Skip to main content Skip to search Skip to main navigation

EMA: What EU adaptations are necessary for ICH Q12?

The ICH Q12 guideline on technical and regulatory considerations for pharmaceutical product lifecycle management was adopted by the CHMP (European Committee for Medicinal Products for Human Use) in January 2020. On March 4,  the EMA (European Medicines Agency) published a two page note on the implementation of ICH Q12. It addresses the fact that there are conceptual differences between ICH Q12 and the EU legal framework. Therefore, a 1:1 application in the EU is not possible without further ado.

This applies to

  • the term “Established Conditions (ECs)” and  the associated reporting categories (section 3.2.3), which do not exist in EU law, and
  • the Product Lifecycle Management (PLCM) document, as described in Chapter 5 which is not considered compatible with the existing EU legal framework on variations.

However, it is clearly understood, that the legal requirements of the EU take precedence over scientific or technical guidelines. Therefore, the definition ECs and their reporting categories must comply with EU Variation Regulation(EC) No1234/2008 and the associated guidelines. As far as PLCM documents are concerned, if submitted, they currently cannot be recognised in the EU.

Irrespective of this, the concepts in ICH Q12, which are not foreseen in the EU regulatory framework will be further reviewed. The European Commission, together with the EMA and the National Competent Authorities, will continue to work on the implementation of ICH Q12 within the existing EU legal framework.


Source:

EMA: Note on EU Implementation of ICH Q12

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FDA: Draft Guidance on Responding to Form 483 Observations

FDA: Draft Guidance on Responding to Form 483 Observations

The US Food and Drug Administration (FDA) has issued a draft guidance on responding to Form FDA-483 observations following drug CGMP inspections.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