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A Guide for
Australian Manufacturers and Exporters of
Medicinal Products
The MRA became operative on 1 January 1999 and covers various other industry sectors
including medical devices, machinery, pressure equipment, low voltage equipment,
telecommunication terminal equipment, electromagnetic compatibility and automotive parts.
In recognition that different legislative and regulatory requirements apply between MRA
partners, the MRA does not create a direct equivalence between Australia and EU regulations.
Rather, it allows for mutual recognition of test results and other conformity assessment
documentation including certification.
The Medicinal Products Annex covers all those medicinal products for human and veterinary use
that are manufactured in Australia and EU, and to which GMP requirements apply, including
chemical and biological pharmaceuticals, immunologicals, radiopharmaceuticals, and products
derived from human blood/plasma. The MRA has the provision to be applied to medicinal
products covered by the legislation of one party but not the other, eg. vitamin and herbal
products, active pharmaceutical ingredients, manufacture of products for clinical trials, and pre-
marketing inspections.
It is important to note that the MRA only applies to GMP inspections of manufacturers of
medicinal products, and subsequent certification of the manufacturer. It does not apply to the
mutual recognition of marketing authorisation of medicinal products. Australian manufacturers
and/or sponsors wishing to market medicinal products in Europe will still need to lodge an
application for product marketing authorisation with an individual EU member country (“de-
centralised” procedure) or EMEA (“centralised” procedure).
For further information on the procedures for lodging applications for product marketing
authorisation, refer to “The rules governing medicinal products in the European Union”,
particularly Volumes 2A and 2B on “Notice to applicants – Medicinal products for human use”
(this publication can be obtained from the Office for Official Publications of the European
Communities, L-2985 Luxembourg).
Certification of Manufacturer:
The main thrust of the Medicinal Products Annex is the recognition of GMP inspections
conducted by the other party. This is facilitated by the exchange of a "Certificate of GMP
Compliance of a Manufacturer" certifying that the manufacturer has been inspected and found to
comply with GMP for the manufacture of a specific medicinal product or group of medicinal
products.
The Therapeutic Goods Administration (TGA) is nominated in the MRA as the Official
Inspection Service for Australia. Any request for a "Certificate of Compliance of a
Manufacturer" pertaining to an Australian manufacturer of a medicinal product for human use
should be made to: The Chief GMP Auditor, TGA, PO Box 100, Woden, ACT, 2606. The TGA
fee relevant to GMP certification will apply for requests received from importers and exporters;
the fee will not apply when the request comes from a European competent authority.
Batch Certification:
EU legislation requires that each batch of medicinal product imported into Europe must be
accompanied by a batch certificate. This certificate must:
• show agreed testing specification of the product
• show reference of analytical methods and test results
• contain a statement like “batch records reviewed and found to be in conformity with GMP”
• be signed by the person in the company responsible for releasing the batch of medicinal
product for sale/supply.
The batch certificate must be held by the European importer and be available upon request by the
relevant authority in Europe. The need for a batch certificate is a specific requirement of Europe;
there is no similar Australian requirement.
An internationally harmonised batch certificate has been developed for use by all MRA partners.
The current version of this certificate is attached at Annex B.
Veterinary Medicines:
A two-year transition period was applicable initially to Australian-made veterinary medicines
exported to Europe. Following an assessment by EC of Australia’s system of regulatory
controls for veterinary medicines the transition period was removed on 1 July 2001. That is,
the MRA became fully operational for veterinary products on 1 July 2001.
Whilst TGA is nominated in the MRA as the Official Inspection Service for all medicinal
products, including veterinary medicines, any request for a Certificate of Manufacturer relating to
an Australian veterinary manufacturer should be made to: GMP Licensing Scheme Manager,
National Registration Authority (NRA), PO Box E240, Parkes, ACT 2600.
Country of Origin:
The MRA applies to goods undergoing the final significant manufacturing step in Australia, and
vice versa. That is, the MRA cannot be applied to manufacturers located outside EU or Australia.
It is possible that the country of origin provision may be removed from the MRA sometime in
the future in order to make it consistent with the MRA’s that Europe has arranged with USA and
Canada.
Further Information:
A copy of the MRA, including the Medicinal Products Annex, can be obtained from the web site:
http://www.ecdel.org.au Further information on the Medicinal Products Annex can be obtained
from Mr Bob Tribe of TGA (Ph. (02) 62328629 Fax (02) 62328426) in relation to medicines for
use in humans, and from Mr Graham Savage of NRA (Ph. (02) 62723418 Fax (02) 62724753 )
in relation to veterinary medicines.
has been authorised, in accordance to the [Agricultural and Veterinary Chemicals Codes; the Therapeutic
Goods Act 1989; Directive 75/319/EEC, Article 16, and/or Directive 81/851/EEC, Article 24, or Directive
92/25/EEC article 3, transposed in the following national legislation: .
