Skip to main content Skip to search Skip to main navigation

EMA Clarifies “Novel or Complex Manufacturing Process” Definition

In its Quality of Medicines Q&A – Part 1, the EMA has clarified how “novel or complex manufacturing processes” should be interpreted for variation categories Q.II.b.1 (new/replacement finished product manufacturing site) and Q.II.b.4 (change in batch size).

Such processes involve technologies that pose specific risks during site transfer or scale-up, potentially affecting product quality and thus requiring a Type II variation. Not all “non-standard processes” qualify as complex - aseptic processing, for example, is not considered complex for this classification, but as it is a non-standard manufacturing process, production scale process validation data is required.

Examples of complex processes include:

  • ATMPs, liposomal and nanoparticulate preparations,
  • Parenteral modified-release products,
  • Metered-dose inhalers and DPI,
  • Multilayer tablets.

Examples of novel processes include:

  • Continuous manufacturing, decentralised manufacturing,
  • Decentralised manufacturing
  • Additive manufacturing,
  • Use of process models,
  • Personalised medicine production.

Applicants submitting a Type IB variation must justify why the process is not novel or complex. If the justification is rejected, authorities may request withdrawal and resubmission as Type II. Pre-submission consultation and the use of Post Approval Change Management Protocols (PACMPs) can help ensure correct categorisation.


Source:

EMA: Quality of medicines questions and answers: Part 1

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:

How is First Air Verified and Monitored During Aseptic Process Qualification?

How is First Air Verified and Monitored During Aseptic Process Qualification?

Here's the answer:
Read more
Outsourced Activities in the GDP Environment Part I: Supplier Management

Outsourced Activities in the GDP Environment Part I: Supplier Management

Supplier management is the systematic management of a company´s relationship with its suppliers. It encompasses supplier qualification and customer audits as described in the following excerpt from GMP:KnowHow Pharmalogistics (GDP).

Read more
FDA: Draft Guidance on Assessing Container Closure Systems for Drugs and Biologics

FDA: Draft Guidance on Assessing Container Closure Systems for Drugs and Biologics

On 14 August 2026, the US Food and Drug Administration (FDA) announced the publication of a new draft guidance document entitled ‘Container Closure Systems for Human Drugs and Biological Products’.

Read more
FDA: New FDA Commissioner Dr. Heidi Overton

FDA: New FDA Commissioner Dr. Heidi Overton

President Donald Trump has named White House aide Heidi Overton to lead the US Food and Drug Administration (FDA). Overton will fill the position previously held by Marty Makary, who left the agency in May. This announcement was made on Trump's Truth Social account on 19 August. Her nomination is subject to confirmation by the Senate.

Read more
IPEC: Stability Guide for Excipients has been Updated

IPEC: Stability Guide for Excipients has been Updated

The IPEC Stability Guide for Pharmaceutical Excipients has been updated and is now available as version 3 (2026), as announced on the IPEC (International Pharmaceutical Excipients Council) website.

Read more
EU: “Forever Chemicals” in a Conflict of Interests

EU: “Forever Chemicals” in a Conflict of Interests

On 14 July 2026, the European Parliamentary Research Service (EPRS) published a comprehensive briefing on PFAS (per- and polyfluoroalkyl substances), also known as ‘forever chemicals’. The document is intended to serve as a technical basis for MEPs in their upcoming political decisions on PFAS regulation and summarises the current state of scientific knowledge, regulation and procedures.

Read more
Previous
Next