Questions and answers: Urgent Union procedure (Article 107i)

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This page lists questions that stakeholders, particularly marketing-authorisation holders (MAHs), may have on urgent Union procedures.

It provides an overview of the European Medicines Agency’s practical and operational aspects with regards to the handling of these procedures.  Revised topics are marked 'New' or 'Rev.' on publication.

A PDF version of these questions and answers is available:

These questions and answers are for guidance only, without prejudice to legal and regulatory interpretation that might be provided in future updates of the rules governing medicinal products in the European Union, volume 2, notice to applicants.

These questions and answers should be read in conjunction with Directive 2001/83/EC, as amended by Directive 2010/84/EU of the European Parliament and of the Council of 15 December 2010, without prejudice to the implementation of the changes resulting from Directive 2012/26/EU of the European Parliament and of the Council of 25 October 2012 amending Directive 2001/83/EC as regards pharmacovigilance.

Table of contents


Initiation of the urgent Union procedure

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1. What is the legal basis of an urgent union procedure? Rev. March 2015

An urgent union procedure follows the provisions under Article 107i of Directive 2001/83/EC.

The procedure for an urgent union procedure under Article 107i is laid down in Articles 107j to 107k of Directive 2001/83/EC.

References:

2. In which situations is an urgent union procedure initiated? Rev. March 2015

An urgent union procedure is automatically initiated when, on the basis of concerns resulting from the evaluation of data from pharmacovigilance activities, a Member State or the European Commission considers one (or more) of the following situations:

  1. suspending or revoking a marketing authorisation (MA);
  2. prohibiting the supply of a medicinal product;
  3. refusing the renewal of a MA;
  4. is informed by the marketing authorisation holder that, on the basis of safetyconcerns, he has interrupted the placing on the market of a medicinal product or has taken action to have a MA withdrawn, or intends to take such action or has not applied for the renewal of a MA.

References:

3. In which other situations can an urgent union procedure be initiated? Rev. March 2015

When, on the basis of concerns resulting from of the evaluation of data from pharmacovigilance activities, a Member State or the European Commission considers that urgent action is necessary in case of a new contraindication, a reduction in the recommended dose or a restriction to the indications of a medicinal product. Then this procedure can be triggered.

4. Who can initiate an urgent union procedure? Rev. March 2015

This procedure can be initiated by competent authorities in the Member States (MSs) or by the European Commission (EC). A marketing authorisation holder (MAH) cannot trigger this procedure.

The initiator of the procedure will circulate a notification to the Agency, all MSs and the EC triggering the urgent union procedure. The notification will identify the safety concern including a detailed explanation of the issue raised and the regulatory action which is being considered.

The notification will be publicly available at the start of the procedure (please refer to Question 9).

5. Can a Member State take regulatory action before triggering an urgent union procedure?

A Member State may, where urgent action is necessary to protect public health, suspend the marketing authorisation and prohibit the use of the medicinal product concerned on its territory until a definitive decision is adopted.

In this case, it informs the European Commission, the Agency and all other Member States, no later than the following working day, of the reasons for its action and simultaneously triggering the urgent union procedure (please refer to Question 2 and Question 3).

6. Which medicinal products can be involved in an urgent union procedure? Rev. March 2015

All products affected by the safety issue and with a valid marketing authorisation (MA) in the European Union will be included in the urgent union procedure.

This includes all products concerned by the safety issue, regardless of whether the MA was granted nationally (including via the mutual recognition and decentralised procedures) or via the centralised procedure. However, in case the safety issue concerns only centrally authorised medicinal products, the procedure under Article 20 of Regulation (EC) No 726/20041 is initiated and will follow the steps of an urgent procedure, as needed.

The procedure may concern a specific medicinal product, all medicinal products containing the same active substance (range of medicinal products) or all medicinal products belonging to the same therapeutic class (several active substances concerned).

The marketing authorisation holders cannot choose whether or not to include their products in an urgent union procedure. The inclusion of their products depends on the scope of the procedure.

References:


1Please refer to the questions & answers on practical implementation of Article 20 pharmacovigilance procedure.

7. How the product(s) are identified to be part of an urgent union procedure? Rev. March 2015

The Agency and the competent authorities of the Member States (MSs) within the European Economic Area (EEA) will identify the authorised products that are concerned by the procedure. All authorised products concerned are identified by using information from the Article 57 database. This will take place at the start of the procedure, and a draft list of the products identified will be publicly available on the Agency’s website on the specific procedure webpage (please refer to Question 9).

If after consultation with the MSs, it is concluded that the safety issue triggering the urgent union procedure also concerns other product(s) (e.g. range of products, a therapeutic class) than the ones covered by the notification, the Agency can extend the scope of the procedure.

