding test method, as a result of a safety or quality issue

 

1, 2, 3, 4, 5, 6, 8

IB

g)

Where there is no monograph in the European Pharmacopoeia or the national pharmacopoeia of a Member State for the excipient, a change in specification from in-house to a non-official Pharmacopoeia or a Pharmacopoeia of a third country

 

1, 2, 3, 4, 5, 6, 8

IB

Conditions

1.

The change is not a consequence of any commitment from previous assessments to review specification limits (e.g. made during the procedure for the marketing authorisation application or a type II variation procedure).

2.

The change does not result from unexpected events arising during manufacture, e.g. new unqualified impurity; change in total impurity limits.

3.

Any change should be within the range of currently approved limits.

4.

The test procedure remains the same, or changes in the test procedure are minor.

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

6.

The test method is not a biological/immunological/immunochemical method, or a method using a biological reagent (does not include standard pharmacopoeial microbiological methods)

7.

The change does not concern a genotoxic impurity.

8.

The specification parameter does not concern the control of a critical parameter, e.g.:

 

impurities (unless a particular solvent is definitely not used in the manufacture of the excipient)

 

any critical physical characteristics (particle size, bulk, tapped density, etc.)

 

identity test (unless there is a suitable alternative control already present)

 

microbiological control (unless not required for the particular dosage form)

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Comparative table of current and proposed specifications.

3.

Details of any new analytical method and validation data, where relevant.

4.

Batch analysis data on two production batches (3 production batches for biological excipients) of the excipient for all specification parameters.

5.

Where appropriate, comparative dissolution profile data for the finished product on at least one pilot batch containing the excipient complying with the current and proposed specification. For herbal medicinal products comparative disintegration data may be acceptable.

6.

Justification for not submitting a new bioequivalence study according to the relevant (Human, Veterinary) Guideline on Bioavailability, if appropriate.

7.

Justification/risk assessment showing that the parameter is non-significant or that it is obsolete.

8.

Justification of the new specification parameter and the limits.

B.II.c.2

Change in test procedure for an excipient

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor changes to an approved test procedure

1, 2, 3, 4

1, 2

IA

b)

Deletion of a test procedure if an alternative test procedure is already authorised

5

1

IA

c)

Substantial change to or replacement of a biological/immunological/immunochemical test method or a method using a biological reagent

 

 

II

d)

Other changes to a test procedure (including replacement or addition)

 

1, 2

IB

Conditions

1.

Appropriate validation studies have been performed in accordance with the relevant guidelines and show that the updated test procedure is at least equivalent to the former test procedure.

2.

There have been no changes of the total impurity limits; no new unqualified impurities are detected.

3.

The method of analysis should remain the same (e.g. a change in column length or temperature, but not a different type of column or method).

4.

The test method is not a biological/immunological/immunochemical method or a method using a biological reagent (does not include standard pharmacopoeial microbiological methods).

5.

An alternative test procedure is already authorised for the specification parameter and this procedure has not been added through IA/IA(IN) notification.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a description of the analytical methodology, a summary of validation data, revised specifications for impurities (if applicable).

2.

Comparative validation results or if justified comparative analysis results showing that the current test and the proposed one are equivalent. This requirement is not applicable in case of an addition of a new test procedure.

B.II.c.3

Change in source of an excipient or reagent with TSE risk

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)   From TSE risk material to vegetable or synthetic origin

1.

For excipients or reagents not used in the manufacture of a biological/immunological active substance or in a biological/immunological medicinal product

1

1

IA

2.

For excipients or reagents used in the manufacture of a biological/immunological active substance or in a biological/immunological medicinal product

 

1, 2

IB

b)

Change or introduction of a TSE risk material or replacement of a TSE risk material from a different TSE risk material, not covered by a TSE certificate of suitability

 

 

II

Conditions

1.

Excipient and finished product release and end of shelf life specifications remain the same.

Documentation

1.

Declaration from the manufacturer or the marketing authorisation holder of the material that it is purely of vegetable or synthetic origin.

2.

Study of equivalence of the materials and the impact on production of the final material and impact on behaviour (e.g. dissolution characteristics) of the finished product.

