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CTD Conversion

In June 2010, The Medicines Control Council (MCC) announced the intention to implement the South African Common Technical Document (ZA CTD) format which will replace the current MRF1 and any applications still in MBR1 format.

From June 2011, submissions in ZA CTD format are mandatory (excluding veterinary medicines).

Freyr is currently working with many Global Pharmaceutical and Consumer Health Care companies in supporting them in planning and executing the CTD conversion requirement for the existing and new product registrations in South Africa enabling them to meet the MCC mandate.  For some of these global companies CTD conversion is a time consuming and a huge responsibility that needs careful planning and execution given their growing product portfolio in the African market.

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Good Manufacturing Practice

Good Manufacturing Practice is that part of Quality Assurance which ensures that products are consistently produced and controlled to the quality standards.

  • Regular periodic or rolling quality reviews of all registered medicinal products, including export only products are conducted.
  • The Manufacturer and Holder of Certificate of Registration, where different, should evaluate the results of the review and an assessment should be made of whether corrective and preventative action or any revalidation should be undertaken.

Medicines Control Council’s (MCC)  general policy is that the standard to be used to assess compliance with current Good Manufacturing Practice (cGMP), is the South African Guide to Good Manufacturing Practice (SA guide to GMP).

  • Under Section 22C of the Act, all South African manufacturers should be licensed
  • The Act requires that overseas manufacturers of medicine supplied to South Africa should comply with the same or equivalent manufacturing standards as expected of South African manufacturers
  • When acceptable evidence of GMP compliance is not available, overseas manufacturers are inspected by the GMP Inspectorate before registration of the medicine is approved

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Medicines Registration

Medicines to be used in South Africa for both public and private sectors shall be duly registered with the national regulatory authority, the Medicines Control Council’s (MCC) in accordance with the provisions and requirements of the Medicines and Related Substances Control Act No. 101 of 1965 and the Regulations and Guidelines published in terms thereof.

A written notification from the Minister to the effect that the medicine is considered essential to national health; an expert report (which is not more than 2 (two) years old; a package insert (where the product has been approved) and a summary basis for the registration (SBRA) should be submitted with application.

The Registrar shall notify the applicant within 30 days of the date of receipt of the application and the Council shall, within 9 months make a decision with regard to the application.

The abbreviated medicine review process is based mainly on the expert reports of the pharmaco toxicological and clinical data.

Applications for Abbreviated Medicine Review Process (AMRP) can only be accepted if the product has been approved by the said authorities within the last three years of the license in the licensing country.

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Submissions Publishing

In June 2010, The Medicines Control Council (MCC) announced the intention to implement the South African common technical document (ZA CTD) format which will replace the current MRF1 and any applications still in MBR1 format.  From June 2011, submissions in ZA CTD format are mandatory (excluding veterinary medicines).

With the need for converting old format submissions to CTD format comes the opportunity for Market Authorization Holders (MAH) to plan and be ready for electronic submissions.  Freyr can compile submissions in eCTD format and print in paper format as required by the current MCC requirement. This allows the MAHs to be prepared for future eCTD requirements from MCC and enables efficient electronic submission dossier management.

Registrations and Submissions Information Management

Module 1 (Administrative 1.10 Foreign Regulatory Status) requirement from Medicines Control Council’s (MCC) requires the applicant to provide a list of countries in which an application for the same product is being applied for in South Africa has been submitted, dates of submission (if available). This should detail approvals (with indications).  Applicants must declare whether a marketing application for the medicine has been rejected in the countries listed under 1.10.1 prior to submission of the application in South Africa. If the medicine has been rejected, repeatedly deferred or withdrawn, then the MCC must be informed and the reasons supplied.

If no application has been submitted for registration in the country of origin, include a statement to provide the reason for this decision. It should be noted that aforementioned information is required to be provided in dossier however, it does not mean that this will help to speed up the review process.

