Your batch is ready. All that is missing is the signature that counts.
Without release by a Qualified Person under § 14 AMG, no batch of a medicinal product may be placed on the market. If this function is not available in-house, the medicinal product cannot be released. A&O Pharma provides you with a named Qualified Person (QP) holding its own manufacturing authorisation (§ 13 AMG), who reviews your batch documentation and personally releases it by certification. If your company does not hold a manufacturing authorisation, we can also carry out the batch release under A&O Pharma's manufacturing authorisation.
Non-binding and confidential. Answer in one to two working days.
CTR 536/2014 & Annex 16
Clinical trial and commercial
Own GMP laboratory
§ 13 AMG authorisation, Itzehoe site
§ 15 AMG expertise
Named Qualified Person
A finished batch that cannot be released for the market costs a great deal of money every day.
The question that matters
Are you even permitted to outsource QP release?
Yes. You can transfer batch certification to another company, clearly regulated by contract through a Service Agreement, supplemented by a Quality Technical Agreement (QTA) setting out the allocation of responsibilities. Overall responsibility for the medicinal product remains with the marketing authorisation holder (MAH) or the sponsor of the clinical trial. This is precisely what makes outsourcing attractive for companies without their own manufacturing authorisation: you get the release without having to maintain the § 13 AMG authorisation and the Qualified Person yourself.
Under Annex 16 of the EU GMP Guide, the Qualified Person (QP) confirms by certification that a batch complies with the requirements of Good Manufacturing Practice and with the marketing authorisation (or clinical trial authorisation). The QP ensures the batch was manufactured and tested in accordance with the applicable legislation and the dossiers approved by the authorities. Without this release, no batch of a medicinal product may be placed on the market or used in a clinical trial.
A&O Pharma holds its own manufacturing authorisation under § 13 AMG, under which batch releases can be carried out in accordance with CTR 536/2014 and Annex 16 or AMWHV § 16. The release can be carried out either under your own manufacturing authorisation or under ours, whichever you prefer.
What we take on for you
All responsibilities and activities associated with batch release:
QP release of investigational and comparator medicinal products for phase 1 to 3 trials under CTR 536/2014, flexible in terms of timing, workload and number of batches.
EU batch release of authorised, commercial medicinal products under Annex 16 of the EU GMP Guide or AMWHV § 16.
Oversight of GMP-compliant manufacturing and testing throughout the entire manufacturing process, including GDP-compliant transport across the whole supply chain, from active substance manufacture to dispatch to the distribution centre, distribution to pharmacies or clinical trial sites. We carry out audits and keep track of the whole picture.
Qualification of your suppliers and manufacturers, whether active substance manufacturers, manufacturers of packaging materials or excipients, or contract manufacturers and testing laboratories. We qualify and audit on a risk-based approach.
The regulatory framework
§ 13 AMG, own manufacturing and import authorisation (MIA) at three sites.
§ 14 AMG, named Qualified Persons in-house.
CTR 536/2014, investigational medicinal products for phase 1 to 3 clinical trials.
Annex 16 EU GMP Guide, certification by the Qualified Person and batch release.
AMWHV § 16, batch release under the German Medicinal Products and Active Substances Manufacturing Ordinance.
§ 13 AMG, GMP-certified laboratory for accompanying analytics.
You describe the product, dosage form and timeframe. We tell you what we need for the batch release.
02
Document and process review
We review the existing documentation and define the release process together with you.
03
Analytics where required
Any missing tests can be carried out in our GMP laboratory in Itzehoe, documented in accordance with GMP.
04
Certification and release
The Qualified Person certifies the batch. It may then go to market or into the clinical trial.
Typical initial situations
Does this sound familiar?
Biotech or virtual pharma
You have a product but no in-house QP. A full-time position is not worthwhile, and the trial will not wait.
Manufacturers outside the EU
Your product is finished. For the EEA market, you need a QP based in the EU who bears responsibility for batch release under European law.
Companies with a QP vacancy
Your own Qualified Person is unavailable or has resigned. Releases cannot wait regardless.
Clinical trial teams
Investigational medicinal product for phase 1, 2 or 3 ready, trial start imminent. You need the release under CTR 536/2014, reliable and GMP-compliant.
Responsibility
Who can take this on for you with us.
You get the name, the legal role and the extension of the person who takes over your topic. Before the start of the contract, not afterwards, and not as a team, but as a person.
Dr. Olaf Mundszinger
Founder and Managing Director
QP
Key areas
Pharmaceutical quality control and quality assurance
Person responsible for narcotics
IMPD preparation
Pharmaceutical analytics
Doctorate in analytical chemistry, degree in pharmaceutical sciences and chemistry
What exactly does batch release under Annex 16 mean?
Annex 16 of the EU GMP Guide governs certification by the Qualified Person. In it, the QP confirms that a batch complies with both the requirements of Good Manufacturing Practice and the marketing authorisation, that is, the marketing authorisation itself or the clinical trial authorisation. Only with this certification may the batch be placed on the market.
Can you also release investigational medicinal products under EU Regulation 536/2014?
Yes. We release investigational and comparator medicinal products for phase 1 to 3 trials under CTR 536/2014. We remain flexible according to timing, workload and number of batches.
Is the release carried out under our manufacturing authorisation or yours?
Both are possible. The release can be carried out under your own manufacturing authorisation. However, A&O Pharma also holds its own authorisation under § 13 AMG, under which batch releases can be carried out in accordance with Annex 16 or AMWHV § 16, which requires corresponding registration in the marketing authorisation documentation.
Can you release a batch even if I do not (currently) have my own Qualified Person?
Yes. That is precisely what we provide: a named Qualified Person under § 14 AMG from our company. She reviews your batch documentation and personally releases the batch by certification. The Qualified Person is integrated into your quality management system and works under your manufacturing authorisation.
Do you hold your own manufacturing authorisation for the release?
We hold the manufacturing and import authorisation under § 13 AMG (MIA). This foundation is already fully in place in-house at two sites and does not need to be established. It is the prerequisite for our Qualified Person to be able to certify and release your batch at all.
How quickly can you release a batch that has already been produced?
If a batch is finished and only the release is outstanding, short-notice releases are possible. This requires complete, auditable batch documentation. As soon as we have the documentation, we begin the assessment, for time-critical cases, please contact us directly.
What happens in the event of a deviation or an OOS result?
Deviations and out-of-specification findings are assessed before the release decision is made. Our Qualified Person examines whether the finding affects marketability and decides on this basis, in dialogue with you and, where necessary, backed by analytics from our GMP-certified laboratory. Only what can be justified is released.
Can you also place goods from third countries on the market?
Yes. For imports from third countries without a Mutual Recognition Agreement, we carry out the retesting required in the EU before the Qualified Person certifies the batch in accordance with Annex 21. Only then is the batch considered marketable. We cover the EU retesting with our GMP-certified laboratory.
As a member of the Life Science Nord cluster, we benefit from a strong, innovative network and work with other experts in the industry on forward-looking developments.