Legal basis
Anyone who manufactures medicinal products commercially or professionally needs a manufacturing authorisation under section 13 of the German Medicinal Products Act (AMG). Section 3 of the German Medicinal Products and Active Substances Manufacturing Ordinance (AMWHV) refers to the EU GMP Guide. Wholesale distribution is governed by the EU Guidelines on Good Distribution Practice (GDP), which likewise require self-inspections, supplier qualification and validated systems. GMP, GDP and GCP are often grouped together under the term GxP.
What a consultant may take on and what stays with the manufacturer
Chapter 2 of the Guide requires consultants to have adequate education, training and experience for the subject they advise on. Under Chapter 7 and section 9 AMWHV, every outsourced activity needs a written contract.
A consultant may prepare protocols and documents, carry out qualification and validation, and conduct audits.
The manufacturer remains responsible for the pharmaceutical quality system and for reviewing and approving protocols supplied by a third party (Annex 15, point 2.6).
Batch certification remains with the Qualified Person under section 14 AMG.
Qualification and validation under Annex 15
The validation master plan defines the programme. Qualification runs from user requirements (URS) through DQ, factory acceptance testing (FAT) and site acceptance testing (SAT), IQ, OQ and PQ. Process and cleaning validation, validation of analytical test methods and change control follow. Scope and depth follow a documented risk assessment. Retrospective validation is no longer considered acceptable.
Computer system validation and data integrity
Under Annex 11, applications must be validated and IT infrastructure qualified. A risk assessment determines the extent of validation and of data integrity controls. Requirements include a system inventory, access controls, audit trails that are regularly reviewed and periodic evaluation of whether a system remains validated. Drafts of a revised Annex 11, a revised Chapter 4 and a new Annex 22 on artificial intelligence were open for consultation from July to October 2025.
GMP documentation, self-inspection and regulatory inspection
Chapter 4 distinguishes instructions such as specifications and SOPs from records. In addition there is the Site Master File. Under Chapter 9, self-inspections must follow a pre-arranged programme and be recorded, and independent audits by external experts may also be useful. Under section 64 AMG, sites holding a manufacturing or import authorisation are generally inspected by the competent authority every two years.