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Services · Regulatory Affairs

Your medicinal product is ready. Who will take it through EU marketing authorisation?

Without a marketing authorisation holder in the EU, even the best product cannot reach the market. A&O Pharma applies for the marketing authorisation on your behalf and acts as interim marketing authorisation holder until the authorisation can be transferred to your commercial partner.

iMAH model IMPD / CTA Variations & lifecycle

No obligation, in confidence. We reply within one to two working days.

A product that is ready for authorisation but has no EU marketing authorisation is tied-up capital: it costs money every day and earns nothing.

The question that matters

Can you act as interim marketing authorisation holder for our product, and who takes over the authorisation later?

Yes. A&O Pharma meets all the legal requirements for a marketing authorisation holder in the EU. We apply for the marketing authorisation in our name on your behalf and hold it on an interim basis. The later marketing authorisation transfer to a company in the EU is a standard procedure, not an exception: the transfer to your commercial partner is planned from the outset and set out in the contract, so you never depend on us.

An efficient route to marketing authorisation

Two things are essential for marketing a finished medicinal product: a marketing authorisation granted by the competent authority, and its ongoing maintenance throughout the product's life. Regulatory affairs covers everything needed to obtain the authorisation (or registration) and keep it valid over the long term.

We take on these tasks for you, with named people responsible rather than changing contacts.

What we take on for you

  • Regulatory strategy: Everything starts with the strategy. Together with you, we develop the strategy that gets you to market fastest, tailored to your situation.
  • Interim marketing authorisation holder (iMAH): We apply for the marketing authorisations and act as marketing authorisation holder in the EU on an interim basis, until the authorisations are transferred to a commercial partner of your choice. You can find out how this works in the section on the iMAH model.
  • Support with scientific advice procedures: Scientific and procedural advice from the authorities helps resolve open questions before submission and avoid costly, time-consuming delays. We help you prepare and request scientific advice.
  • Submission of marketing authorisation applications and clinical trial applications on your behalf, including communication with the authorities and compilation of IMPDs and MAA dossiers. Preparing the dossier and keeping it up to date throughout the product's life ties up considerable resources. We support you and take this work off your hands, so you can concentrate on what matters most for your company's success.
  • Lifecycle management: Over its lifecycle, every medicinal product undergoes changes (variations) that must be notified to the authorities. In addition, the marketing authorisation must be renewed five years after it is granted. Another very important aspect is keeping documents up to date as regulations change, which places a considerable burden on your company's resources on top of its actual work. A&O takes this work off your hands cost-effectively, with experienced staff.
  • Information Officer under § 74a AMG: mandatory for every marketing authorisation holder and responsible for reviewing and approving the product information texts (summary of product characteristics, package leaflet, labelling) and all marketing materials, including the company website. A&O provides experienced colleagues who can take on this role for your company. If you have already appointed an Information Officer, we speed up the process by pre-reviewing texts and artwork.
  • Support with product launches and mergers and acquisitions, which involve a large number of regulatory transfers and notifications. Important aspects are easily overlooked at the planning stage. Support from experienced specialists helps projects run smoothly and ensures that every regulatory requirement is handled quickly and reliably. Here too, A&O provides experienced colleagues who work closely with your team.

The iMAH model in detail

You plan to bring your pharmaceutical products to the EU market but have no pharmaceutical company operating there.

Can you become the marketing authorisation holder for our product?
Yes. We meet all the requirements for a marketing authorisation holder in the EU. We apply for the marketing authorisation on your behalf and hold it on an interim basis. The exit is a standard procedure, not an exception. A&O does not act as distributor or sales organisation for the product; the transfer of the marketing authorisation to your commercial partner or your own distribution affiliate is planned from the outset and set out in the contract.

The approach has two stages:

  • Step 1: Together with you, we develop the marketing authorisation strategy. Based on the available documentation and the conditions for the applications, it forms the basis for your market access decision.
  • Step 2: We submit the registration and marketing authorisation applications (MAA). During the procedure, A&O Pharma acts as the applicant and, once the authorisation is granted, as interim marketing authorisation holder (iMAH).

Statutory roles: During the procedure and beyond, we provide the Stufenplanbeauftragter (German QPPV) under § 63a AMG, the Qualified Person (QP) under § 14 AMG and the Information Officer under § 74a AMG.

Once the marketing authorisation has been transferred to your commercial partner or distribution affiliate, we can continue to handle lifecycle management and the pharmacovigilance obligations under § 62 et seq. AMG. We also carry out the required EU batch certification and EU retesting. You decide the scope of our work.

The regulatory framework

  • § 63a AMG Stufenplanbeauftragter (German QPPV) for pharmacovigilance.
  • § 62 et seq. AMG pharmacovigilance obligations.
  • § 14 AMG Qualified Person (QP).
  • § 74a AMG Information Officer.
  • Clinical Trial Regulation (EU) 536/2014 and submission via CTIS.
  • §§ 13 and 72 AMG our own manufacturing and import authorisation (MIA) for subsequent EU batch certification.

Process

From enquiry to marketing authorisation dossier.

4 steps, one dedicated contact, no surprises.

Book an initial consultation
01

Strategy call

Target markets, procedure and timeframe. We tell you which route is fastest and what it will cost.

02

Dossier gap analysis

We review what is available and tell you plainly what is missing or should be clarified with the authority in advance.

03

Submission and communication with authorities

We compile and submit the dossier, respond to questions from the authorities and manage the procedure.

