Skip to main content Skip to search Skip to main navigation

EMA: Further update of Q&A on regulatory GMP-requirements during COVID-19

The European Commission, the EMA and the European Network of Medicines Regulatory Authorities have published the third version of the Q&A on regulatory expectations for medicinal products for human use during the COVID-19 pandemic on July 1, 2020. The document has meanwhile grown from originally 7 to now 23 pages and intends to serve pharmaceutical companies as a guide on current adjustments to the regulatory framework due to COVID-19.

 

What's new?


Question 2.2, on the validity period of GMP certificates for manufacturing/importing sites of APIs and/or finished products has been updated.
For pharmaceutical sites within the EEA:

  • The validity of GMP certificates will be automatically extended until the end of 2021 without any further action by the certificate holder. This automatic extension does not apply to changes in the scope of the GMP certificate (e.g. new buildings, new medicinal products). However, it also applies to the validity of time-limited authorisations/registrations, which should also be automatically extended until the end of 2021. Changes to the scope of application are not included here, either.
  • For new sites/facilities that have never been inspected and approved, a distant assessment can be conducted as a first step. If the result is positive, a certificate may then be issued. An on-site inspection should be carried out as soon as circumstances permit. If the result is negative, a time stop will be triggered until an on-site inspection is possible.

For pharmaceutical sites outside the EEA:

  • In principle, the same conditions apply as for sites within the EEA, unless the issuing/supervisory authority takes measures that affect the validity of the certificate. Here, too, new sites/plants are subject to the possibility of a remote assessment by an EEA supervisory authority, in case no corresponding mutual agreement (MRA) exists.
  • Pre-authorisations or routine on-site inspections should be resumed as soon as the COVID-19 restrictions are lifted.

It is emphasised that manufacturers and importers remain obliged to comply fully with all GMP requirements.

Questions 4.2, 4.3, 4.4 on pharmacovigilance measures are new.

  • Question 4.2 deals with the management of corrective and preventive actions. These should be duly recorded as soon as identified and addressed and closed when circumstances permit so.
  • Question 4.3 explains that quality system audits should be carried out regularly and on a risk-based basis. Delays in conducting audits during the pandemic should be well justified and documented and should be resumed as soon as possible. Alternative means such as remote audits should be considered (e.g. telephone calls or video conferences). Utilising questionnaires alone, without supporting evidence, would not be accepted as audits.
  • Question 4.4 deals with on-site inspections. These may not be possible due to travel bans, restrictions on access to facilities or additional health risks for inspectors and inspectors. A remote inspection may also be carried out during pharmacovigilance inspections. Whether it is feasible and whether all technical requirements, e.g. remote access to electronic systems, are met, has to be clarified in advance.

 
As a marketing authorisation holder you should regularly check this EMA-page for new information.


Source:

EMA: Q&A

EMA: COVID-19: What's new?

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