Skip to main content Skip to search Skip to main navigation

EC: Updated Q&A on Safety Features, Version 19

The European Commission published Version 19 of the Q&A on safety features for medicinal products in late December 2021.

What's new?

  • Question 1.29: Do the unique identifiers of reference and retention samples taken from stock in compliance with Annex 19 of the EU GMP Guidelines5 and uploaded to the EMVS have to be decommissioned? If yes, to what status?
    Answer: Yes, if a sample of a batch is taken as reference or retention sample after uploading in EMVS, it should be decommissioned as "sample". If a sample is taken voluntarily by a wholesaler that fall outside the scope of Annex 19, they should be decommissioned as "destroyed".

What has been updated?

  • Question 1.22: In the case of parallel-traded packs, can parallel traders cover or remove the safety features of the original pack?
  • Answer:
    Yes. Parallel traders who cover or remove the existing safety features are required to apply equivalent safety features in accordance with Article 47a of Directive 2001/83/EC. If the product code or/and batch number change, the original one must be decommissioned as a first step. The new individual identifier should comply with the requirements of the Member State where the medicinal product is to be placed on the market. In any case, traceability must be maintained in the final storage system.

 

  • Question 5.8: Can a wholesaler request another wholesaler to verify the authenticity and decommission the unique identifiers for medicinal products they intend to distribute outside the EU on their behalf?
    Answer: No, this obligation cannot be delegated, as the audit trail would not reflect the reality of the supply chain.

 

  • Question 7.19: Can a marketing authorisation holder delegate the uploading of the information laid down in Article 33(2) of Commission Delegated Regulation (EU) 2016/161?
    Answer: Yes, this is possible if there is a written agreement between both parties. However, the legal responsibility will remain with the MAH. He must ensure the accuracy, confidentiality, and integrity of the data uploaded into the system.

Source:

EC: Q&A Safety Features, Version 19

Meet the GMP Compliance Adviser

The GMP Compliance Adviser is the world's largest knowledge portal for quality management in the pharma business. 

The demo access is non-binding and ends automatically.

Test it now for free

You may also be interested in the following articles:

ICH: Updated Q9(R1) Briefing Pack

ICH: Updated Q9(R1) Briefing Pack

The ICH has fully revised the Q9(R1) Briefing Pack (March/April 2026) to align with the updated ICH Q9 guideline.
Read more
EMA: New Plans for the EU GMP Guide

EMA: New Plans for the EU GMP Guide

EMA published the GMDP Inspectors Working Group’s new 2026-2028 work plan and its 2025 annual report.
Read more
EMA: Pharmaceutical Quality System (PQS) Effectiveness Pilot Project

EMA: Pharmaceutical Quality System (PQS) Effectiveness Pilot Project

EMA launched a pilot under which EEA GMP inspectors will assess how sites demonstrate the effectiveness of their pharmaceutical quality system for risk-based change management, and whether the EEA GMP certificate could serve as the main evidence of this effectiveness.
Read more
EMA: Updated Guideline on Active Substance Chemistry

EMA: Updated Guideline on Active Substance Chemistry

The EMA has updated guidance on the information required for the manufacture and control of active substances used in medicinal products, with a 1 September 2026 date of application.
Read more
EMA: Q&A on the Implementation of 3DP Technology for Solid Oral Dosage Forms

EMA: Q&A on the Implementation of 3DP Technology for Solid Oral Dosage Forms

EMA added a new GMP/Q&A section on its website and published a dedicated Q&A document on 3D printing (3DP) for solid oral dosage forms.
Read more
Microbiological Monitoring – Sources of Contamination

Microbiological Monitoring – Sources of Contamination

All pharmaceutical dosage forms must be manufactured under controlled microbiological conditions. This requires microbial monitoring. This applies not only to sterile manufacturing, but also to facilities that manufacture non-sterile products.
Read more
Previous
Next