From a procedural view point, only those products identified at the start of the procedure will be covered by its scope. However, to the extent that other medicinal products affected by the scope but not identified at the start of the procedure are authorised in the EEA, or subject to future authorisations by the MSs, upon conclusion of the procedure, the concerned MSs should take due consideration of the scientific conclusions of the procedure and apply them to these products not initially included in the procedure.

8. What happens if the medicinal product involved is only approved in one Member State? Rev. March 2015

Upon receipt of the notification triggering the urgent union procedure, the Agency, based on the information collected from Articled 57 database, will liaise with the national competent authorities of the Member States (MSs) within the European Economic Area (EEA).

If after consultation with the MSs, it is concluded that the scope of the procedure concerns product(s) authorised in only one MS, an urgent union procedure will not be initiated, and the safety issue will only be handled by the MS concerned.

9. When and how will an urgent union procedure be announced? Rev. March 2015

A brief summary of the safety issue and the urgent action being considered will be discussed at the upcoming Pharmacovigilance Risk Assessment Committee (PRAC) plenary meeting and will be included in the agenda published at the beginning of the PRAC meeting.

The start of the procedure will be announced as part of the PRAC meeting highlights, which will be published on the next working day following the PRAC meeting during which the matter is considered.

In certain cases, depending on the urgency of the matter the announcement may take place earlier.

The announcement will specify the safety issue under urgent consideration, the product(s) concerned and the modalities for the marketing authorisation holders (MAHs), healthcare professionals and the general public to submit to the Agency information relevant to the procedure (please refer to Question 15, Question 19 and Question 21).

The following documents will be published at the time of announcement of the start of the procedure on the Agency’s website on the specific procedure webpage:

  • notification triggering the procedure together with the scientific background;
  • products listing including name of the medicinal products concerned/active substances and MAHs;
  • list(s) of questions and timetable adopted by the PRAC;
  • summary of the start of the procedure and
  • press release in relation to the urgent union procedure, if applicable.
10. How will marketing authorisation holders be informed about the start of the urgent union procedure? Rev. March 2015

The public announcement on the Agency’s website will include all information related to the start of procedure.

In addition, all qualified persons for pharmacovigilance (QPPV) of the medicinal product(s) concerned by the urgent union procedure identified in the published products listing will be notified electronically (via e-mail/Eudralink) by the Agency. The notification to the QPPV on the procedure initiation will include:

  • the name and contact details of the Agency’s dedicated Procedure Manager who will be the contact point throughout the procedure and the name of the product-shared mailbox, which should always be copied in all correspondence with the Agency;
  • the pathway to the Agency’s website where the relevant documentation is available

The Agency may release updated information on the website during the procedure and therefore marketing authorisation holder(s) and other interested parties should continuously check the Agency’s website for any relevant updates (please refer to Question 30, Question 36 and Question 40).

11. Should marketing authorisation holders identify a contact person to communicate with the Agency during the urgent union procedure? Rev. March 2015

The marketing authorisation holders (MAHs) will not need to designate a specific contact person for Pharmacovigilance referrals procedures. The qualified person for pharmacovigilance (QPPV) will, by default, be the contact person and will receive all correspondence from the Agency regarding the pharmacovigilance procedure.

The QPPV may if they wish to, designate a different contact person for the procedure. In this case it must inform the procedure manager identified in the notification sent at the time of the procedure initiation.

All documentation concerning the urgent union procedure will be sent to the contact person only.

Receipt of any documents by the contact person will be considered to constitute effective receipt by the MAH inter alia for the purposes of calculating the procedural timelines.

12. Can marketing authorisation holders group with other marketing authorisation holders involved in the procedure? Rev. March 2015

The marketing authorisation holders can form a group for the purpose of the procedure in order to provide a single consolidated response and/or oral clarifications to the questions raised by the Pharmacovigilance Risk Assessment Committee (PRAC) during the procedure. In this case the cover letter accompanying the single consolidated response and/or request for oral explanation should clearly identify the parties responsible for the submission/request.

13. What happens if centrally authorised products are involved in the procedure? Rev. March 2015

If a centrally authorised product is involved in an urgent union procedure, the qualified person for pharmacovigilance (QPPV) will be notified by the Agency of the start of the procedure, as will all other QPPV (please refer to Question 10). The announcement on the Agency’s website will also be linked to the EPAR page of the product.

14. Do marketing authorisation holders have to pay a fee? Rev. March 2015

The Agency will levy a fee for the assessment of an urgent union procedure under Article 107i of Directive 2001/83/EC.

