EU Directive 2001/83/EC

Report
Presentation by
Dr. P. V. Appaji, M.Pharm, Ph.D
Director General,
PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA
Hyderabad
Email: [email protected]
CONTENTS
 Which are EU Countries?
 Objectives of EU Directive 2001/83/EC
 Definition of Falsified Medicinal Product
 Potential targets of EU Directive 2001/83/EC
 Current Indian Pharmaceutical Industry Status
 Advantages with EU Directive to India
 Disadvantages with EU Directive to India
 Possible Negotiations
Which Are EU Countries?
Objectives Of EU Directive 2001/83/EC
 Introduction of a New Term Falsified Medicinal Product
 Aims to prevent suspected medicines reaching patients
 Safety features to be harmonised within the Union
 Aims safety measures All through the supply chain
(manufacturer to end user)
Contd…
Objectives Of EU Directive 2001/83/EC
 Prevent distortions in the internal market
 Prevent falsified medicinal products entering the legal
supply chain
 Aims at Ensuring Good Manufacturing Process of EU/EU
Pharmacopoeia standards
 Aims at Pharmaceutical product quality for APIs,
Generics formulations, Excipients at the manufacturing
level
EU Defines Falsified Medicine As
Any medicinal product with a false representation of:
a. Its identity, inclusive of package and labeling, its name or its
composition as regards to any of the ingredients inclusive of
excipients and the strength of those ingredients;
b. Its source, its manufacture, its country of manufacturing, its
country of origin or its marketing authorisation holder;
c. Its history: The records and documents relating to the
distribution channels used
The definition Excludes unintentional quality defects and is without prejudice to
infringements of intellectual property rights
Potential Targets Of EU Directive 2001/83/EC
 Confirming GMP with audits (for APIs, formulations, Excipients)
 Confirming distribution with audits
 Confirming GMP practices at least equivalent to those laid down by
the Union
 Notification to the authority for any changes that may impact on
the quality or safety of the active substances that are
manufactured, imported or distributed
Contd…
Potential Targets Of EU Directive 2001/83/EC
 Implementation of anti-tampering devices
 Maintaining records in the form of purchase/sales at various levels
of supply chain
 Persons brokering medicinal products are also subject to
inspection by competent authorities
 Persons brokering must have permanent address, contact details
in the Union
Contd…
Potential Targets Of EU Directive 2001/83/EC
 Repeated inspections of Manufacturers (located in the Union
or in third countries) and wholesale distributors of medicinal
products
 Inspections of the premises of marketing authorisation holders
and of brokers of medicinal products are possible
 Data submitted to comply with monographs of European
Pharmacopoeia
Current Indian Pharmaceutical Industry Status
 India is a leading exporter of quality pharmaceutical products
globally
 Indian exporters comply with ISO, GMP/WHO GMP, ICH guidelines
etc.,
 Indian Drugs & Cosmetic Act terminology
- Spurious drugs
- Not of standard quality or substandard drugs
- Adulterated drugs
- Misbranded drugs
may fall under the purview with international acts
Directive 2001/83/EC as amended by Directive 2011/62/EU
EU rules for import of API’s.
 According to Articles 46b 2(b) i, ii & iii
 Written confirmation from the competent authority of the exporting third
country of the following:
 The standards of good manufacturing practice applicable to the plant
manufacturing the exported active substance are at least equivalent to those
laid down by the Union.
 The manufacturing plant concerned is subject to regular, strict and transparent
controls and to the effective enforcement of good manufacturing practice,
including repeated and unannounced inspections, so as to ensure a protection
of public health at least equivalent to that in the Union;
 In the event of findings relating to non-compliance, information on such findings
is supplied by the exporting third country to the Union without any delay.
Implementation Of The New Directive
 Concept paper submitted for public consultation.
 “Implementing act on the requirements for the
assessment of the regulatory framework applicable to
the manufacturing of Active Substances of Medicinal
products for Human Use”.
 Consultation closed on March 23 , 2012.
 Implementation date : July 2013
Written Confirmation & Equivalence Assessment (111b)
 Written confirmation waived for countries to be listed as per
Article 111b.
 Third country to request for “Equivalence assessment”
 Assessment to be done by the commission
 If assessment
confirms equivalence , third country will be
included in the list.
 Regular verification thereafter.
Equivalence Assessment
 A review of relevant documentation
 An on-site review of the third country's regulatory system,
unless a mutual recognition agreement ('MRA') is in place
that covers the manufacturing of active substances; and
 If necessary, an observed inspection of one or more of the
third country's manufacturing sites for active substances.
