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Obligatory GMP certification of manufacturing site(s) responsible for bulk finished product and batch release manufacturing stages is required for any EAEU registration of finished drug product and bulk drug product, as well as for any national registration (Enrollment to the Russian State Register of Medicines) of any commercial API in Russia.
EAEU GMP certification is governed by the Resolution № 77 dd. Nov 03, 2016 of the Council of the Eurasian Economic Commission "On Adoption of the Rules of Good Manufacturing Practice of the Eurasian Economic Union".
EAEU GMP certificate by its format is "site activities"-wise. The duration of EAEU GMP certificate is 3 years starting the last date of the latest GMP inspection of corresponding site. Despite the format of the certificate, indicating the (inspected) site activities only, the format of the GMP application is product-and-activity sensitive. Within the obligatory forms that accompany EAEU GMP application, an applicant should provide details of exact product(s), their registration status and corresponding on-site activities per each product to be inspected.
Absence of EAEU GMP certificate (at least at the final review stage) of submitted registration dossier of a finished drug product or a commercial API results in automatic refusal for the registration of the corresponding product(s) by the Ministry of Health (MoH) of concerned EAEU member country.
Federal State Institution “State Institute of Drugs and Good Practices” ("FSI SID&GP") was officially empowered by the Ministry of Industry and Trade (MIT) of the Russian Federation as the only dedicated institution that performs EAEU GMP inspections and GMP certification expertise for all international manufacturers' GMP applications submitted in Russia.
MIT elaborates ultimate decision on issuance/refusal of EAEU GMP certificate after obtaining corresponding GMP inspection(s) report(s) that officially comes to MIT from FSI SID&GP for every GMP application.
EAEU member states apart Russia (Belarus, Kazakhstan, Kyrgyzstan and Armenia) have their own GMP certification authorities and GMP expertise institutions that provide GMP inspections and official GMP expertise in frames of current EAEU regulations.
FSI SID&GP practices comprehensive approach and well-established procedures for the GMP certification since 2016 being the only official institute in Russia that provides corresponding GMP-compliance expertise and GMP inspections as such. The institution also can coordinate EAEU GMP inspections performed by the authorities of other EAEU member states, the institute reviews any other member-states GMP inspection reports in case of EAEU MRP submission with Russian Federation as a recognition (not reference) member.
Some types of type II CMC variations (addition of new manufacturing site, any significant changes of QC testing methods, any significant changes in product's release specification, major changes in manufacturing process etc.) requires EAEU GMP certification for the affected site(s) in order to obtain official approval of such variation.
MIT regularly uploads publicly available list of issued EAEU GMP Certificates. The list of previously issued National Russian GMP Conclusions is also publicly available.
We provide all organizing and supporting activities for before, during and after Russian GMP inspection procedure:
Complete EAEU GMP certification procedure from the initial submission to MIT to the issuance of the certificate takes from 6 to 12 months, depending on the queue of applicants, complexity and coverage of the activities for particular site, as well as services plans and service features that we propose.
Due to managing EAEU GMP certification as integral part of our service for a finished product or API registration since 2016, as well as our time optimization of every single regulatory affairs process (thorough gap analysis of all initial documents and dossiers, parallel execution of processes, import and customs clearance of samples, preliminary QC testing of samples for compliance to product's Normative Document; use of biowaiver studies etc.), we minimize the overall timeline of the GMP certification procedure .
In all cases we provide EAEU GMP certification services that can be integrated to overall registration timeline "seamlessly", adding no extra time to planned product registration term.
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