The total chargeable units in the procedure will be identified from the Article 57 database. The share payable by each marketing authorisation holder (MAH) will be calculated by the Agency. In this respect, an advice note will be sent at the start of procedure, to the relevant qualified person(s) for pharmacovigilance (QPPV) in order to ensure the accurate identification of the chargeable units for the products involved in the procedure. At the start of the procedure, the invoice will be sent to each MAH with the relevant chargeable units calculation. The fee will be due to the Agency within 30 calendar days from the date of the invoice.

For MAHs already qualified as a micro-, small or medium-sized enterprise (SME) by the Agency, or those that will send a SME declaration in advance of the start date, or at least after 30 days of the invoice date, the fee will be reduced (small- or medium-sized enterprise) or waived (micro-sized enterprise).

The Agency will also publish further guidance on how the fees will be calculated and collected.

References:

15. Who can submit data to be considered for this procedure? Rev. March 2015

The marketing authorisation holders (MAHs), health care professionals and the general public have the right to submit information relevant to the safety issue under review within the urgent union procedure.

This is an opportunity given by the provisions of the pharmacovigilance legislation for data to be submitted by all stakeholders, and considered for the assessment of the safety issue. This is not a mandatory step of the procedure.

The announcement of the start of the procedure will include detailed information on how and when to submit data (please refer to Question 19 and Question 20).

Regardless of whether or not the MAHs present written or oral explanations to the Pharmacovigilance Risk Assessment Committee (PRAC), a recommendation will be issued by the PRAC, in any case, applicable to all marketing authorisations concerned by the procedure.

16. How will data be gathered during the procedure?

The safety issue under urgent consideration by the PRAC will be substantiated by additional data that could be requested under the format of a list(s) of questions, comments to the scientific background supporting the triggering of the procedure or by using data sources available to the Agency and/or to the national competent authorities (NCAs) of the Member State(s).

The additional data may be gathered from several different sources (i.e. from concerned marketing authorisation holders, healthcare professionals, patients’ organisations, the public, eudravigilance data, data available to the NCAs, etc). The need for specific data to be collected is identified by the PRAC at the start of the procedure and announced on the Agency’s website.

The data to be considered for the assessment will have to be submitted within the specified deadline as published in the announcement of the start of the procedure (please refer to Question 9). The time limit for submission of data will not exceed 20 days.

Notwithstanding the above, the PRAC may in some specific cases also collect additional data through a public hearing and/or in an oral explanation (please refer to Question 24).

17. Who will perform the assessment?

The assessment of data within an urgent union procedure is the responsibility of the Pharmacovigilance Risk Assessment Committee (PRAC). At the start of the procedure, the PRAC appoints a PRAC rapporteur and PRAC co-rapporteur who will take the lead in the assessment of all data collected within the agreed timelines.

The assessment will result with the PRAC issuing a recommendation on the safety issue reviewed, to be provided for adoption to the Committee for Medicinal Products for Human Use (CHMP) or to the Co-ordination Group for Mutual Recognition and Decentralised Procedures - Human (CMDh), as applicable (please refer to Question 33).

Even though the assessment of the urgent union procedure will be performed by the PRAC, there will be a close collaboration between the PRAC (co-) rapporteurs and the CHMP rapporteur or with the CMDh member with a leading role during the assessment.

18. How are the PRAC rapporteur and PRAC co-rapporteur appointed? Rev. March 2015

The Pharmacovigilance Risk Assessment Committee (PRAC) (co-) rapporteur for an urgent union procedure should be appointed by the PRAC from amongst its members or alternates (hereafter referred to as PRAC members).

The PRAC will endeavour to apply the criteria of best available expertise to be taken into account for the appointment of the PRAC (co-)rapporteurs for each urgent union procedure.

In case of an urgent union procedure concerning several active substances belonging to the same therapeutic class, or where several issues are to be assessed, a lead rapporteur and several co-rapporteurs could be appointed.

References:

During the assessment

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19. How shall I present my responses? Rev. March 2015

The announcement of the start of the procedure will specify the modalities for submission of data relevant to the procedure (e.g. response to the Pharmacovigilance Risk Assessment Committee (PRAC) list of questions, comments to the scientific background supporting the triggering of the procedure).

Considering the urgency of the matter, all information available by stakeholders (e.g. marketing authorisation holders (MAHs), healthcare professionals, patients’ organisations, general public) must be provided by the date published in the announcement.

Marketing authorisation holder(s) (MAHs)

The MAHs of products concerned by the procedure should submit their responses as follows:

  • The data should be presented in electronic format according to the electronic Common Technical Document (eCTD)/CTD format and accompanied by a signed cover letter and a written summary of each question.
  • The cover letter must make clear reference to the procedure number and the Agency’s Procedure Manager who should always be put in copy. A cover letter template is available on the Agency's website.
  • The written summary answering each question should follow the numbering as per the published PRAC list of questions. Please note that supportive data to the responses submitted (e.g. study reports, literature data, risk management plan) are expected to be provided together with a summary of those data as per the modular structure of the CTD format.

