Skip to main content Skip to search Skip to main navigation

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.

The Guideline on the chemistry of active substances was revised to include further recommendations on cohort of concern impurities, principally N-nitrosamines, and expand the sections covering starting materials, recovery and re-processing.

What’s new compared to the 2016 guideline?

1. Strong focus on nitrosamines & mutagenic impurities
The new guideline explicitly requires:

  • Assessment of nitrosamine risks across the entire process
  • Consideration of “cohort of concern” impurities (ICH M7)
  • Implementation of robust control strategies

2. Much deeper process understanding expected
Compared to the previous version, companies now need to provide:

  • Full process transparency, including all materials (e.g. gases, quenching agents, depletion agents)
  • Quantitative information (e.g. molar equivalents, excess reagents)
  • Clear process flow diagrams and step-by-step descriptions

3. Expanded requirements for starting materials

  • Stronger justification of starting material selection
  • Mandatory evaluation of impurity carry-over, especially mutagenic impurities
  • Nitrosamine risk assessment already at starting material level
  • Increased regulatory scrutiny of supplier and manufacturing changes

4. Tightened rules for reprocessing & recovery

  • Clear distinction between routine vs. occasional reprocessing
  • Reprocessing must be part of the validated process if frequently used
  • Recovery of materials must be risk-assessed
  • Use in late stages (e.g. final step) is discouraged unless justified

5. Explicit control strategy required (aligns with ICH Q11)
The new guideline introduces a clear expectation to:

  • Describe the overall control strategy (not just individual controls)
  • Link process understanding, impurity risks, and specifications
  • Justify decisions based on scientific rationale and risk assessment

6. Analytical expectations increased

  • Methods must be sensitive enough for toxicologically relevant limits
  • Specific expectations for nitrosamine detection (Limit of Quantitation, LOQ)
  • Stronger link between analytics and control strategy

Source:

EMA: Chemistry of active substances (chemistry of new active substances) - Scientific guideline

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:

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
What are the Prospects and Developments in the Operation of Computerised Systems?

What are the Prospects and Developments in the Operation of Computerised Systems?

Here's the answer:
Read more
Previous
Next