B.II.c.4

Change in synthesis or recovery of a non-pharmacopoeial excipient (when described in the dossier) or a novel excipient

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor change in synthesis or recovery of a non-pharmacopoeial excipient or a novel excipient

1, 2

1, 2, 3, 4

IA

b)

The specifications are affected or there is a change in physico-chemical properties of the excipient which may affect the quality of the finished product.

 

 

II

c)

The excipient is a biological/immunological substance

 

 

II

Conditions

1.

The synthetic route and specifications are identical and there is no change in qualitative and quantitative impurity profile (excluding residual solvents, provided they are controlled in accordance with ICH/VICH limits), or in physico-chemical properties.

2.

Adjuvants are excluded.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Batch analysis data (in a comparative tabulated format) of at least two batches (minimum pilot scale) of the excipient manufactured according to the old and the new process.

3.

Where appropriate, comparative dissolution profile data for the finished product of at least two batches (minimum pilot scale). For herbal medicinal products, comparative disintegration data may be acceptable.

4.

Copy of approved and new (if applicable) specifications of the excipient.


B.II.d)   Control of finished product

B.II.d.1

Change in the specification parameters and/or limits of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Tightening of specification limits

1, 2, 3, 4

1, 2

IA

b)

Tightening of specification limits for medicinal products subject to Official Control Authority Batch Release

1, 2, 3, 4

1, 2

IAIN

c)

Addition of a new specification parameter to the specification with its corresponding test method

1, 2, 5, 6, 7

1, 2, 3, 4, 5, 7

IA

d)

Deletion of a non-significant specification parameter (e.g. deletion of an obsolete parameter such as odour and taste or identification test for a colouring or flavouring material)

1, 2, 9

1, 2, 6

IA

e)

Change outside the approved specifications limits range

 

 

II

f)

Deletion of a specification parameter which may have a significant effect on the overall quality of the finished product

 

 

II

g)

Addition or replacement (excluding biological or immunological product) of a specification parameter with its corresponding test method as a result of a safety or quality issue

 

1, 2, 3, 4, 5, 7

IB

h)

Update of the dossier to comply with the provisions of an updated general monograph of the Ph. Eur for the finished product  (8)

1, 2, 3, 4, 7, 8

1, 2

IAIN

i)

Ph. Eur. 2.9.40 Uniformity of dosage units is introduced to replace the currently registered method, either Ph. Eur. 2.9.5 (Uniformity of mass) or Ph. Eur. 2.9.6 (Uniformity of content)

1, 2,10

1, 2, 4

IA

Conditions

1.

The change is not a consequence of any commitment from previous assessments to review specification limits (e.g. made during the procedure for the marketing authorisation application or a type II variation procedure), unless the supporting documentation has been already assessed and approved within another procedure.

2.

The change does not result from unexpected events arising during manufacture, e.g. new unqualified impurity; change in total impurity limits.

3.

Any change should be within the range of currently approved limits.

4.

The test procedure remains the same, or changes in the test procedure are minor.

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

6.

The test method is not a biological/immunological/immunochemical method or a method using a biological reagent for a biological active substance.

7.

The change does not concern any impurities (including genotoxic) or dissolution.

8.

The change concerns the updating of the microbial control limits to be in line with the current Pharmacopoeia, and the currently registered microbial control limits (present situation) are in line with the pre January 2008 (non-harmonised) situation and does not include any additional specified controls over the Pharmacopoeia requirements for the particular dosage form and the proposed controls are in line with the harmonised monograph.

9.

The specification parameter or proposal for the specific dosage form does not concern a critical parameter for example:

 

assay,

 

impurities (unless a particular solvent is definitely not used in the manufacture of the finished product)

 

any critical physical characteristics (hardness or friability for uncoated tablets, dimensions, etc.)

 

a test that is required for the particular dosage form in accordance with the general notices of the Ph. Eur.;

 

any request for skip testing.

10.

The proposed control is fully in line with the Table 2.9.40.-1 of Ph. Eur. 2.9.40 monograph, and does not include the alternative proposal for testing uniformity of dosage units by Mass Variation instead of Content Uniformity when the latter is specified in Table 2.9.40.-1.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Comparative table of current and proposed specifications.

3.

Details of any new analytical method and validation data, where relevant.

4.

Batch analysis data on two production batches (3 production batches for biologicals, unless otherwise justified) of the finished product for all specification parameters

5.