Published data can be presented as supportive documentation in response to a specific question if no other data is available.

In case some questions (e.g. on a specific pharmaceutical form) are not applicable/relevant to all product(s) concerned by the procedure or to the product(s) of the represented group, the response should be “not applicable” with a short explanation.

It should be noted that the responsibility for the quality of the submitted documentation lies with the MAHs and is crucial to the overall assessment of the safety issue. All submissions are expected to be submitted in English and electronically only (please refer to Question 20). Submission of responses concerning the Article 31 Pharmacovigilance referral with regards to centrally authorised products (CAPs) should follow the requirements for post-authorisation procedures for CAPs (e.g. submission via e-CTD).

In case MAHs formed a group (please refer to Question 12), the cover letter accompanying the single consolidated response and/or request for oral explanation should clearly identify the parties responsible for the submission/request.

Other stakeholders

All submissions from other stakeholders who are not the MAHs concerned by the procedure, (e.g. healthcare professionals, patients’ organisations, general public), have to be accompanied by a submission form with all its mandatory fields duly completed. This is a requirement for data to be considered for assessment. The submission form template is available in the announcement of the urgent union procedure that has a dedicated section for submission of data by stakeholders who are not MAHs.

The other requirement is the submission of all data within the deadline specified in the announcement.

In all cases, data submitted should be accompanied by an overall summary of its content and should make reference to the specific PRAC question being addressed (as per PRAC published list of questions numbering).

It is of the utmost importance that data is provided in due course to avoid undermining the safety review. In the same sense, due regard should be given to timelines constraints in the event of requirements for translations prior to assessment. Considering this aspect within the nature and timeframe of an urgent union procedure, data submission in English and electronically is therefore strongly advised.

20. How and to whom shall I submit my responses? Rev. March 2015

Marketing authorisation holder(s) (MAHs)

Within the given timeline as specified in the announcement of the procedure, the responses should be submitted to the Agency via the Gateway as specified in Dossier requirements for referral procedures or Dossier Requirements for Centrally Authorised Products.

The Agency strongly recommends using the electronic submission channels (eSubmission Gateway or Web Client) and the electronic Common Technical Document (eCTD) or NeeS (Non-eCTD electronic Submission) formats for submission of referrals.

All submissions for referral procedures for human medicinal products should be sent via the eSubmission Gateway or the Web Client. Since 1 November 2014, the Agency no longer accepts electronic submissions for referrals on CD or DVD.

For referral submissions related to centrally authorised products, it is mandatory to use the eCTD format.

For all type of submissions responses should be presented in the modular format.

Recommended folder structure:


 

Documentation can be included in respective Modules following the CTD location as referenced in the above folder structure - e.g. as following:

Root folder should be 4 digits (between 0000-9999), e.g. Submission 0000 as below:


 

Any Working Documents (for example: documents in Word format) should be outside the root submission folder, e.g. as following:


 

More information on the required naming conventions and file formats can be found in EMA eSubmission Gateway: Questions and answers relating to practical and technical aspects of the implementation and in the eSubmission Gateway Web Client - Guidance for Applicants. For more information please refer to eSubmission website. Submissions that are sent using the eSubmission Gateway and web client will receive an automated acknowledgement.

There is no need to send any separate paper cover letters for these submissions, as the cover letter will be in the relevant part of eCTD module 1 in PDF format.

For the number of copies and for a full overview of the dossier requirements for the Agency, (co-)rapporteurs and Committee Members/Alternates and national competent authorities of (co-) rapporteurs, including delivery addresses, please refer to Dossier Requirements for Referral procedures or Dossier Requirements for Centrally Authorised Products. or should you have any questions regarding your submission, please contact us via email: referralsubmission@ema.europa.eu, for any technical issues contact esubmission@ema.europa.eu.

Other stakeholders

In the announcement of the urgent union procedure, other stakeholders who are not the MAHs concerned by the procedure, (e.g. healthcare professionals, patients’ organisations, general public) can submit data relevant to the assessment of the safety issue to the Agency via a given email address available in a dedicated section for submission of data by stakeholders.

All submissions of responses from other stakeholders should be submitted within the given timeline as specified in the announcement.

21. How will my data be assessed?

Submissions from marketing authorisation holders (MAHs) concerned by the procedure are provided in CTD format and directly to the PRAC (co-) rapporteur to be considered for the assessment.

Data submitted from other stakeholders (e.g. healthcare professionals, patients’ organisations, general public), will be received and recorded by the Agency.

