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:

FDA: Draft Guidance on Responding to Form 483 Observations

FDA: Draft Guidance on Responding to Form 483 Observations

The US Food and Drug Administration (FDA) has issued a draft guidance on responding to Form FDA-483 observations following drug CGMP inspections. The document provides recommendations on how manufacturers should structure their responses and what information they should include.
Read more
Which Quality and Process Parameters must Typically be Taken into Account During Process Validation for Terminally Sterilized Products?

Which Quality and Process Parameters must Typically be Taken into Account During Process Validation for Terminally Sterilized Products?

Here's the answer:
Read more
Veterinary GMP 2026: The New Regulatory Framework

Veterinary GMP 2026: The New Regulatory Framework

Implementing Regulations (EU) 2025/2091 and 2025/2154 consolidate the GMP requirements for veterinary medicinal products into a distinct and legally binding framework for the first time. While establishing regulatory independence for the veterinary sector, they remain substantively aligned with the EU GMP Guide.
Read more
Team-NB: Opportunities and Concerns in the MDR/IVDR Revision

Team-NB: Opportunities and Concerns in the MDR/IVDR Revision

Team-NB, the European association of medical device Notified Bodies, sees the proposed MDR and IVDR revision as an opportunity to improve efficiency, transparency and predictability in conformity assessment.
Read more
EMA: GMP Documentation for the Sterilisation of an API

EMA: GMP Documentation for the Sterilisation of an API

The EMA Q&A on the quality of medicines has been updated with a new question: “What kind of GMP documentation is required for an API manufacturer performing sterilisation of an active substance?”

Read more
EMA: Updated Q&A on OOS Batches of ATMPs

EMA: Updated Q&A on OOS Batches of ATMPs

The EMA has revised its questions and answers on the use of out-of-specification (OOS) batches of authorised cell- and tissue-based ATMPs (“Questions and answers on the use of out-of-specification batches of authorised cell/tissue-based ATMPs”, Rev. 1, 2026).
Read more
Previous
Next