Pharma
- What applies
- Regulation (EC) No 1234/2008 governs variations, Directive 2001/83/EC Articles 23 and 24 renewal and updating; PSUR: Articles 107b to 107e.
We carry marketing authorizations through lifecycle management: variations under Regulation (EC) No 1234/2008, renewals, PSURs and US supplements under 21 CFR 314.70. How a change is classified decides whether you may ship at once or must wait for agency approval.
Overview
Variations type IA/IAIN/IB/II and extensions under Regulation (EC) No 1234/2008 · renewal under Art. 24 of Directive 2001/83/EC · PSUR under Art. 107b et seq. · PAS, CBE-30 and CBE-0 under 21 CFR 314.70 · changes under EU 2017/745 and EU 2017/746
Last updated: September 18, 2026
The lifecycle is the longest phase of a marketing authorization and the worst resourced. The approval project has a team, the maintenance that follows rarely does. Four places drive the cost.
Industries
Services
Assessment of every planned change against Regulation (EC) No 1234/2008 and Annex I: type IA, IAIN, IB, II or extension, with a reasoned classification, filing route and expected procedural timeline.
Classification under 21 CFR 314.70 and 601.12 into prior approval supplement, CBE-30 and CBE-0 with the distribution each permits, plus the annual report under 21 CFR 314.81(b)(2).
Renewal under Article 24 of Directive 2001/83/EC, PSURs under Articles 107b et seq. in the PBRER format per ICH E2C(R2), and scheduling along the EURD list.
Taking over the recurring work across a portfolio: change notifications, renewals, reporting obligations and agency questions, with a defined response time rather than a project end date.
How we work together
A marketing authorization is not a state, it is an inventory that has to be maintained. The effort does not sit where people expect it: not in the dossier but in the classification. Whether a change counts as type IA, IB or II under Regulation (EC) No 1234/2008 decides whether you may ship immediately, wait thirty days, or wait for approval, and the same question arises again, in a different form, in the US as CBE-0, CBE-30 or a prior approval supplement under 21 CFR 314.70.
The second lever is grouping. Sending the same change through twenty countries individually costs twenty times the fee and the review; Articles 7 and 20 of the regulation expressly provide for grouping and work sharing, and for larger portfolios the difference between the two routes is the single biggest item in the annual lifecycle budget.
The third is the deadline without an owner. Renewal under Article 24 of Directive 2001/83/EC, PSUR data lock points from the EURD list, the annual report under 21 CFR 314.81(b)(2): these clocks run on regardless of any project and go unnoticed until one is missed. For medical devices, EU 2017/745 adds that a technical change can trigger something in regulatory terms that development never sees, up to the question of whether the Article 120 transitional provision still holds.
Our approach
Step
Result
Portfolio inventory
List of all marketing authorizations and certificates with procedure type, countries, deadlines and open commitments.
Classification of the planned change
Reasoned category under Regulation (EC) No 1234/2008 or 21 CFR 314.70, with filing route and the consequence for distribution.
Grouping and sequencing
Plan for which changes run as a group or under work sharing and in what order, so that dependent changes do not block one another.
Dossier and filing
Variation or supplement filed in the required format, with the affected modules and the rationale for the classification.
Agency questions
Questions answered within the procedural deadlines, with the documented effect on the authorization text and product information.
Updating the records
Updated product information, updated dossier and a refreshed deadline list for renewal and reporting obligations.
Common pitfalls
A change is classified too low in order to ship sooner.
A change notified as type IA that is a type II change under Annex I of Regulation (EC) No 1234/2008 will be rejected; the goods then stand still longer, not shorter.
Grouping and work sharing go unused.
The same change enters the procedure separately for every country and every authorization, even though Articles 7 and 20 of Regulation (EC) No 1234/2008 expressly provide for bundling.
The renewal is treated as a formality.
Article 24 of Directive 2001/83/EC requires a consolidated version of the dossier; anyone who has filed changes for years without consolidating them is building up work for the renewal date.
PSUR dates are tracked from an internal calendar instead of the EURD list.
The list under Article 107c(7) of Directive 2001/83/EC sets the data lock point and cycle bindingly, and it changes.
For medical devices the change is assessed technically but not in regulatory terms.
Under EU 2017/745 the same design change can trigger notification of the notified body; for devices under Article 120 it decides whether the transitional provision still holds.
Regulatory Affairs
In a first call we assess your situation and say what needs clarifying first in your case. Without obligation, reply usually within one working day.
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The authorization itself, before its maintenance begins
Health Authority Interaction →
Questions and procedures with the EMA, FDA and national authorities
Labeling & IFU →
Product information and labeling that every change has to follow
International Market Access →
The same change across several countries and procedures
eCTD Publishing & Regulatory Operations →
The technical form in which every variation reaches the authority
Briefly outline your situation. We'll respond with an initial assessment, usually within one business day.
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info@theentourage.de