The Agency will prepare a list of all data received (i.e. from MAHs and other stakeholders). This listing together with the respective data from other stakeholders’ non-MAHs will be provided by the Agency to the PRAC (co-) rapporteur to be considered for the assessment.

All information gathered will be assessed within an agreed timeframe as published in the announcement of the urgent union procedure. The assessment report(s) prepared by the PRAC (co-) rapporteur will reflect all data submitted and considered for the review. The listing will be annexed to the PRAC (co-) rapporteur’s assessment report(s) and to the PRAC assessment report and therefore published for transparency purposes and public awareness.

The PRAC (co-)rapporteur assessment report(s) will be circulated to the PRAC members for comments. These will also be shared with the CHMP rapporteur(s) (in case at least one centrally authorised product is included in the scope of the procedure) or with the CMDh member with a leading role as appointed by the CMDh at the initiation of the procedure (in case the concerned products are only nationally authorised including via the mutual recognition and decentralised procedures) for comments. This aims to ensure a close collaboration during the assessment.

22. What is the timetable for the assessment by the PRAC? Rev. March 2015

Please note that the timelines provided below are for guidance purposes only.

The timelines following a 60 day assessment period are as follows:

Article 107 Urgent Union Procedure – Timetable for the assessmentDay1
Assessment starts on the next PRAC meeting2 following submission of all data (as per the published deadline);

Day 1

 

PRAC (co)-rapporteur circulate the assessment report(s) on the data collected;Day 20
Comments in writing from PRAC members, CHMP concerned Rapporteur(s) (if at least one CAP is involved), CMD(h) member with leading role (if applicable);Day 35
PRAC (co-) Rapporteur circulate an updated assessment report(s) based on the comments received and reflecting any additional information received (if applicable);Day 45

PRAC Recommendation

  • Final discussion is held and the final recommendation is reached
Day 60

1The 60 days for assessment should be considered as the period of 3 consecutive PRAC plenary meetings.

2Corresponds to the 2nd PRAC meeting following the receipt of the notification triggering the procedure.


The dates to be followed in accordance to the above timetable for each month can be found in the following link to timetable for safety referral- article 107i.

The Pharmacovigilance Risk Assessment Committee (PRAC) has a maximum of 60 days to issue a recommendation after the deadline for the submission of all data as published at the time of announcement. However, in case of a justified urgency the PRAC may agree on a shorter timetable.

Additional procedural steps within the same timeframe (i.e. maximum of 60 days) may be necessary before the PRAC issues a recommendation. This applies in case of oral explanation(s) by the concerned marketing authorisation holder(s), public (and non-public) hearing or in case the PRAC requires input from a scientific advisory group or from an ad-hoc expert meeting to support the PRAC recommendation.

23. Will I receive the PRAC (co-) rapporteur assessment report(s)? Rev. March 2015

All marketing authorisation holder(s) (MAHs) with products included in the scope of the urgent union procedure will be provided with the Pharmacovigilance Risk Assessment Committee (PRAC)
(co-)rapporteur’s assessment report(s) electronically via email/Eudralink.

As a general rule, other stakeholders will not be provided with the PRAC (co-)rapporteur’s assessment report. In any case, the PRAC recommendation and assessment report will be published on the Agency website together with the final outcome of the Committee for Medicinal Products for Human Use (CHMP)/Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh), as applicable (please refer to Question 30).

24. Will I have the possibility to present my views in front of the PRAC and how is this organised? Rev. March 2015

The Pharmacovigilance Risk Assessment Committee (PRAC), depending on the urgency of the matter, may decide whether there are issues that need to be addressed orally by the marketing authorisation holders (MAHs). In such a case, the MAHs will be duly informed in advance of the issues to be addressed during the oral explanation.

The MAHs may also request the PRAC to attend for an oral explanation. In such a case, the MAHs should send a written request to the PRAC stating the reason(s) and specifying the issue(s) to be addressed during the oral explanation. The PRAC will take due account of the request considering the urgency of the matter, and will decide whether the oral explanation will be held.

Oral explanation(s) should take place during the assessment phase and after the receipt of the PRAC (co-)rapporteur’s assessment report(s). Further detailed information on organisational aspects of the oral explanation can be found here.

Exceptionally, an oral explanation may be held in front of the CHMP/CMDh, as applicable following the PRAC recommendation (please refer to Question 35)

The MAHs can provide the oral explanation on their own behalf or on behalf of the group of MAHs whom they represent.

Where the urgency of the matter permits, the PRAC may also hold public hearings, on justified grounds, particularly with regard to the extent and seriousness of the safety concern.

When the PRAC is of the opinion that a public hearing should be convened, the hearing shall be held in accordance with the modalities and rules specified by the Agency and shall be announced on the Agency’s website. The announcement shall also specify the modalities of the participation.