Where appropriate, comparative dissolution profile data for the finished product on at least one pilot batch complying with the current and proposed specification. For herbal medicinal products, comparative disintegration data may be acceptable.

6

Justification/risk assessment showing that the parameter is non-significant or that it is obsolete.

7.

Justification of the new specification parameter and the limits

B.II.d.2

Change in test procedure for the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor changes to an approved test procedure

1, 2, 3, 4,

1,2

IA

b)

Deletion of a test procedure if an alternative method is already authorised

4

1

IA

c)

Substantial change to, or replacement of, a biological/immunological/immunochemical test method or a method using a biological reagent or replacement of a biological reference preparation not covered by an approved protocol

 

 

II

d)

Other changes to a test procedure (including replacement or addition)

 

1, 2

IB

e)

Update of the test procedure to comply with the updated general monograph in the Ph. Eur.

2, 3, 4, 5

1

IA

f)

To reflect compliance with the Ph.Eur. and remove reference to the outdated internal test method and test method number  (9)

2, 3, 4, 5

1

IA

Conditions

1.

Appropriate validation studies have been performed in accordance with the relevant guidelines and show that the updated test procedure is at least equivalent to the former test procedure.

2.

There have been no changes of the total impurity limits; no new unqualified impurities are detected

3.

The method of analysis should remain the same (e.g. a change in column length or temperature, but not a different type of column or method);

4.

The test method is not a biological/immunological/immunochemical method or a method using a biological reagent (does not include standard pharmacopoeial microbiological methods).

5.

The registered test procedure already refers to the general monograph of the Ph. Eur. and any changes are minor in nature and require update of the technical dossier.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a description of the analytical methodology, a summary of validation data, revised specifications for impurities (if applicable).

2.

Comparative validation results or if justified comparative analysis results showing that the current test and the proposed one are equivalent.; This requirement is not applicable in case of an addition of a new test procedure.

B.II.d.3

Variations related to the introduction of real-time release or parametric release in the manufacture of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

 

 

II


B.II.e)   Container closure system

B.II.e.1

Change in immediate packaging of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)   Qualitative and quantitative composition

1.

Solid pharmaceutical forms

1, 2, 3

1, 2, 3, 4, 6

IA

2.

Semi-solid and non-sterile liquid pharmaceutical forms

 

1, 2, 3, 5, 6

IB

3.

Sterile medicinal products and biological/immunological medicinal products.

 

 

II

4.

The change relates to a less protective pack where there are associated changes in storage conditions and/or reduction in shelf life.

 

 

II

b)   Change in type of container or addition of a new container

1.

Solid, semi-solid and non-sterile liquid pharmaceutical forms

 

1, 2, 3, 5, 6, 7

IB

2.

Sterile medicinal products and biological/immunological medicinal products

 

 

II

3.

Deletion of an immediate packaging container that does not lead to the complete deletion of a strength or pharmaceutical form

4

1, 8

IA

Conditions

1.

The change only concerns the same packaging/container type (e.g. blister to blister).

2.

The proposed packaging material must be at least equivalent to the approved material in respect of its relevant properties.

3.

Relevant stability studies have been started under ICH/VICH conditions and relevant stability parameters have been assessed in at least two pilot scale or industrial scale batches and at least 3 months satisfactory stability data are at the disposal of the applicant at time of implementation. However, if the proposed packaging is more resistant than the existing packaging, e.g. thicker blister packaging, the 3 months’ stability data do not yet have to be available. These studies must be finalised and the data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

4.

The remaining product presentation(s) must be adequate for the dosing instructions and treatment duration as mentioned in the summary of product characteristics.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including revised product information as appropriate.

2.

Appropriate data on the new packaging (comparative data on permeability, e.g. for O2, CO2 moisture).

3.

Where appropriate, proof must be provided that no interaction between the content and the packaging material occurs (e.g. no migration of components of the proposed material into the content and no loss of components of the product into the pack), including confirmation that the material complies with relevant pharmacopoeial requirements or legislation of the Union on plastic material and objects in contact with foodstuffs.

4.

A declaration that the required stability studies have been started under ICH/VICH conditions (with indication of the batch numbers concerned) and that, as relevant, the required minimum satisfactory stability data were at the disposal of the applicant at time of implementation and that the available data did not indicate a problem. Assurance should also be given that the studies will be finalised and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

5.

