Exceptions and modifications to the EU guidance on good pharmacovigilance practices that apply to UK MAHs and the MHRA
This guidance clarifies the expectations on the application of the EU guidance on good pharmacovigilance practices (GVP)
Latest change: Exceptions and modifications document – updates (01 Jan 2025) -Overall updates were made to the document to reflect changes to UK legislation implementing new arrangements for medicines following the Windsor Framework and European Union Updates to GVP Module XVI and Addendum II - Updates throughout to indicate requirements for Category 1 and Category 2 products following the implementation of the Windsor Framework - Other specific updates include: Section I.C.1.4 – Additional information added for Category 1 products with an associated EU license to consider new information published on the European Medicines web portal and where necessary make changes to the UK authorisation via a variation Section I.C.2.1 – Additional information added to paragraph 4 regarding withdrawal options for NI as a CMS. Section II.B.2.2 - Information added to last sentence of paragraph 1 regarding the location of the Qualified person for Category 2 products. Section II.B.4.1 – Addition of Paragraph 3 Section II.B.4.6 – Addition of Paragraph 2 Sections II.B.4.7 – New section added Section II.B.4.8 – Addition of paragraph 3 and 7 Section III.A – Paragraph 4 no longer applies to UK authorised products GVP Module V (Summary) – sentence added to the end of the 1st paragraph which describes requirements for UK RMP and footnote to the UK specific RMP annex template Section VI.A – New paragraph added to describe reporting requirements to for Category 1 products Section VI.C.2.2.12 – Addition of paragraph 2, section subparagraph 3 Section VI.C.4 Reporting to EudraVigilance – Information added in relation to Category 1 products and category 2 products Section VI.App.2.10 -Updated contact details to vigilanceservice@mhra.gov.uk Section VII.A Note added under Paragraph 9 regarding the legal basis of application of a UK authorised product Section VII.C.6.1 - Additional information added for Category 1 products with an associated EU license to consider new information published on the European Medicines web portal and where necessary make changes to the UK authorisation via a variation. Section VIII.A – Paragraph 4 added Section VIII.A – Paragraph 11 and Paragraph 12 added Section VIII.B.1 – Additions of Paragraph 1, 2, 5 and 6. Section VIII.B.3 – Paragraph 4 added Section VIII.B.5.1 – New section added Section VIII.B.6 – Paragraph 2 added Section VIII.B.7 – Paragraph 1 and 2 added Section IX.C.1.2 - Additional information added for Category 1 products with an associated EU license to consider new information published on the European Medicines web portal and where necessary make changes to the UK authorisation via a variation. Section IX.C.4.3 – New information added to end of section to state that newly triggered procedures on the PRAC agenda do not need to be notified to the licensing authority Section XV.C.2.1 - removal of paragraph referring to centrally authorised products Section XV.B.5.1 - Updated contact details to vigilanceservice@mhra.gov.uk GVP Module XVI : Risk Minimisation measures – extensive updates to reflect updates to GVP Module XVI GVP Module XVI Addendum II – Extensive updates to reflect updates to GVP Module XVI Addendum II. GVP Annex I – Definitions. – Amendment to definition of ATMP. Additional definitions – concomitant medication, primary endpoint, reference safety information in the context of clinical trials and UK marketing authorisation added.
AI Summary
The UK Medicines and Healthcare products Regulatory Agency (MHRA) has issued guidance regarding Good Pharmacovigilance Practices (GVP) following the UK's departure from the European Union. GVP represents a critical set of measures designed to ensure the safety monitoring and performance of medicines. While these standards traditionally apply to Marketing Authorisation Holders (MAHs) and regulatory bodies like the European Medicines Agency (EMA), the evolving regulatory landscape necessitates specific adjustments for operations within the United Kingdom. The guidance clarifies that GVP standards cover both centrally and nationally authorized medicinal products. However, with the UK's regulatory autonomy, certain aspects of the EU framework are no longer applicable to the MHRA or UK-based MAHs. In other instances, existing EU guidelines must be interpreted with specific modifications to align with UK law. The primary regulatory framework is the established GVP system, now adapted for the UK context. While no specific company violations or inspection dates are cited in this general guidance, the document serves as a compliance roadmap. MAHs are required to review their pharmacovigilance systems to ensure they comply with the MHRA’s specific interpretations. This includes distinguishing between EU-wide requirements and those specifically tailored for the UK market to maintain the safety and integrity of medicinal products.
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