Where a MAH or another person intending to submit information has confidential data relevant to the subject matter of the procedure he may request permission to present that data to the PRAC in a non- public hearing.

A non-public hearing can only be held whenever a public hearing has been decided and agreed by the PRAC. When the MAH or another person requests a non-public hearing, this should be duly justified on the grounds of confidentiality of data to be presented.

25. What should I do if my product is transferred to another marketing authorisation holder? Rev. March 2015

If the marketing authorisation (MA) for a nationally (including mutual recognition and decentralised) approved product is transferred during the procedure, the former marketing authorisation holder (MAH) should update Article 57 database and inform the procedure manager for the referral procedure. The Agency will then liaise with the national competent authority (NCA) of the Member State (MS) concerned.

Following confirmation by the NCA of the transfer of a MA, the Agency will inform the new MAH that they are included in the urgent union procedure and will inform the new qualified person for pharmacovigilance (QPPV) via email/Eudralink.

If during the procedure the MA for an approved centrally authorised product (CAP) is transferred, the former MAH should inform the Agency and the appropriate procedure should be followed (please refer to transfer of marketing authorisation: questions and answers).

The products listing published at the start of the procedure (please refer to Question 9) will be updated accordingly and republished on the Agency’s website on the specific procedure webpage.

26. What should I do if the name of my product changes or, if the name and/or address of the MAH changes or, if my product is withdrawn? Rev. March 2015

If during the procedure, the name of a nationally (including mutual recognition and decentralised) approved product changes or if the name and/or address of the marketing authorisation holder (MAH) changes or if the marketing authorisation is withdrawn, the MAH should updated Article 57 database without delay.

If the Article 57 database is updated within the next 30 days following the start of the procedure, these changes will be included in the revised products listing that will be republished at day 30 following the start of the procedure. After day 30 the products listing will not be subject to any other changes except in case of transfer of a MA (please refer to Question 25).

If during the procedure, the name of an approved centrally authorised product (CAP)changes, or if the name and/or address of the MAH changes or if the marketing authorisation is withdrawn, the MAH should inform the Agency and the appropriate procedure should be followed (please refer to Changing the (invented) name of a centrally authorised medicine: questions and answers and Withdrawn-product notification: questions and answers).

Pharmacovigilance Risk Assessment Committee (PRAC) recommendation

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27. When will the PRAC recommendation be issued?

The PRAC has a maximum of 60 days to issue a recommendation after the deadline for submission of all data as published at time of announcement (please refer to Question 22). The PRAC recommendation will usually be issued on the last day of the PRAC's plenary meeting.

However, in case of justified urgency, the PRAC may issue a recommendation on a shorter timeframe and if needed by written procedure (i.e. outside a scheduled plenary meeting).

28. What could be the outcome of the PRAC recommendation?

The Pharmacovigilance Risk Assessment Committee (PRAC) recommendation shall include any or a combination of the following conclusions:

  1. no further evaluation or action is required at Union level;
  2. the marketing authorisation holder (MAH) should conduct further evaluation of data together with the follow-up of the results of that evaluation;
  3. the MAH should sponsor a post-authorisation safety study together with the follow up evaluation of the results of that study;
  4. the Member States (MSs) or MAH should implement risk minimisation measures;
  5. the marketing authorisation (MA) should be suspended, revoked or not renewed;
  6. the MA should be varied.

With regards to point (d), the recommendation will specify the risk minimisation measures recommended and any conditions or restrictions to which the MA should be made subject.

With regards to point (f), Where the recommendation is for the MA to be varied, including changes or addition of information in the summary of product characteristics (SmPC) or the labelling or package leaflet (PL), the recommendation will include the suggested wording of such changed or added information and state where in the SmPC, labelling or PL such wording should be placed.

The PRAC recommendation can be adopted by consensus or by majority vote. In the event of adoption by majority, the divergent positions of the concerned PRAC members and the grounds on which they are based shall be appended in the recommendation issued by the PRAC.

References:

29. How is the PRAC recommendation structured? Rev. March 2015

The Pharmacovigilance Risk Assessment Committee (PRAC) recommendation will include:

  • a cover page in which the recommendation adopted is outlined together with the voting outcome of the PRAC;
  • a products listing including name of the medicinal products concerned/active substances and marketing authorisation holders (MAHs) for all identified products approved nationally (including via the mutual recognition/decentralised procedures). In case centrally authorised products (CAPs) are involved their respective Annex A will be attached;
  • the scientific grounds and explanation for the PRAC recommendation;
  • the wording (in English only) to be included in the relevant sections of the summary of product characteristics (SmPC) or the labelling or package leaflet (PL), if applicable;
  • the conditions or restrictions imposed on the MAHs or Member States for the safe and effective use of the medicinal product, if applicable;
  • the PRAC members’ divergent views, in case the recommendation is adopted by majority;
  • Direct Healthcare Professional Communication (DHPC) and communication plan as agreed by PRAC (as relevant);
  • the PRAC assessment report on the evaluation performed and the conclusion of the PRAC that led to the adoption of the recommendation(s) based on all data gathered.
30. When is the PRAC recommendation published? Rev. March 2015

A brief outcome of the Pharmacovigilance Risk Assessment Committee (PRAC) recommendation will be included in the PRAC meeting highlights that are released on the next working day following the PRAC plenary meeting together with a summary of the PRAC recommendation and a press release, as applicable.