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Health Authority Updates

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  2. Health Authority Updates
  • South Korea Approves the First Physically Recycled PET Containers for Food and Beverages

    August 09, 2023
    Food and Food Supplements
    Regulatory Affairs
    Health Authority Updates
    South Korea Approves the First Physically Recycled PET Containers for Food and Beverages

    South Korea has taken a step towards carbon neutrality and has approved the first ever physically recycled Polyethylene Terephthalate (PET) containers for food and beverages.

    The new policy, applicable from January 17, 2023, only includes PET containers that have undergone a physical or mechanical recycling process and have not been subject to a chemical recycling process. As per the Promotion of Saving and Recycling of Resources Act (Recycling Act), the South Korean Ministry of Environment (MoE) has graded the packing material into the following four (04) categories:

    • Read more about South Korea Approves the First Physically Recycled PET Containers for Food and Beverages
  • Failure to Respond to an ANDA CRL – What Does the FDA Guidance Say?

    January 06, 2023
    Generics
    Publishing & Submissions
    Health Authority Updates
    Failure to Respond to an ANDA CRL – What Does the FDA Guidance Say?

    The United States Food and Drug Administration (US FDA) released guidance in December 2022, a revision of the guidance titled ‘Failure to Response to an ANDA Complete Response Letter (CRL) Within the Regulatory Timeframe Guidance for Industry,’ of July 2022. It is meant to guide the applicants of Abbreviated New Drug Applications (ANDAs) submitted under section 505(j) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) (21 U.S.C. 355(j)). A complete and relevant response to a CRL is crucial for the approval of the generic drug.

    • Read more about Failure to Respond to an ANDA CRL – What Does the FDA Guidance Say?
  • NMPA Acknowledges E-certificates as Equivalents of Conventional Paper Certificates

    January 03, 2023
    Pharmaceuticals
    Health Authority Updates
    NMPA Acknowledges E-certificates as Equivalents of Conventional Paper Certificates

    China’s pharmaceutical sector is witnessing changes and advancements frequently. In a recent shift, the National Medicinal Products Authority (NMPA) has made electronic certificates for drug registration in China possible. This has been done as an initiative to deepen the reform of the pharmaceutical market and drug supervision. The declaration was given by the NMPA under announcement no. 83-2022, and China has started issuing these e-certificates from November 01, 2022.

    • Read more about NMPA Acknowledges E-certificates as Equivalents of Conventional Paper Certificates
  • US FDA Releases Labeling Draft Guidance on Dose Banding

    November 29, 2022
    Regulatory Labeling
    Health Authority Updates
    US FDA Releases Labeling Draft Guidance on Dose Banding

    In July 2022, the United States Food and Drug Administration (US FDA) issued draft guidance titled ‘Human Prescription Drug and Biological Products - Labeling for Dosing Based on Weight or Body Surface Area for Ready-to-Use Containers - “Dose Banding.” It is to help sponsors include dose banding information in drug labeling for ready-to-use containers in New Drug Applications (NDAs), Biologics License Applications (BLAs), or supplements to those applications.

    • Read more about US FDA Releases Labeling Draft Guidance on Dose Banding
  • US FDA Releases Draft Guidance on Content and Format of Labeling for Non-prescription Drugs

    November 29, 2022
    Regulatory Labeling
    Health Authority Updates
    US FDA Releases Draft Guidance on Content and Format of Labeling for Non-prescription Drugs

    In September 2022, the United States Food and Drug Administration (US FDA) released a draft guidance document titled “Statement of Identity and Strength - Content and Format of Labeling for Human Non-prescription Drug Products.” The draft guidance aims to enhance the consistency of labeling for Over-the-Counter (OTC) drugs. It addresses the statement of identity and drug strength for OTC products.

    • Read more about US FDA Releases Draft Guidance on Content and Format of Labeling for Non-prescription Drugs
  • DMA Revises 2022 Submission Deadline for MA and Clinical Trial Applications

    November 09, 2022
    Pharmaceuticals
    Regulatory Affairs
    Health Authority Updates
    DMA Revises 2022 Submission Deadline for MA and Clinical Trial Applications

    As per the recent update from the Danish Medicines Agency (DMA) dated October 19, 2022, the deadline for submitting marketing authorization and clinical trial applications has been revised to December 20, 2022. The move comes as the DMA will be closed from December 24 to January 01, 2023, for the Holiday Season.

