Skip to main content Skip to search Skip to main navigation

EMA: Concept Paper on the Revision of Annex 15

EMA and PIC/S have published a concept paper outlining a targeted revision of Annex 15 (Qualification and Validation).

Background of the revision
The revision is largely driven by the nitrosamine (sartan) case. The “lessons learnt” report identified shortcomings in process and product knowledge, validation practices, change control and contamination control among active substance manufacturers.

A key recommendation was to make Annex 15 mandatory for active substance manufacturers.

In addition, Annex 15 will be aligned with ICH Q9 (R1) on Quality Risk Management.

Key elements of the proposed revision

Qualification and Validation

  • Extension of scope to chemical and biological active substance manufacturers (mandatory application)
  • For API manufacturers strengthening of:
    • Validation Master File
    • Qualification & Validation policy
    • Investigation of results not meeting predefined acceptance criteria
    • Oversight of third-party validation activities
    • Supplier qualification
    • Process validation activities to process recovery of materials and solvents

GDP Principles
The integration of Good Distribution Practices (GDP) for active substances is foreseen. Expanded requirements for transport verification are planned.

ICH Q9 (R1)

Annex 15 is intended to be specifically aligned with the updated version of ICH Q9 (R1):

  • Stronger emphasis on Quality Risk Management (QRM) in design and validation of monitoring systems
  • Integration of risk reviews to support qualification and validation
  • Application of QRM also in the context of traditional processes

The public consultation will end on 9 April 2026. The revised Annex 15 is expected to be published by December 2026


Source:

EMA: Concept paper on the revision of the guidelines on Good Manufacturing Practice for medicinal products - Annex 15 - Qualification and Validation

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 can the Specific Requirements for Sterile Products be Taken into Account in the Quality Management System?

How can the Specific Requirements for Sterile Products be Taken into Account in the Quality Management System?

Here's the answer:
Read more
GMP Meets Radiation Protection – How Do They Fit Together?

GMP Meets Radiation Protection – How Do They Fit Together?

The manufacture of radiopharmaceuticals requires simultaneous compliance with the EU GMP Guide and radiation protection regulations, which can lead to conflicting objectives between product safety and personal protection. Technical solutions such as negative pressure systems and lead-lined cells, as well as early consultation with the authorities, are crucial for implementation that complies with both GMP and radiation protection requirements.
Read more
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
Previous
Next