The PRAC recommendation including the PRAC assessment report and its annexes, in English only, will be published on the Agency’s website (on the specific procedure webpage) together with the final outcome of the Committee for Medicinal Products for Human Use (CHMP) or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) as applicable, on the week following the CHMP or CMDh plenary meetings during which the CHMP opinion or CMDh position/agreement was adopted.

31. Will I receive the PRAC recommendation? Rev. March 2015

The marketing authorisation holder(s) (MAHs) of product(s) concerned and identified at the start of the procedure will receive the Pharmacovigilance Risk Assessment Committee (PRAC) recommendation electronically via email/Eudralink during the week following the PRAC meeting when the recommendation was adopted.

The PRAC assessment report will be publicly available on the Agency’s website on the specific procedure webpage on the week following the Committee for Medicinal Products for Human Use (CHMP) or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) plenary meetings during which the CHMP opinion or CMDh position/ agreement was adopted (please see Article 107i procedures' webpage).

32. What happens after the PRAC recommendation?

The Pharmacovigilance Risk Assessment Committee (PRAC) recommendation on an urgent union procedure is sent during the week following its adoption to:

  • the Committee for Medicinal Products for Human Use (CHMP), if at least one centrally authorised product is included in the procedure, for adoption an opinion;
  • the Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh), if only nationally (including via mutual recognition and decentralised authorised products) are included in the procedure, to reach a position/agreement;

The CHMP or CMDh will consider the PRAC recommendation at their following plenary meeting and will agree on the timeframe needed to issue an opinion or position/agreement, respectively. This timeframe should not exceed 30 days after receipt of the PRAC recommendation (please refer to Question 33).

In parallel, if you are one of many concerned marketing authorisation holder (MAH) you may be contacted by the Agency with a proposal for worksharing of the translation process in all EU official languages (please refer to Question 39).

Committee for Medicinal Products for Human Use (CHMP) opinion or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) position/agreement

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33. When will the CHMP issue an opinion/CMDh reach a position/agreement? Rev. March 2015

Following the receipt of the Pharmacovigilance Risk Assessment Committee (PRAC) recommendation, the Committee for Medicinal Products for Human Use (CHMP) or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) will, consider the PRAC recommendation at their plenary meeting. As a general rule, the aim will be to adopt the CHMP opinion or CMDh position/agreement in the same month of the PRAC recommendation.

However in some cases, the CHMP or CMDh may agree on the need to further consider the PRAC recommendation. In such cases, the CHMP opinion or CMDh position/agreement will be adopted within a maximum of 30 days after receipt of the PRAC recommendation.

This decision will be reflected in the CHMP or CMDh meeting highlights published on the next working day following the plenary meetings.

The overall process including timelines for adoption of an opinion/position/agreement is the following:

34. What is the basis of the CHMP opinion /CMDh position/agreement? Rev. March 2015

The Committee for Medicinal Products for Human Use (CHMP) or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) will consider the Pharmacovigilance Risk Assessment Committee (PRAC) recommendation and assessment report and will adopt by consensus or by majority vote, an opinion or position/agreement respectively, on the maintenance, variation, suspension, revocation or non-renewal of the marketing authorisations (MAs) concerned (please refer to Question 28).

Exceptionally, an oral explanation may be held in front of the CHMP/CMDh should issues need to be addressed orally by the marketing authorisation holders (MAHs). The CHMP/CMDh decides whether the oral explanation will be held.

Where the CHMP opinion or CMDh position/agreement differs from the recommendation of the PRAC, the CHMP or CMDh shall attach to its opinion or position/agreement an explanation of the scientific grounds for the differences.

