Skip to main content Skip to search Skip to main navigation

EC: Updated Q&A on Safety Features, Version 19

The European Commission published Version 19 of the Q&A on safety features for medicinal products in late December 2021.

What's new?

  • Question 1.29: Do the unique identifiers of reference and retention samples taken from stock in compliance with Annex 19 of the EU GMP Guidelines5 and uploaded to the EMVS have to be decommissioned? If yes, to what status?
    Answer: Yes, if a sample of a batch is taken as reference or retention sample after uploading in EMVS, it should be decommissioned as "sample". If a sample is taken voluntarily by a wholesaler that fall outside the scope of Annex 19, they should be decommissioned as "destroyed".

What has been updated?

  • Question 1.22: In the case of parallel-traded packs, can parallel traders cover or remove the safety features of the original pack?
  • Answer:
    Yes. Parallel traders who cover or remove the existing safety features are required to apply equivalent safety features in accordance with Article 47a of Directive 2001/83/EC. If the product code or/and batch number change, the original one must be decommissioned as a first step. The new individual identifier should comply with the requirements of the Member State where the medicinal product is to be placed on the market. In any case, traceability must be maintained in the final storage system.

 

  • Question 5.8: Can a wholesaler request another wholesaler to verify the authenticity and decommission the unique identifiers for medicinal products they intend to distribute outside the EU on their behalf?
    Answer: No, this obligation cannot be delegated, as the audit trail would not reflect the reality of the supply chain.

 

  • Question 7.19: Can a marketing authorisation holder delegate the uploading of the information laid down in Article 33(2) of Commission Delegated Regulation (EU) 2016/161?
    Answer: Yes, this is possible if there is a written agreement between both parties. However, the legal responsibility will remain with the MAH. He must ensure the accuracy, confidentiality, and integrity of the data uploaded into the system.

Source:

EC: Q&A Safety Features, Version 19

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:

EU: Annexes 4 and 5 no Longer Included in the EU GMP Guide

EU: Annexes 4 and 5 no Longer Included in the EU GMP Guide

Following the entry into application of Commission Implementing Regulations (EU) 2025/2091 and (EU) 2025/2154 on the principles and guidelines of Good Manufacturing Practice (GMP) for veterinary medicinal products and active substances for veterinary medicinal products on 16 July 2026, the European Commission removed Annexes 4 and 5 from the EU GMP Guide.
Read more
EMA: Revision of Annex 15 Delayed

EMA: Revision of Annex 15 Delayed

In February 2026, the EMA published a concept paper on the revision of Annex 15 "Qualification and Validation" of the EU GMP Guide (we reported previously). The Agency has now released a corrected version containing a significantly revised timetable.
Read more
EU: Updated Q&A on Safety Features for Human Medicinal Products

EU: Updated Q&A on Safety Features for Human Medicinal Products

The European Commission has published Version 22 of its Questions and Answers on Safety Features for Medicinal Products for Human Use.
Read more
EMA: Q&A Paper on Measures to Prevent Microbial Contamination of Non-Sterile Medicinal Products

EMA: Q&A Paper on Measures to Prevent Microbial Contamination of Non-Sterile Medicinal Products

The EMA has published a new Q&A paper on technical and organisational measures to prevent microbial contamination of non-sterile medicinal products.
Read more
When APS Fail and First Air is at Risk

When APS Fail and First Air is at Risk

At the PDA Good Aseptic Manufacturing Conference 2026, Alberto Gonzales (Takeda) discussed challenges and practical solutions related to aseptic process simulations (APS). Anna Campanella (Takeda) and Hussein Bachir (Franz Ziel) explored how first air protection in aseptic processing can be compromised by equipment design, glove interventions, and operator activities.
Read more
Why is import authorisation necessary for medicinal products entering the EU?

Why is import authorisation necessary for medicinal products entering the EU?

Here's the answer:
Read more
Previous
Next