Country's Rules For GMP (111b(1)(a))
 Third countries rules for GMP implementation
 Pending the adoption of a delegated act on the principles and
guidelines of good manufacturing practice for Active
Substance
 EU rules to be taken into account are contained in Part II of
the good manufacturing practice guideline of the EU
(Eudralex Volume 4).
Regular Verification
 Article 111b(3)
 The Commission shall verify regularly whether the conditions of
the GMP equivalence are fulfilled
 The first verification shall take place no later than three years
after the country has been included in the list.
Minimum Expectations Of New Directive
The manufacture of active substances should be subject to good
manufacturing practice regardless of whether those active substances are
manufactured in the Union or imported.
With regard to the manufacture of active substances in third countries, it
should be ensured that the legislative provisions applicable to the
manufacturing of active substances intended for export to the Union, as
well as inspections of facilities and enforcement of the applicable
provisions, provide for a level of protection of public health equivalent to
that provided for by Union law.
Responsibility of Formulators in the new directive
A written confirmation that the manufacturer of the medicinal product has
verified, compliance of the manufacturer of the active substance with
principles and guidelines of good manufacturing practice by conducting
audits, in accordance with point (f) of Article 46.
The written confirmation shall contain a reference to the date of the audit
and a declaration that the outcome of the audit confirms that the
manufacturing complies with the principles and guidelines of good
manufacturing practice.
Global Bulk Drugs Imports Region Wise
Sr. no
Region
(Values In US$ Mn)
2008
2009
2010
YOY %
%share
14794.04
15649.54
16673.38
6.54
50.58
1
EU
2
North America
7379.52
4494.00
3866.23
-13.97
11.73
3
LAC
2180.33
3338.82
3611.87
8.18
10.96
4
Asia (Excluding Middle East)
2337.40
2445.33
2611.03
6.78
7.92
5
Other European Countries
1483.95
1045.19
1680.84
60.82
5.10
6
Asean
1211.84
1250.18
1255.68
0.44
3.81
7
South Asia
1069.94
1079.49
1082.13
0.24
3.28
8
Middle East
761.60
599.14
995.23
66.11
3.02
9
Africa
420.60
423.74
450.69
6.36
1.37
10
Oceania
392.32
368.32
378.67
2.81
1.15
11
CIS
261.88
385.31
355.17
-7.82
1.08
12
Other America
4.37
5.43
6.19
14.10
0.02
32297.79
31084.49
32967.11
6.06
World
Source : UN COMTRADE
PIC/S
Pharmaceutical Inspection Convention (PIC)
&
Pharmaceutical Inspection Co-operation
Scheme (PICS)
Brief note on PIC/S
• PICS Established in 1995.
• Current members – 40 Participating Authorities
• Partners
a) EDQM European Directorate for Quality of Medicines and
Health Care, France
b) EMA- European Medicines Agency
c) UNICEF
d) WHO
Requirements :
- Law on medicinal products.
- A GMP guide equivalent to PIC/S or EU GMP Guide.
- A GMP inspectorate fulfils PIC/S quality system requirements.
- Experienced GMP inspectors
Objective of PIC/S
• An active and constructive co-operation in the field of GMP.
• To facilitate networking between participating authorities and
to increase mutual trust, to exchange information and
experience, in the field of GMP and related areas, and mutual
training of GMP inspectors.
• Attain confidence of drug regulatory authority.
• Avoid duplication relating to
→ Inspections
→ Licensing procedures
→ Expenditure
→ One time procedure
Goals of PIC/S
• Mutual recognition of Inspections.
• Harmonisation of GMP requirements.
• Uniform inspection systems.
• Training of inspectors.
• Exchange of information.
• Mutual confidence.
Financial Costs
• PIC/S Constituted fee 8,100 CHF
•
•
•
•
PIC/S Committee meetings – 2 per annum
Seminars - 1 per year.
Expert Circle meetings 3- per annum
Events duration are 1 to 3 days in other PIC/S
countries.
• Registration fee 8100 CHF & In assessment
process, annual fee is 50% of Reg. fee for
expert.
Benefits
 PIC/S is not a trade agreement.
 Membership in PIC/S may facilitate the export of
pharmaceuticals.
 Non-PIC/S Countries (e.g. Colombia) may accept
accreditation of PIC/S participating Authorities.
 Consequently, the Pharmaceutical industry located in these
countries indirectly benefits PIC/S membership.

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