    • Read more about DMA Revises 2022 Submission Deadline for MA and Clinical Trial Applications
  • NMPA Contemplates Implementing By laws for Drug Administration Law

    September 26, 2022
    Biologicals
    Generics
    Pharmaceuticals
    Health Authority Updates
    NMPA Contemplates Implementing Bylaws for Drug Administration Law

    The National Medical Products Administration (NMPA) of China recently released a comprehensive draft amendment for implementing the China Drug Administration Law (DAL). 

    The draft amendment introduces significant changes to the Regulatory framework. It encodes the various Regulatory initiatives undertaken by the Chinese government since the implementation of the current China DAL, which was promulgated in 2019. The Law was intended for data protection and patent linkage.  

    • Read more about NMPA Contemplates Implementing By laws for Drug Administration Law
  • Nitrosamine Impurity Confirmatory Testing by MAHs

    September 22, 2022
    Pharmaceuticals
    Health Authority Updates
    Nitrosamine Impurity Confirmatory Testing by MAHs

    According to the CMDh practical guidance for Marketing Authorization Holders (MAHs) of nationally authorized products, the evaluation of nitrosamine impurity or cross-contamination in a marketed product is a critical criterion. Nitrosamines are proven to be carcinogenic and can affect the overall output of the formulated product.

    Considering the severity, the Co-ordination group for Mutual recognition and Decentralised procedures – human (CMDh) issued the following first three (03) steps a manufacturer must follow to mitigate the amount of impurity in the final drug product.

    • Read more about Nitrosamine Impurity Confirmatory Testing by MAHs
  • Promotional Material – FDA’s Electronic and Non-electronic Format Submission Guidance

    May 20, 2022
    Publishing & Submissions
    Health Authority Updates
    Promotional Material – FDA’s Electronic and Non-electronic Format Submission Guidance

    Pharmaceutical advertising, including direct-to-consumer advertising, is regulated by the United States Food and Drug Administration’s (US FDA) Office of Prescription Drug Promotion (OPDP), Advertising and Promotional Labeling Branch (APLB) at the Center for Drug Evaluation and Research (CDER), and the Center for Biologics Evaluation and Research (CBER) respectively. The information submitted to the OPDP and the APLB must be accurate, ethical, and non-misleading. Additional information about the product’s benefits and risks must be included in the submission.

    • Read more about Promotional Material – FDA’s Electronic and Non-electronic Format Submission Guidance
  • PAAB Complements the Standard
    Pre-clearance Pathway with Accelerated Review Options (AROs)

    April 04, 2022
    Medical and Scientific Communication
    Pharmaceuticals
    Publishing & Submissions
    Health Authority Updates
    PAAB Complements the Standard Pre-clearance Pathway with Accelerated Review Options (AROs)

    The ever-increasing demand for various channels to share information and engage with customers poses numerous challenges in the pharmaceutical industry. Such engagement comes with risks, particularly in the advertising domain. To ensure accurate and good practice, Health Canada regulates the advertising or promotional material before its dissemination in Canada. The Pharmaceutical Advertising Advisory Board (PAAB) is an organization whose advertising pre-clearance service for healthcare professionals is recognized by Health Canada.

    • Read more about PAAB Complements the Standard Pre-clearance Pathway with Accelerated Review Options (AROs)

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Publishing and Submissions
Regulatory Labeling

Creating compliant packaging for a cosmetic product is a collaborative effort of various departments in an organization such as: Labeling, Artwork and Regulatory Affairs. While label artwork must be validated by an artwork labeling team, it must combinedly be reviewed and approved by Regulatory Affairs team to ensure the compliance.

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Artwork services for the current Consumer Healthcare/Food Supplements landscapes are divided as per the markets. For Compliance based markets, artworks are created by Freyr team and submitted to the client for finalizing the artwork/ label.

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The current medical device landscape has turned challenging for manufacturers in terms of ensuring quality and audit compliance due to ever-evolving regulations which may lead to extended time for approvals and market access.

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