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Published byΑνδρομέδη Γούναρης Modified over 6 years ago
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Handling the “stop of the clock” in product authorisation
Background: Agreed actions list in Sept to minimise delays in PA: “6. ECHA/COM: monitor delays, particularly in refMSs” Detailed reports by ECHA at CG-21 (January 2017): significant delays before the refMS releases the PAR for MR Several reasons, but most important are: - Content of the dossier and Handling of the “stop of the clock” provision: Requirement of additional information, Delays by applicants when submitting that information, Time needed to assess the submitted information, In some cases, the above-mentioned "process" is repeated several times until an acceptable outcome is found.
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Handling the “stop of the clock” in product authorisation
Background: Need to take action, in order to: - Identify any technical or regulatory issues arising from the assessment of the applications by different evaluating bodies at the same time 4. refMSs: early identify any emerging issue and to refer it to the relevant EU fora 5. ECHA/MSs: ensure assistance in WGs to product authorisation issues - Make the product authorisation process more efficient and allow all MSs (or COM) to deliver the product authorisations within the three-year period referred to in Article 89(3) of the BPR.
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Handling the “stop of the clock” in product authorisation:
MRP Existing products under the transitional rules (Article 89(2) – 3 years) Application for PA Products authorised under the BPR “confort zone” Validation up to 5 months ( days) MR + NA up to 9 months MR: 90 d CG: 60 d COM dec: +/-90 d NA: 30 d Evaluation by refMS (365 + up to 180 days)
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Handling the “stop of the clock” in product authorisation:
UA Existing products under the transitional rules (Article 89(2) – 3 years) Application for PA Products authorised under the BPR “confort zone” Validation up to 5 months ( days) Peer review BPC (270 days) Evaluation by refMS (365 + up to 180 days) UA by COM (120 d left!)
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Handling the “stop of the clock” in product authorisation:
MR-P or UA Existing products under the transitional rules (Article 89(2) – 3 years) Validation up to 5 months ( days) Application for PA Evaluation (365 + > 180 days)
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Handling the “stop of the clock” in product authorisation:
MR-P or UA Existing products under the transitional rules (Article 89(2) – 3 years) Validation up to 5 months ( days) MR + NA or UA Products authorised under the BPR “concern zone” Application for PA Evaluation (365 + > 180 days)
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Handling the “stop of the clock” in product authorisation:
MR-P or UA Existing products under the transitional rules (Article 89(2) – 3 years) Evaluation + “stop(s) of the clock” MR + NA or peer review + UA E- body 1 E- body 2 E- body 3 E- body 4 E- body 5 Identification of technical or regulatory issues
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Handling the “stop of the clock” in product authorisation:
MR-P or UA Existing products under the transitional rules (Article 89(2) – 3 years) Evaluation + “stop of the clock” MR + NA or peer review + UA Products authorised under the BPR “confort zone” E- body 1 E- body 2 E- body 3 Consistency between e-CAs Harmonised approach for all products Less MR disagreements E- body 4 E- body 5 Send “list of all questions” to the applicants Identification of technical or regulatory issues for CG/WGs in time
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