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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

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