Key Rules in Pharmaceutical Product Registration and Pharmacovigilance

Pharmacovigilance rules and regulations arestage to involve a pharmacovigilance services
understandably complex, aimed at ensuring there iscompany to ensure the process is properly
always ongoing good quality reporting and monitoringadministrated and staff understand fully what is
of pharmaceutical products. There's no substitute forrequired at all stages to avoid mistakes.
the professional advice of a pharmacovigilanceAbout The Mutual Recognition Procedure
services company, but this article provides a briefHere this refers to cases where a marketing
guide to some of the key regulations and guidelinesauthorisation has been authorised by one EU country
for products marketed in the EU. This guide can be aand it is essentially copied by all other EU countries.
useful adjunct to professional advice to allow betterThere is the 'Reference Member State', where the
pharmacovigilance work liaison with related teams inmarketing authorisation is granted, and the other
understanding of how the Centralised Procedure,countries, referred to as the 'Concerned Member
Mutual Recognition Procedure and DecentralisedStates'. An application under the Mutual Recognition
Procedure operate in the EU.Procedure incurs a 90 day period during which the
The Three Routes for Pharmaceutical Product'Concerned Member States' accept the product as
Registrationfar as Marketing Authorisations are concerned or
Pharmaceutical products which are to be marketed inraise considerations about the product. If the
one or more member states of the EU must beapplication is successful, a marketing authorisation is
subjected to one of three procedures to gain thegiven which is an identical summary of product
correct Marketing Authorisations status:characteristics to that of the original marketing
"Centralised Procedure" - Regulation (EC) No 726authorisation in the 'Reference Member State'.
2004Sometimes, the process will not automatically
"Mutual Recognition Procedure"succeed. EU countries may raise objections and in the
"Decentralised Procedure" - Directive 2001/83/EC.intervening time, the original marketing Authorisation
There are also certain extra-national authorisationswill simply not be recognised by them. The next
which allow products to be marketed in some singlestage is then referral to the EMEA, where the
EU member states. This means products may bematters are formally debated, involving all concerned
regulated under separate authorisation in two orparties. If this step does not resolve the issues, there
more individual EU countries. The Mutual Recognitionthen will be recourse to binding arbitration.
Procedure allows for application for a nationalThis is another stage at which professional advice
authorisation. The regulatory body in the country infrom an experienced relatedpharmacovigilance
which the original national authorisation was obtainedservicesteam is obviously going to be of paramount
is deemed responsible for product monitoring andimportance to guide the applicant throughout the
safety assessment.process.
About The Centralised ProcedureAbout The Decentralised Procedure
This is the administrative responsibility of the EMEA.When no marketing authorisation has been issued in
A single application for marketing authorisation for allany EU country, an identical dossier is submitted to
the countries in the European Union (and theevery EU country in which a marketing authorisation
European Economic Area, meaning all EU countries,is desired. The applying company can nominate which
Iceland, Norway and Liechtenstein) is made. Ifcountry becomes the 'Reference Member State'. The
applications are approved, at the point they enter thecompany must compile a preliminary report within a
market then all products become the responsibility oftimeframe of 120 days and distribute it to
The European Commission instead.appropriate personnel in regulatory agencies of all the
This option applies for all new or novel pharmaceuticalEU countries concerned. Those countries are then
products and stands as the only route at this timeallowed to approve or raise objections. In the case
for any biotechnology medicines. It's also the routeof objections, there is a facilitation process which is
for any product which contains novel substancesentered into to try to resolve the problems. A
which have the intended purpose of modifyingfurther step should facilitation not proved expedient
serious disease.is again, arbitration.
The regulatory agency of one EU country is chargedThroughout this regulatory process, the input of the
with becoming the Rapporteur, who completes theapplicant's pharmacovigilance work team is vital to
initial assessments required for a Marketingensure that the process continues smoothly. The
Authorisation. Their Rapporteur will undertake initialinvolvement of many countries requires a truly
assessments which are necessary for the applicationinternational level of expertise and applicants are
for a Marketing Authorisation. In addition, as aadvised to partner with experienced
double-checking system, there will be thepharmacovigilance companies.
appointment of a Co-Rapporteur, a second agencyUnderstanding these three basic regulatory pathways
to oversee things, from a second EU country.can be useful when working with an in-house or
Between the two agencies, the safety assessmentexternal pharmacovigilance services team. From this
and monitoring are directed in a controlled manner tobackground reading, it should be easier to begin
allow the product to be introduced onto the market.discussions around the legal requirements of product
They will also hold responsibility for the continuingregistration in the EU. In every eventuality, there is
pharmacovigilance work during the time the productno better advice than that of experienced
will be on sale after its introduction.international pharmacovigilance workconsultants.
Application for a Marketing Authorisation is a key