04

Holding or transfer

We hold and maintain the marketing authorisation until it can be transferred to your commercial partner.

Typical starting points

Does one of these sound familiar?

Manufacturers outside the EU

You have no legal entity in the EEA, and therefore no one who could hold the marketing authorisation. Without this step, the product cannot reach the market at all.

Biotechs preparing their first marketing authorisation application

It is your first dossier and you have no regulatory affairs department. You need someone who already knows the route, rather than learning it alongside development at considerable cost in time and money.

A growing portfolio

Variations, renewals and lifecycle maintenance are piling up while your own specialists work on new products. Maintenance is mandatory, but it ties up the same people.

Clinical trial sponsors

You need the application under Regulation (EU) 536/2014, including the IMPD, and the trial start date is already set.

Responsibility

Who is accountable for this.

You get the name, statutory role and direct phone number of the person handling your project before the contract starts, not afterwards. A named person, not a team.

Ute Hegener

Ute Hegener

Regulatory Affairs

Key areas

  • Marketing authorisation
  • Strategic consulting
  • EU authorisation procedures
  • Lifecycle maintenance

Degree in biology with a focus on molecular biology, plant metabolic physiology and enzyme chemistry, over 20 years of experience

Dr. Barbara Siebertz

Dr. Barbara Siebertz

Regulatory Affairs

Key areas

  • Lifecycle maintenance
  • Regulatory affairs
  • Quality management

Degree in biology with a doctorate, focus on molecular biology, biochemistry and botany, over 15 years of experience

Dr. Lenka Taylor

Dr. Lenka Taylor

Investigational Medicinal Products and GCP

QP

Key areas

  • GCP and GMP consulting
  • GCP training
  • Clinical trial planning
  • IMPD preparation

Doctorate in clinical analysis, specialist pharmacist in clinical pharmacy

Dr. Emmanuel Bey

Dr. Emmanuel Bey

Analytical Development

QP

Key areas

  • Analytical development, including validation and transfer of analytical methods
  • IMPD and dossier preparation

Doctorate in pharmaceutical chemistry

Case studies

Problems we have solved in this area.

Anonymised projects from this service: starting point, approach and outcome.

Clinical trial sponsor, small biotech company

From IMPD to QP release, all from a single provider

A new active substance from a non-EU country was to be used in a phase 1 trial as an investigational medicinal product. We provided GMP oversight, pro...

Read the full case study

Innovative biotech company in cancer therapeutics

Setting up a GMP manufacturing facility for peptide vaccines

A research institution is setting up a GMP manufacturing facility for personalised peptide vaccines. We are supporting it from regulatory classificati...

Read the full case study

Mid-sized company, marketing authorisation holder

Manufacturing site transfer: CMC review, transfer plan and support

A marketing authorisation holder is planning to change its manufacturer. We reviewed the CMC documentation, made recommendations on selecting a contra...

Read the full case study

Mid-sized contract manufacturer of medicinal products

QP batch release after EU import for a Swiss contract manufacturer

A Swiss contract manufacturer needs batch release for its authorised medicinal products after import into the EU. We release every batch on an ongoing...

Read the full case study

Clinical trial sponsor, small biotech company

Third-country active substance: QP release for a clinical trial

Active substance from a non-EU country, investigational medicinal product for a trial in several European countries: we provided GMP oversight, the IM...

Read the full case study

Clinical trial sponsor, small innovative biotech company

Novel manufacturing process, supported through to phase 2a

A multi-stage manufacturing process with many manual steps was to be automated in compliance with GMP. The phase 2a trial went ahead, and production t...

Read the full case study

Frequently asked questions about Regulatory Affairs.

We will answer your questions in an initial consultation. Ute Hegener will take the time to go through them with you.

Book an initial consultation
What does the iMAH model mean in practice, and why is it relevant to me?

iMAH stands for interim marketing authorisation holder. A&O Pharma applies for your marketing authorisations and acts as marketing authorisation holder in the EU on an interim basis. This matters if you do not yet have your own marketing authorisation holder in the EU: your product can be authorised without you first having to set up an EU company with all the regulatory obligations that entails. As soon as you are ready, the authorisations are transferred in an orderly way to the commercial partner you have chosen. Authorisation and building your commercial set-up can run in parallel, which saves considerable time before your product launch.

Does A&O act as marketing authorisation holder permanently, or only on an interim basis?

On an interim basis. The iMAH role is designed as a bridge: A&O holds the marketing authorisation until it is transferred to a commercial partner of your choice. You keep control of the product and decide when it is transferred and to whom.

Who is responsible for my marketing authorisation? Will I have a dedicated contact?

Yes. You do not get an anonymous ticket number but a named person responsible for your project. You know who you are talking to and can reach that person directly, including by phone.

Can I book regulatory affairs services on their own, or only as a package?

Both. You can commission individual services such as strategic advice, a single submission or lifecycle management. You can equally combine regulatory affairs with manufacturing (§ 13 AMG) and analytical testing from one provider, if you prefer to have everything in one place.

Which submissions do you handle on my behalf?

We prepare and submit marketing authorisation applications and clinical trial applications on your behalf, support scientific advice procedures with the authorities, and handle variations and the ongoing maintenance of existing authorisations throughout the product lifecycle.

How quickly can we get started, and what timeframe should we expect?

After a confidential initial consultation, we agree the strategy and procedure with you and can move quickly into preparation. The exact timeframe depends on the product, the target market and the authorisation procedure. We make this clear before you commit to anything. You will usually hear back from us within one to two working days, with no obligation and in confidence.

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