The results of stability studies that have been carried out under ICH/VICH conditions, on the relevant stability parameters, on at least two pilot or industrial scale batches, covering a minimum period of 3 months, and an assurance is given that these studies will be finalised, and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

6.

Comparative table of the current and proposed immediate packaging specifications, if applicable.

7.

Samples of the new container/closure where applicable (see NTA, Requirements for samples in the Member States/EMA).

8.

Declaration that the remaining pack-size(s) is/are consistent with the dosage regimen and duration of treatment and adequate for the dosing instructions as approved in the summary of product characteristics.

Note:

for B.II.e.1.b), applicants are reminded that any change which results in a ‘new pharmaceutical form’ requires the submission of an Extension application.

B.II.e.2

Change in the specification parameters and/or limits of the immediate packaging of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Tightening of specification limits

1, 2, 3, 4

1, 2

IA

b)

Addition of a new specification parameter to the specification with its corresponding test method

1, 2, 5

1, 2, 3, 4, 6

IA

c)

Deletion of a non-significant specification parameter (e.g. deletion of an obsolete parameter)

1, 2

1, 2, 5

IA

d)

Addition or replacement of a specification parameter as a result of a safety or quality issue

 

1, 2, 3, 4, 6

IB

Conditions

1.

The change is not a consequence of any commitment from previous assessments to review specification limits (e.g. made during the procedure for the marketing authorisation application or a type II variation procedure).

2.

The change does not result from unexpected events arising during manufacture

3.

Any change should be within the range of currently approved limits.

4.

The test procedure remains the same, or changes in the test procedure are minor.

5.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

Comparative table of current and proposed specifications.

3.

Details of any new analytical method and validation data, where relevant.

4.

Batch analysis data on two batches of the immediate packaging for all specification parameters.

5.

Justification/risk assessment showing that the parameter is non-significant or that it is obsolete.

6.

Justification of the new specification parameter and the limits.

B.II.e.3

Change in test procedure for the immediate packaging of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Minor changes to an approved test procedure

1, 2, 3

1, 2

IA

b)

Other changes to a test procedure (including replacement or addition)

1, 3, 4

1, 2

IA

c)

Deletion of a test procedure if an alternative test procedure is already authorised

5

1

IA

Conditions

1.

Appropriate validation studies have been performed in accordance with the relevant guidelines and validation studies show that the updated test procedure is at least equivalent to the former test procedure.

2.

The method of analysis should remain the same (e.g. a change in column length or temperature, but not a different type of column or method).

3.

Any new test method does not concern a novel non-standard technique or a standard technique used in a novel way.

4.

The active substance/finished product is not biological/immunological.

5.

An alternative test procedure is already authorised for the specification parameter and this procedure has not been added through IA/IA(IN) notification.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including a description of the analytical methodology, a summary of validation data.

2.

Comparative validation results or if justified comparative analysis results showing that the current test and the proposed one are equivalent. This requirement is not applicable in case of an addition of a new test procedure.

B.II.e.4

Change in shape or dimensions of the container or closure (immediate packaging)

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Non-sterile medicinal products

1, 2, 3

1, 2, 4

IA

b)

The change in shape or dimensions concerns a fundamental part of the packaging material, which may have a significant impact on the delivery, use, safety or stability of the finished product

 

 

II

c)

Sterile medicinal products

 

1, 2, 3, 4

IB

Conditions

1.

No change in the qualitative or quantitative composition of the container.

2.

The change does not concern a fundamental part of the packaging material, which affects the delivery, use, safety or stability of the finished product.

3.

In case of a change in the headspace or a change in the surface/volume ratio, stability studies in accordance with the relevant guidelines have been started and relevant stability parameters have been assessed in at least two pilot scale (three for biological/immunological medicinal products) or industrial scale batches and at least 3 months (6 months for biological/immunological medicinal products) stability data are at the disposal of the applicant. Assurance is given that these studies will be finalised and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including description, detailed drawing and composition of the container or closure material, and including revised product information as appropriate.

2.

Samples of the new container/closure where applicable (see NTA, Requirements for samples in the Member States).

3.

