GMP · Foundations

EU GMP

EU GMP is set out in EudraLex Volume 4, given legal force by EU Directives, and enforced by the national inspectorate of each member state — IGJ in the Netherlands.

In one line

EU GMP is set out in EudraLex Volume 4, given legal force by EU Directives, and enforced by the national inspectorate of each member state — IGJ in the Netherlands.

Plain-English explanation, then the primary regulation it comes from.

Explanation

Understanding eu gmp

EudraLex Volume 4 is the guideline document, and its structure matters because it determines which rules apply to you. Part I covers medicinal products and is organised as nine chapters. Part II covers active substances used as starting materials and is essentially ICH Q7. Part III holds supporting documents rather than requirements — the Site Master File format, ICH Q9 and ICH Q10 among them. The Annexes then layer product- or activity-specific requirements on top.

The guideline itself is not the law. Legal force comes from the Directives: Directive 2001/83/EC establishes the framework for medicinal products for human use, Commission Directive (EU) 2017/1572 sets out the GMP principles and guidelines for them, and Commission Delegated Regulation (EU) 2017/1569 does the equivalent job for investigational medicinal products. This is why 'it is only a guideline' is a misreading.

Enforcement is national. Each member state's inspectorate inspects sites in its territory and issues GMP certificates or non-compliance statements, which are published in the EudraGMDP database. EMA coordinates rather than inspects. For a Dutch site the inspectorate is IGJ; marketing authorisations are a separate matter handled by CBG-MEB.

Two practical consequences follow. First, an inspection outcome in one member state is visible across the EU and to your customers. Second, PIC/S membership means the same expectations largely travel — a PIC/S-aligned inspectorate outside the EU will recognise the same structure, which is why the EU text is worth knowing even for sites supplying elsewhere.

What it requiresThe substance of the requirement, stated plainly.
Part I — Chapters 1 to 9
Pharmaceutical Quality System, Personnel, Premises and Equipment, Documentation, Production, Quality Control, Outsourced Activities, Complaints and Recalls, Self Inspection.
Part II — active substances
Basic requirements for APIs used as starting materials; aligns with ICH Q7.
Part III — supporting documents
Site Master File guidance, ICH Q9 on quality risk management, ICH Q10 on the pharmaceutical quality system, and related templates.
The Annexes
Activity- and product-specific requirements, including Annex 1 (sterile), Annex 11 (computerised systems), Annex 15 (qualification and validation) and Annex 16 (QP certification).
Legal basis
Directive 2001/83/EC, Commission Directive (EU) 2017/1572, and Commission Delegated Regulation (EU) 2017/1569 for investigational products.
Enforcement and transparency
National inspectorates inspect and certify; outcomes appear in EudraGMDP. IGJ inspects in the Netherlands.
Where it goes wrongThe part a definition alone will not tell you.

Common failure modes

  • Working to a downloaded Annex that has since been revised — always check the version in force and its transition dates.
  • Assuming Part I applies to an API operation, when Part II is the relevant text.
  • Treating an Annex as optional because it is 'only an annex'; where it applies, it applies in full.
  • Confusing the roles of IGJ and CBG-MEB, and routing a GMP question to the wrong authority.
Primary sourcesAlways verify against the primary source before acting; guidance is revised.

Where this is written down

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Applying this to your site

Knowing the requirement is not the same as closing the gap

If you want to know where your site actually stands against this, the readiness score covers seven quality-system domains in twenty questions, and takes about ten minutes.