Skip to main content Skip to search Skip to main navigation

EMA: Final assessment report on nitrosamines

The Committee for Medicinal Products for Human Use (CHMP) of the European Medicines Agency (EMA) has published a final assessment report on nitrosamine impurities.

The report calls on the pharmaceutical manufacturers concerned to reduce the presence of nitrosamines in medicinal products as far as possible and to comply with the defined limits.

We prepared an overview for you that summarizes the recommendations of the comprehensive 90-page report of the EMA: 

  • The presence of N-nitrosamines in medicinal products for human use should be reduced as far as possible, based on the limits of the principles stated in ICH M7 (R1) and calculated considering a lifetime daily exposure. 
     
  • The risk of presence of nitrosamines should be evaluated by marketing authorisation holders respectively applicants. If there is a risk, further confirmatory tests should be performed. For new applications for authorisation, a risk assessment on the presence of nitrosamines must be submitted with the application.
     
  • The risk assessment should include manufacturing processes of active substances and finished products, taking into account the root-causes, and subsequent confirmatory tests on the finished product, if a risk exists.
     
  • For biological medicinal products the general risk of nitrosamine formation is very low, but the following cases should be considered: Biological medicinal products containing chemically synthesised fragments where risk factors similar to chemically synthesised active substances exist, biological medicinal products to which nitrosating reagents are deliberately added during the manufacturing process, biological medicinal products packaged in primary packaging such as blisters made of nitrocellulose
     
  • If more than one nitrosamine has been found in a finished product or the active substance, it must be ensured that the total risk of the sum does not exceed 1:100,000 at life-time risk. Alternatively, the sum of all N-nitrosamines found should not exceed the limit for the most potent nitrosamine.
     
  • If the limit value for a single nitrosamine cannot be met according to ICH M7 (R1), the marketing authorisation holder should immediately submit an investigation report including the potential/identified causes, preventive/corrective measures and a discussion of the impact on the risk-benefit balance. The authorities decide on a case-by-case basis.
     
  • Exceptions to the limit values apply to finished products for the treatment of advanced cancer stages (here ICH Q3 A(R2), ICH Q3B(R2) and Q&A to ICH S9 apply) or in cases where the active substance itself is genotoxic (here limits for non-mutagenic impurities according to ICH M7 (R1) can be used).
     
  • If there are sufficient data on carcinogenicity from animal studies for a reliable TD50 value, a substance-specific limit should be derived from this.
     
  • If N-nitrosamines are found for which no substance-specific data are available, the class-specific TTC of 18 ng/d from the Lhasa carcinogenic potency database should be used. 

Marketing authorisation holders are obliged to carry out risk assessments for APIs as well as for the finished product, to ensure that the medicinal products are manufactured in accordance with the latest scientific and technical standards in accordance with Article 23 and Annex I of Directive 2001/83/EC and Article 16 of Directive (EC) 726/2004 and, where necessary, to adapt the manufacturing processes accordingly. 

It must also be ensured that all active substances and excipients are manufactured in accordance with the principles of good manufacturing practice as laid down in Article 46(f) of Directive 2001/83/EC.

Further detailed information for pharmaceutical companies can be found on the Nitrosamine website of the EMA


Source: 

EMA: CHMP assessment report 

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:

FDA: Draft Guidance on Responding to Form 483 Observations

FDA: Draft Guidance on Responding to Form 483 Observations

The US Food and Drug Administration (FDA) has issued a draft guidance on responding to Form FDA-483 observations following drug CGMP inspections. The document provides recommendations on how manufacturers should structure their responses and what information they should include.
Read more
Which Quality and Process Parameters must Typically be Taken into Account During Process Validation for Terminally Sterilized Products?

Which Quality and Process Parameters must Typically be Taken into Account During Process Validation for Terminally Sterilized Products?

Here's the answer:
Read more
Veterinary GMP 2026: The New Regulatory Framework

Veterinary GMP 2026: The New Regulatory Framework

Implementing Regulations (EU) 2025/2091 and 2025/2154 consolidate the GMP requirements for veterinary medicinal products into a distinct and legally binding framework for the first time. While establishing regulatory independence for the veterinary sector, they remain substantively aligned with the EU GMP Guide.
Read more
Team-NB: Opportunities and Concerns in the MDR/IVDR Revision

Team-NB: Opportunities and Concerns in the MDR/IVDR Revision

Team-NB, the European association of medical device Notified Bodies, sees the proposed MDR and IVDR revision as an opportunity to improve efficiency, transparency and predictability in conformity assessment.
Read more
EMA: GMP Documentation for the Sterilisation of an API

EMA: GMP Documentation for the Sterilisation of an API

The EMA Q&A on the quality of medicines has been updated with a new question: “What kind of GMP documentation is required for an API manufacturer performing sterilisation of an active substance?”

Read more
EMA: Updated Q&A on OOS Batches of ATMPs

EMA: Updated Q&A on OOS Batches of ATMPs

The EMA has revised its questions and answers on the use of out-of-specification (OOS) batches of authorised cell- and tissue-based ATMPs (“Questions and answers on the use of out-of-specification batches of authorised cell/tissue-based ATMPs”, Rev. 1, 2026).
Read more
Previous
Next