Revalidation studies have been performed in case of sterile products terminally sterilised. The batch numbers of the batches used in the revalidation studies should be indicated, where applicable.

4.

In case of a change in the headspace or a change in the surface/volume ratio, a declaration that the required stability studies have been started under ICH/VICH conditions (with indication of the batch numbers concerned) and that, as relevant, the required minimum satisfactory stability data were at the disposal of the applicant at time of implementation for a Type IA notification and time of submission of a Type IB notification, and that the available data did not indicate a problem. Assurance should also be given that the studies will be finalised and that data will be provided immediately to the competent authorities if outside specifications or potentially outside specifications at the end of the approved shelf life (with proposed action).

B.II.e.5

Change in pack size of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)   Change in the number of units (e.g. tablets, ampoules, etc.) in a pack

1.

Change within the range of the currently approved pack sizes

1, 2

1, 3

IAIN

2.

Change outside the range of the currently approved pack sizes

 

1, 2, 3

IB

b)

Deletion of pack size(s)

3

1, 2

IA

c)

Change in the fill weight/fill volume of sterile multidose (or single-dose, partial use) parenteral medicinal products, including biological/immunological medicinal products

 

 

II

d)

Change in the fill weight/fill volume of non-parenteral multi-dose (or single-dose, partial use) products

 

1, 2, 3

IB

Conditions

1.

New pack size should be consistent with the posology and treatment duration as approved in the Summary of Product Characteristics.

2.

The primary packaging material remains the same.

3.

The remaining product presentation(s) must be adequate for the dosing instructions and treatment duration as mentioned in the Summary of Product Characteristics.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate) including revised product information as appropriate.

2.

Justification for the new/remaining pack-size, showing that the new/remaining size is/are consistent with the dosage regimen and duration of treatment as approved in the summary of product characteristics

3.

Declaration that stability studies will be conducted in accordance with the relevant guidelines for products where stability parameters could be affected. Data to be reported only if outside specifications (with proposed action).

Note:

for B.II.e.5.c) and d), applicants are reminded that any changes to the ‘strength’ of the medicinal product require the submission of an Extension application.

B.II.e.6

Change in any part of the (primary) packaging material not in contact with the finished product formulation (such as colour of flip-off caps, colour code rings on ampoules, change of needle shield (different plastic used))

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Change that affects the product information

1

1

IAIN

b)

Change that does not affect the product information

1

1

IA

Conditions

1.

The change does not concern a part of the packaging material, which affects the delivery, use, safety or stability of the finished product.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate), including revised product information as appropriate.

B.II.e.7

Change in supplier of packaging components or devices (when mentioned in the dossier)

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Deletion of a supplier

1

1

IA

b)

Replacement or addition of a supplier

1, 2, 3, 4

1, 2, 3

IA

c)

Any change to suppliers of spacer devices for metered dose inhalers

 

 

II

Conditions

1.

No deletion of packaging component or device.

2.

The qualitative and quantitative composition of the packaging components/device and design specifications remain the same.

3.

The specifications and quality control method are at least equivalent.

4.

The sterilisation method and conditions remain the same, if applicable.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

2.

For devices for medicinal products for human use, proof of CE marking.

3.

Comparative table of current and proposed specifications, if applicable.


B.II.f)   Stability

B.II.f.1

Change in the shelf-life or storage conditions of the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)   Reduction of the shelf life of the finished product

1.

As packaged for sale

1

1, 2, 3

IAIN

2.

After first opening

1

1, 2, 3

IAIN

3.

After dilution or reconstitution

1

1, 2, 3

IAIN

b)   Extension of the shelf life of the finished product

1.

As packaged for sale (supported by real time data)

 

1, 2, 3

IB

2.

After first opening (supported by real time data)

 

1, 2, 3

IB

3.

After dilution or reconstitution (supported by real time data)

 

1, 2, 3

IB

4.

Extension of the shelf-life based on extrapolation of stability data not in accordance with ICH/VICH guidelines  (10)

 

 

II

5.

Extension of the shelf-life of a biological/immunological medicinal product in accordance with an approved stability protocol.

 

1, 2, 3

IB

c)

Change in storage conditions for biological medicinal products, when the stability studies have not been performed in accordance with an approved stability protocol

 

 

II

d)

Change in storage conditions of the finished product or the diluted/reconstituted product

 

1, 2, 3

IB

e)

Change to an approved stability protocol

1, 2

1, 4

IA

Conditions

1.