35. How is the CHMP opinion /CMDh position/agreement structured? Rev. March 2015

The Committee for Medicinal Products for Human Use (CHMP) opinion or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) position/agreement will include:

  • a cover page in which the CHMP opinion or CMDh position/agreement adopted is outlined together with the voting outcome;
  • the Pharmacovigilance Risk Assessment Committee (PRAC) recommendation and its assessment report;
  • the scientific grounds and explanation for the opinion or position/agreement including a detailed explanation for any differences with the PRAC recommendation;
  • the CHMP/CMDh members’ divergent views, in case of adoption by majority instead of consensus;
  • the products listing including name of the medicinal products concerned/active substances and marketing authorisation holders (MAHs) for all identified products approved nationally (including via the mutual recognition/decentralised procedures).In case centrally authorised products (CAPs) are involved their respective Annex A will be attached;
  • the wording (in English only) to be included in the relevant sections of the summary of product characteristics (SmPC) and/or the labelling and/or package leaflet (PL), if applicable (only for products approved nationally including via the mutual recognition/decentralised procedures);
  • the revised product information with agreed wording included in the relevant sections of the SmPC and/or the labelling and/or PL, if applicable (only for centrally authorised products);
  • the conditions or restrictions imposed on the marketing authorisation holders (MAHs or Member States (MSs) for the safe and effective use of the medicinal product, if applicable;
  • Direct Healthcare Professional Communication (DHPC) and communication plan as agreed by PRAC (as relevant).
36. When will the CHMP opinion or CMDh position/agreement be published? Rev. March 2015

A brief outcome of the Committee for Medicinal Products for Human Use (CHMP) opinion or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) position/agreement, as applicable, will be included in the meeting highlights that are released on the next working day following the plenary meetings together with an EMA public health communication and a press release.

The CHMP opinion or CMDh position/agreement with the final assessment conclusions and recommendations with all its annexes will be published on the Agency’s website (on the specific procedure webpage) the week following the plenary meetings during which the CHMP opinion or CMDh position/agreement was adopted.

37. Will I receive the CHMP opinion or CMDh position/agreement? NEW March 2015

The marketing authorisation holder(s) of products concerned and identified at the start of the procedure, will receive the Committee for Medicinal Products for Human Use (CHMP) opinion or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) position/agreement electronically via email/Eudralink during the week following the CHMP or CMDh plenary meetings during which the CHMP opinion or CMDh position/agreement was adopted.

38. When do I have to submit translations?

The marketing authorisation holders (MAHs) of products approved nationally (including via the mutual recognition or decentralised procedures) will have to provide translations in all EU languages (including Icelandic and Norwegian, if applicable1) of the following annexes to the Committee for Medicinal Products for Human Use (CHMP) opinion or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) position/agreement:

  • products listing of nationally approved products (including via mutual recognition/decentralised procedures) concerned by the procedure;
  • wording to be included in the relevant sections of the summary of product characteristics and/or the labelling and/or package leaflet, if applicable;

Only one translation per EU language is required, therefore the MAHs actively involved in the procedure will be presented with a proposal for worksharing for the translation process.

The Agency will contact the MAHs as early as possible to ensure the smooth running of the worksharing process. The translations will have to be provided to the Member States contact points for linguistic check by Day +5 (i.e. 5 days after adoption of the opinion or the position/agreement) and copied to the Agency.

The MAHs of centrally authorised products involved in the procedurewill have to provide the full product information in all EU languages within the same timeframe (i.e. 5 days after adoption of the opinion) to the MSs contact points for linguistic check and copied to the Agency.

For rurther detailed information on the translation process of the CHMP opinion or CMDh position/agreement, see practical information on translations for referral procedures (human).


1If authorised in Iceland and Norway.

39. What happens after the CHMP opinion or CMDh position/agreement? Rev. March 2015

In case of a Committee for Medicinal Products for Human Use (CHMP) opinion or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) position by majority vote, the Agency together with the concerned marketing authorisation holder(s) (MAHs) and national competent authorities (NCAs) in the Member States (MSs) will finalise the translations and send it to the European Commission (EC).

The EC will then start the decision-making process leading to the adoption of a binding decision addressed either to the MAHs or MSs, depending on whether the decision concerns centrally authorised products (CAPs) or nationally authorised products (including via the mutual recognition and decentralised procedures), respectively (please refer to Question 34).

In case of CMDh agreement (i.e. consensus between Member States), the Agency together with the concerned MAHs and the NCAs in the MSs will finalise the translations. The agreement will be implemented by the MSs in accordance with the timetable determined in the agreement.

For detailed information on the decision-making process, see decision making procedure for the adoption of commission decisions.

The MAHs of CAPs need to submit within 5 days following the EC decision, an eCTD closing sequence of the final documents.

40. Will there be any publication in relation to the urgent union procedure after the Commission Decision and after consensus by CMDh?

Following the European Commission (EC) decision on the Committee for Medicinal Products for Human Use (CHMP) opinion or Co-ordination Group for Mutual Recognition and Decentralised Procedures (CMDh) position, the Agency’s webpage of the specific procedure will be updated to reflect the date of the EC decision or the CMDh agreement, as applicable.