Annual Product Review in Pharma
Contrasting EU and FDA Requirements


In the pharmaceutical industry, adhering to Good Manufacturing Practices (GMP) regulations is paramount. These regulations necessitate the generation and analysis of a substantial volume of data encompassing all facets of pharmaceutical operations. The Annual Product Review (APR) process serves as a critical component in maintaining product quality and regulatory compliance. This article explores the distinctions between the European Union (EU) and the United States Food and Drug Administration (FDA) requirements for APR, highlighting key differences that pharmaceutical companies must be aware of.

The Purpose of Annual Assessments: The overarching goal of annual assessments is to ensure that pharmaceutical products and associated processes remain under control, pinpoint areas necessitating change, and identify opportunities for continuous improvement. While some companies may perform these reviews solely to meet regulatory obligations, the potential for continuous enhancement should not be overlooked.

Regulatory Framework:

FDA Requirement: In accordance with 21 CFR 211.18(e), FDA GMP regulations. regulations mandate that pharmaceutical companies perform an annual review of data associated with each product.

EU Requirement: The European requirement, referred to as the Product Quality Review (PQR), is detailed in Chapter 1 of Volume 4 of the EU GMP guidelines and Chapter 1 of the PIC/S PE-009-11 GMP Guide. Similar to the FDA requirement, the EU mandates an annual review of specified data elements. However, there are noteworthy distinctions between the two regulatory bodies.

Key Differences:

a. Assessment of Corrective and Preventive Actions: 

EU: Regulations explicitly demand an assessment of the review's results to determine the need for corrective or preventive actions, as well as revalidation if necessary.

FDA: While not explicit, FDA likely expects firms to perform similar analyses, but it is not a requirement specified in the regulations.

b. Incorporation of Previous Review Data

EU: Regulations require the assessment of current data against data from previous review periods to identify adverse trends.

FDA: Unlike the EU, FDA does not mandate firms to consider data from previous review periods. However, it may be necessary depending on the number of batches manufactured.

c. Grouping of Products:

EU: Regulations permit the grouping of products by type (e.g., solid dosage forms, liquid dosage forms, sterile products) when scientifically justified.

FDA: Regulations require individual APRs for each product and do not allow grouping.

d. Written Procedure Requirement:

EU: Regulations do not specify a requirement for a written procedure outlining the PQR process.

FDA: Explicitly requires firms to adopt a written procedure for the APR process. Developing a written operating procedure is advisable to ensure compliance with regulatory expectations.

d. Additional Data Elements in EU PQR:

 In contrast to FDA regulations, EU GMP guidelines include several additional data elements that must be incorporated into the PQR, such as starting materials, including packaging materials used in the product, with an emphasis on those from new sources. It is crucial for pharmaceutical companies to be aware of these differences to maintain compliance with the respective regulations.

The Annual Product Review process is an essential aspect of pharmaceutical quality assurance, ensuring that products remain in control, and driving opportunities for improvement. Understanding the disparities between EU and FDA requirements is vital for pharmaceutical companies operating on a global scale, enabling them to navigate these regulatory landscapes effectively and meet their obligations while striving for continuous enhancement in product quality and process efficiency

1. European Commission, "Medicinal Products for Human and Veterinary Use," in -- EU Guidelines for  GMP,  Chapters 1
2. European Commission, Final Version of Annex 15 to the EU Guide to Good Manufacturing Practice,  "Qualification and Validation," 


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Annual Product Review in Pharma
Safaa Abdel Wahab
8 October, 2023
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