The change should not be the result of unexpected events arising during manufacture or because of stability concerns.

2.

The change does not concern a widening of the acceptance criteria in the parameters tested, a removal of stability indicating parameters or a reduction in the frequency of testing.

Documentation

1.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate). This must contain results of appropriate real time stability studies (covering the entire shelf life) conducted in accordance with the relevant stability guidelines on at least two pilot scale batches (11) of the finished product in the authorised packaging material and/or after first opening or reconstitution, as appropriate; where applicable, results of appropriate microbiological testing should be included.

2.

Revised product information

3.

Copy of approved end of shelf life finished product specification and where applicable, specifications after dilution/reconstitution or first opening.

4.

Justification for the proposed change(s).


B.II.g)   Design Space and post approval change management protocol

B.II.g.1

Introduction of a new design space or extension of an approved design space for the finished product, concerning:

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

One or more unit operations in the manufacturing process of the finished product including the resulting in-process controls and/or test procedures

 

1, 2, 3

II

b)

Test procedures for excipients/intermediates and/or the finished product.

 

1, 2, 3

II

Documentation

1.

Results from product and process development studies (including risk assessment and multivariate studies, as appropriate) demonstrating that a systematic mechanistic understanding of material attributes and process parameters to the critical quality attributes of the finished product has been achieved.

2.

Description of the design space in tabular format, including the variables (material attributes and process parameters, as appropriate) and their proposed ranges.

3.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

B.II.g.2

Introduction of a post approval change management protocol related to the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

 

1, 2, 3

II

Documentation

1.

Detailed description for the proposed change.

2.

Change management protocol related to the finished product.

3.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

B.II.g.3

Deletion of an approved change management protocol related to the finished product

Conditions to be fulfilled

Documentation to be supplied

Procedure type

 

1

1, 2

IAIN

Conditions

1.

The deletion of the approved change management protocol related to the finish product is not a result of unexpected events or out of specification results during the implementation of the change(s) described in the protocol and does not have any effect on the already approved information in the dossier.

Documentation

1.

Justification for the proposed deletion.

2.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

B.II.g.4

Changes to an approved change management protocol

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Major changes to an approved change management protocol

 

 

II

b)

Minor changes to an approved change management protocol that do not change the strategy defined in the protocol

 

1

IB

Documentation

1.

Declaration that any change should be within the range of currently approved limits. In addition, declaration that an assessment of comparability is not required for biological/immunological medicinal products.

B.II.g.5

Implementation of changes foreseen in an approved change management protocol

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

The implementation of the change requires no further supportive data

1

1, 2, 4

IAIN

b)

The implementation of the change requires further supportive data

 

1, 2, 3, 4

IB

c)

Implementation of a change for a biological/immunological medicinal product

 

1, 2, 3, 4, 5

IB

Conditions

1.

The proposed change has been performed fully in line with the approved change management protocol, which requires its immediate notification following implementation.

Documentation

1.

Reference to the approved change management protocol.

2.

Declaration that the change is in accordance with the approved change management and that the study results meet the acceptance criteria specified in the protocol. In addition, declaration that an assessment of comparability is not required for biological/immunological medicinal products.

3.

Results of the studies performed in accordance with the approved change management protocol.

4.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format or NTA volume 6B format for veterinary products, as appropriate).

5.

Copy of approved specifications of the finished product.


B.II.h   Adventitious Agents Safety

B.II.h.1

Update to the ‘Adventitious Agents Safety Evaluation’ information (section 3.2.A.2)

Conditions to be fulfilled

Documentation to be supplied

Procedure type

a)

Studies related to manufacturing steps investigated for the first time for one or more adventitious agents

 

 

II

b)   Replacement of obsolete studies related to manufacturing steps and adventitious agents already reported in the dossier

1)

with modification of risk assessment

 

 

II

2)

without modification of risk assessment

 

1, 2, 3

IB

Documentation

1.

Amendment of the relevant section(s) of the dossiers including the introduction of the new studies to investigate the capability of manufacturing steps to inactivate/reduce adventitious agents.

2.

Justification that the studies do not modify the risk assessment.

3.

