What Are the Latest Compliance Requirements for UK Pharmaceutical Companies Exporting Medicines?

April 22, 2024

Pharmaceutical companies are some of the most regulated entities in the world. The stringent rules they have to adhere to are designed to ensure the safety, efficacy, and quality of the medicines they produce. But for companies based in the UK and exporting to other countries, there are additional compliance requirements they need to be aware of. This article aims to provide you with the latest guidance on what these requirements are, with a particular focus on the rules from the European Medicines Verification Organisation (EMVO), and the Medicines and Healthcare products Regulatory Agency (MHRA) of Northern Ireland.

Understanding the Role of the EMVO in Medicine Verification

The EMVO is a key player in the European medicines verification system. It is a non-profit organisation, established to safeguard the legal supply of medicinal products across Europe. The EMVO is responsible for the European Hub, which connects the national systems and marketing authorisation holders.

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The EMVO has published specific guidance for companies producing medicinal products intended for export to the European market. This guidance stipulates that all prescription medicines must have a unique identifier and an anti-tampering device on the packaging. The unique identifier is a 2D data matrix code which contains product information, serial number, national reimbursement number, batch number and expiry date. These features must be verified at the point of dispensing.

In light of these requirements, it is imperative that UK pharmaceutical companies embrace these guidelines in their manufacturing and packaging processes. Failure to comply with the EMVO’s guidelines may lead to their products being considered non-compliant, which would prohibit them from being distributed within the European market.

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The MHRA’s Good Manufacturing Practice (GMP)

The MHRA is the governing body for medicines, medical devices and blood components for transfusion in the UK. One of the agency’s key responsibilities is to ensure that companies adhere to Good Manufacturing Practice (GMP). GMP is a system for ensuring that products are consistently produced and controlled according to quality standards. It is designed to minimise the risks involved in any pharmaceutical production that cannot be eliminated through testing the final product.

MHRA’s GMP covers all aspects of production, from the starting materials, premises and equipment to the training and personal hygiene of staff. Regular inspections are carried out to check that these guidelines are being followed. These inspections assess the systems and processes in place for the manufacture, control and release of medicines.

UK-based companies exporting pharmaceutical products must ensure they have a current and valid GMP certificate, and they must be prepared for routine inspections by the MHRA. Ensuring compliance with GMP is not just about meeting legal requirements – it also provides assurance to the public that the medicines they are taking are safe, effective and of high quality.

The Northern Ireland Protocol and Medicines Regulation

The Northern Ireland Protocol, agreed as part of the UK’s Brexit deal, has particular implications for pharmaceutical companies. Under the protocol, Northern Ireland follows the EU’s rules for medicines. This means that companies in Northern Ireland must adhere to the regulatory requirements of the EU, including being connected to the EMVO system.

However, in February 2024, the UK government published further guidance for companies in Great Britain (England, Scotland, and Wales) moving medicines to Northern Ireland. The guidance outlines the necessary procedures to ensure the continued supply of medicines in Northern Ireland. This includes requirements for batch testing and release, importation, and active pharmaceutical ingredient (API) standards.

For companies exporting medicines from the UK to Northern Ireland, ensuring compliance with these additional requirements will be paramount. It is a complex situation, but one that can be navigated with careful planning, robust systems and processes, and a thorough understanding of the regulatory landscape.

Export Certificates from the MHRA

For UK pharmaceutical companies wishing to export medicines outside of the UK, it is essential they obtain an export certificate from the MHRA. This certificate is a statement issued by the MHRA, confirming that the product meets the requirements of the UK and is authorised for sale within the UK.

The process for obtaining an export certificate involves a review of the product’s marketing authorisation, its GMP status, and a physical inspection of the manufacturing site. The MHRA provides a comprehensive guide on how to apply for an export certificate, and companies are advised to familiarise themselves with this guide to ensure they meet all the necessary requirements.

In conclusion, while the regulatory landscape for UK pharmaceutical companies exporting medicines can seem complex and challenging, a thorough understanding of these latest compliance requirements can help to navigate it successfully. Ensuring compliance not only meets legal obligations but also guarantees the safety, efficacy, and quality of exported medicines, which is of course, the ultimate goal of any pharmaceutical company.

Marketing Authorisation and the Role of the European Commission

In the realm of pharmaceutical compliance, the marketing authorisation of medicinal products is crucial. This is the green light that enables pharmaceutical companies to sell their products within the European market. The European Commission is the authority that grants this authorisation based on a positive assessment of the European Medicines Agency (EMA).

The process leading to marketing authorisation is rigorous and involves several stages. Firstly, a detailed dossier containing information about the medicinal product is submitted. This includes details on its composition, manufacturing and control methods, results of non-clinical tests and clinical trials, therapeutic effects, adverse reactions and its proposed use.

Once marketing authorisation is granted, it is valid in all EU Member States, as well as in the European Economic Area countries Iceland, Liechtenstein and Norway. For UK pharmaceutical companies, even though Great Britain has left the EU, Northern Ireland still operates under the EU’s rules for medicines due to the Northern Ireland Protocol. Therefore, they must ensure that their medicinal products have a valid marketing authorisation from the European Commission if they are to be exported to Northern Ireland.

It is crucial to note that the transition period following Brexit has ended, and all pharmaceutical companies based in the UK must now fully comply with these regulations. This includes the need to have a valid marketing authorisation for each medicinal product they wish to export to the European market.

The Supply Chain and Alert Management

The supply chain for medicinal products is a critical aspect of pharmaceutical compliance. All aspects of the supply chain, from manufacturing to distribution, must adhere to stringent regulations to ensure the safety, quality, and efficacy of the medicines.

One key element in the supply chain is alert management. This involves monitoring the supply chain for any potential issues, such as the detection of counterfeit medicines, product recalls, or problems with the quality of medicines. Pharmaceutical companies are required to have robust alert management systems in place and must act promptly when an alert is issued.

The European Union’s falsified medicines directive (FMD) has introduced new rules to improve the security of the manufacturing and delivery of medicines across Europe, including the use of safety features on the packaging of certain medicinal products. These safety features must be verified before the product is dispensed, adding an extra layer of security to the supply chain.

For UK pharmaceutical companies exporting medicines, understanding and implementing these requirements across their supply chain processes is vital. The goal is to ensure that every medicinal product that is manufactured, stored, transported, and ultimately reaches the patient, complies with all regulatory standards to guarantee its safety and effectiveness.

Conclusion

Navigating the current regulatory landscape for UK pharmaceutical companies exporting medicines is undoubtedly complex. The unique circumstances arising from Brexit, including the Northern Ireland Protocol, add further layers of complexity. However, by staying abreast of the latest compliance requirements, such as those stipulated by the EMVO and the MHRA, companies can ensure they remain compliant.

Key areas to focus on include obtaining marketing authorisation from the European Commission, ensuring Good Manufacturing Practice (GMP), meeting the standards for medicinal product packaging, and implementing robust alert management systems within the supply chain. Additionally, UK companies must understand the necessary procedures for the continued supply of medicines to Northern Ireland.

In the end, the ultimate goal is, and must always be, the safety, efficacy, and quality of the medicinal products. By meeting these compliance requirements, pharmaceutical companies do not just fulfil their legal obligations; they also contribute to the health and wellbeing of the public. These challenges may seem daunting, but they are surmountable with a clear understanding of the regulatory landscape and a firm commitment to meeting the highest standards of pharmaceutical production and distribution.