.........................................................................................................(*).]
1.........................................................................................................
2.........................................................................................................
of the following medicinal product or group of products for human use / use in animals(*):
....................................................................................................................................................................
....................................................................................................................................................................
This certificate remains valid for 3 years from the date of last inspection.
…../...…/.....… (date) Name and signature of the authorised person of the Competent
Authority of (country)
…………………………………………….
(name)
(title)
(Competent Authority)
(phone & fax numbers)
Sterile products:
Liquid dosage forms (Large Volume Parenterals)
- aseptically prepared
- terminally sterilized
Liquid dosage forms (Small Volume Parenterals)
- aseptically prepared
- terminally sterilized
- eye drops
Semi-solid dosage forms
Solid dosage forms - solid fill
- freeze-dried
Non-sterile products:
Liquid dosage forms
Semi-solid dosage forms
Solid dosage forms
- unit dose form (tablets, capsules,
suppositories, pessaries)
- multi dose form (powders, granules)
Biological products:
Vaccines
Sera
Blood products
Allergens
Other (describe: e.g. hormones, enzymes of human or animal origin,
genetically engineered products)
Packaging only:
Liquid dosage form
Semi-solid dosage form
Solid dosage form
αα/001β/yyyy
For example, certificate number AT/001H/2000 would be the 1st certificate issued in 2000 by Austria
for a medicinal product for human use.
Country Codes:
AU = Australia
AT = Austria
BE = Belgium
DK = Denmark
FI = Finland
FR = France
DE = Germany
GR = Greece
IE = Ireland
IT = Italy
LU = Luxembourg
NL = Netherlands
PT = Portugal
ES = Spain
SE = Sweden
UK = United Kingdom
Explanatory Note
In the framework of Mutual Recognition Agreements, the Sectoral Annex on Good Manufacturing
Practices (GMP) requires a batch certification scheme for drug/medicinal products covered by the
pharmaceutical Annex. The internationally harmonised requirements for the content of the batch certificate
of a drug/medicinal product is attached. The importer of the batch is to receive and maintain the batch
certificate issued by the fabricator/manufacturer. Upon request, it has to be readily available to the staff
of the Regulatory Authority of the importing country. This certification by the manufacturer on the
conformity of each batch is essential to exempt the importer from re-control (re-analysis).
Each batch transferred between countries having an MRA in force, must be accompanied by a batch
certificate issued by the fabricator/manufacturer in the exporting country. This certificate will be issued
further to a full qualitative and quantitative analysis of all active and other relevant constituents to ensure
that the quality of the products complies with the requirements of the Marketing Authorisation of the
importing country. This certificate will attest that the batch meets the specifications and has been
manufactured in accordance with the Marketing Authorisation of the importing country, detailing the
specifications of the product, the analytical methods referenced, the analytical results obtained, and
containing a statement that the batch processing and packaging quality control records were reviewed and
found in conformity with GMP. The batch certificate will be signed by the person responsible for releasing
the batch for sale or supply/export at the fabrication/manufacturing site.
These harmonised requirements have been agreed by the Regulatory Authorities of the following
parties/countries: Australia, Canada, European Community, New Zealand and Switzerland.
1. Name of product.
2. Importing Country.
The marketing authorisation number of the product in the importing country should be
provided.
4. Strength/Potency.
Identity (name) and amount per unit dose required for all active ingredients/constituents.
6. Package size (contents of container) and type (e.g. vials, bottles, blisters).
7. Lot/batch number.
8. Date of fabrication/manufacture.
9. Expiry date.
All sites involved in the manufacture including packaging and quality control of the batch
should be listed with name and address. The name and address must correspond to the
information provided on the Manufacturing Authorisation/Establishment Licence.
Number should be given for each site listed under item 10.
Should include the authorized specifications, all results obtained and refer to the methods
used (may refer to a separate certificate of analysis which must be dated, signed and
attached).
13. Comments/remarks.
Any additional information that can be of value to the importer and/or inspector verifying the
compliance of the batch certificate (e.g. specific storage or transportation conditions).
This statement should cover the fabrication/manufacturing, including packaging and quality
control. The following text should be used: ”I hereby certify that the above information is
authentic and accurate. This batch of product has been fabricated/manufactured, including
packaging and quality control at the above mentioned site(s) in full compliance with the
GMP requirements of the local Regulatory Authority and with the specifications in the
Marketing Authorisation of the importing country. The batch processing, packaging and
analysis records were reviewed and found to be in compliance with GMP”.
Including its company/site name and address, if more than one company is mentioned under
item 10.