Amendment of product information (where applicable).

B.III   CEP/TSE/MONOGRAPHS

B.III.1

Submission of a new or updated Ph. Eur. certificate of suitability or deletion of Ph. Eur. certificate of suitability:

Conditions to be fulfilled

Documentation to be supplied

Procedure type

For an active substance

For a starting material/reagent/intermediate used in the manufacturing process of the active substance

For an excipient

 

 

 

a)   European Pharmacopoeial Certificate of Suitability to the relevant Ph. Eur. Monograph.

1.

New certificate from an already approved manufacturer

1, 2, 3, 4, 5, 8, 11

1, 2, 3, 4, 5

IAIN

2.

Updated certificate from an already approved manufacturer

1, 2, 3, 4, 8

1, 2, 3, 4, 5

IA

3.

New certificate from a new manufacturer (replacement or addition)

1, 2, 3, 4, 5, 8, 11

1, 2, 3, 4, 5

IAIN

4.

Deletion of certificates (in case multiple certificates exist per material)

10

3

IA

5.

New certificate for a non-sterile active substance that is to be used in a sterile medicinal product, where water is used in the last steps of the synthesis and the material is not claimed to be endotoxin free

 

1, 2, 3, 4, 5, 6

IB

b)   European Pharmacopoeial TSE Certificate of suitability for an active substance/starting material/reagent/intermediate/or excipient

1.

New certificate for an active substance from a new or an already approved manufacturer

3, 5, 6, 11

1, 2, 3, 4, 5

IAIN

2.

New certificate for a starting material/reagent/intermediate/or excipient from a new or an already approved manufacturer

3, 6, 9

1, 2, 3, 4, 5

IA

3.

Updated certificate from an already approved manufacturer

7, 9

1, 2, 3, 4, 5

IA

4.

Deletion of certificates (in case multiple certificates exist per material)

10

3

IA

5.

New/updated certificate from an already-approved/new manufacturer using materials of human or animal origin for which an assessment of the risk with respect to potential contamination with adventitious agents is required

 

 

II

Conditions

1.

The finished product release and end of shelf life specifications remain the same.

2.

Unchanged (excluding tightening) additional (to Ph. Eur.) specifications for impurities (excluding residual solvents, provided they are in compliance with ICH/VICH) and product specific requirements (e.g. particle size profiles, polymorphic form), if applicable.

3.

The manufacturing process of the active substance, starting material/reagent/intermediate does not include the use of materials of human or animal origin for which an assessment of viral safety data is required.

4.

For active substance only, it will be tested immediately prior to use if no retest period is included in the Ph. Eur. Certificate of Suitability or if data to support a retest period is not already provided in the dossier.

5.

The active substance/starting material/reagent/intermediate/excipient is not sterile.

6.

The substance is not included in a veterinary medicinal product for use in animal species susceptible to TSE

7.

For veterinary medicinal products: there has been no change in the source of material.

8.

For herbal active substances: the manufacturing route, physical form, extraction solvent and drug extract ratio (DER) should remain the same.

9.

If Gelatine manufactured from bones is to be used in a medicinal product for parenteral use, it should only be manufactured in compliance with the relevant country requirements.

10.

At least one manufacturer for the same substance remains in the dossier.

11.

If the active substance is a not a sterile substance but is to be used in a sterile medicinal product then according to the CEP it must not use water during the last steps of the synthesis or if it does the active substance must also be claimed to be free from bacterial endotoxins.

Documentation

1.

Copy of the current (updated) Ph. Eur. Certificate of Suitability.

2.

In case of an addition of a manufacturing site, the variation application form should clearly outline the ‘present’ and ‘proposed’ manufacturers as listed in section 2.5 of the application form.

3.

Amendment of the relevant section(s) of the dossier (presented in the EU-CTD format).

4.

Where applicable, a document providing information of any materials falling within the scope of the Note for Guidance on Minimising the Risk of Transmitting Animal Spongiform Encephalopathy Agents via Human and Veterinary Medicinal Products including those which are used in the manufacture of the active substance/excipient. The following information should be included for each such material: Name of manufacturer, species and tissues from which the material is a derivative, country of origin of the source animals and its use.

For the Centralised Procedure, this information should be included in an updated TSE table A (and B, if relevant).