Skip to main content Skip to search Skip to main navigation

EMA: Updated Q&A on Combination Products

EMA has updated their „Questions & Answers for applicants, marketing authorisation holders of medicinal products and notified bodies regarding medicines used in combination with medical devices and consultation for certain medical devices“.

This Q&A document provides practical considerations concerning the application of the medical devices and the in vitro diagnostic medical devices regulations (MDR and IVDR) in the context of combinations of medicinal products with medical devices.

A new chapter 4 on lifecycle management has been introduced. It deals with changes after the initial marketing authorisation (MA).

The general principles with regard to device changes when used in combination are:

  • Agreements between the marketing authorisation holder (MAH) and the device manufacturer must ensure effective communication and management of changes to the device component.
  • The MAH must assess whether any device change may impact the delivery, quality, safety or efficacy of the medicinal product.
  • If the change affects information registered in the MA dossier, a variation application must be submitted according to the EU Variations Guideline.
  • Even if the registered information is not affected, a variation is still required when the change impacts delivery, quality, safety or efficacy of the medicine–device combination.
  • No variation is needed only if the change neither affects registered information nor impacts delivery, quality, safety or efficacy, and the information is not required in the MA dossier.

A new or revised notified body opinion or for class I (excluding Im and Is), MAH’s GSPRs (General Safety and Performance Requirements) compliance statement is:

  1. required when a new device is introduced with an extension of MA or a variation
  2. expected when major changes are introduced to an existing device which may have a significant impact on the delivery or the quality, safety, or efficacy of the medicinal product, such as:
  • change to its design
  • addition or replacement of an integral device (or device part)
  • change to its performance characteristics
  • change to its intended purpose such as a different patient population and/or new user (e.g. home versus hospital setting) and/or new usability study, and/or significantly different instructions for use



Source:

EMA: Q&A on Combination Products – with track changes (Source not available anymore)

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