Pharma
- What applies
- Regulation (EU) 2022/123 governs shortage monitoring through the EMA, § 52b AMG the supply and reporting duty; alongside it the ALBVVG.
We make supply shortage risks visible early and translate them into measures: risk analysis, inventory strategy, second-source qualification and crisis management within statutory reporting duties. What counts is lead time: recognizing an interruption only from falling stock leaves no qualified second source and ends in a reportable case.
Overview
Shortage management across Pharma, Biotech, MedTech & IVD · Regulation (EU) 2022/123, § 52b AMG, Art. 10a MDR (EU) 2017/745 / IVDR (EU) 2017/746
Last updated: September 18, 2026
In regulated industries, a shortage of a GMP material, an active substance or a supplied component affects not only production but patient care, and it is subject to mandatory reporting. Unlike in unregulated industries, a source cannot be swapped out at short notice.
Industries
Services
Structured identification of critical materials, active substances and single-source suppliers based on supply relevance, lead time, substitutability and qualification effort. Deliverable: prioritized list of shortage-prone items with risk rating and lead time for countermeasures.
Differentiated safety stocks by criticality and shelf life rather than a blanket ratio, combined with defined contingency measures for each risk item. Deliverable: inventory and contingency strategy per material class with trigger thresholds and predefined action options.
Establishing a process that meets the reporting obligations under § 52b AMG and Regulation (EU) 2022/123 for medicinal products as well as under Art. 10a MDR/IVDR for medical devices and IVDs on time. Deliverable: documented reporting process with responsibilities, trigger criteria and recipient group.
Operational support during an acute shortage: prioritization of supply, allocation decisions, activation of second sources, and steering of internal and external communication. Deliverable: crisis plan with escalation paths and defined allocation rules.
How we work together
In a regulated environment, supply shortages rarely emerge suddenly, but they become visible too late. The real trigger is not the missing quantity but the missing lead time: once stock starts running down, the sequence of countermeasures is already lost.
In Life Sciences, an alternative source cannot be switched in at short notice, because it must be qualified before the first delivery.
Proactive shortage management therefore starts with the criticality analysis: which materials depend on a single source, how long is their lead time, and how demanding would a switchover be.
Only this list determines where a second source should be qualified in advance, where differentiated safety stock should be held, and where blanket stock with limited shelf life merely ties up capital and generates write-offs.
The second logic is that of the reporting obligation. In regulated industries a shortage is not an internal problem but a matter with statutorily defined recipients and deadlines.
For medicinal products, the reporting obligations under § 52b AMG and the framework of Regulation (EU) 2022/123 apply, with monitoring via the European Shortages Monitoring Platform; for medical devices and IVDs, Art. 10a of the MDR (EU) 2017/745 and the IVDR (EU) 2017/746 requires advance information to downstream actors, healthcare institutions and the competent authority.
Setting up the reporting process only during a crisis produces a second finding alongside the shortage itself. The reporting process therefore belongs defined in advance and connected to risk management, so that allocation is documented, the root cause is addressed, and recurrence becomes less likely.
Our approach
Step
Result
Criticality & Risk Analysis
Prioritized list of shortage-prone materials and single-source suppliers with risk rating and available lead time.
Contingency & Inventory Strategy
Contingency measures defined per risk item and differentiated safety stocks, aligned to criticality and shelf life.
Qualify Second Sources
Approved alternative sources for the most critical materials, with complete qualification documentation.
Embed the Reporting Process
Documented reporting process for § 52b AMG, Regulation (EU) 2022/123 and Art. 10a MDR/IVDR with clear trigger criteria and responsibilities.
Establish Early Warning
Ongoing monitoring of lead times and shortage signals that detects impending interruptions while countermeasures are still possible.
Steer the Crisis
In an acute shortage, an activated second source, prioritized allocation and timely reporting instead of an unplanned supply gap.
Common pitfalls
Single-source materials are not systematically captured.
If you do not know which item has only one source, you plan no second source and are left without a qualified alternative in a shortage; identifying the critical materials is the foundation, without which any contingency planning remains patchy.
The second source is only sought once the shortage hits.
In an acute case there is no time for qualification and release; the second source must be built up in advance, not reactively during a crisis.
Safety stock is applied as a blanket measure across all materials.
For GMP materials with limited shelf life, excessive stock generates write-offs rather than supply continuity; shortage protection lies in lead time and a second source, not in inventory volume.
The reporting obligation is underestimated.
For medical devices and IVDs, Art. 10a MDR/IVDR requires advance information well before the expected interruption; for medicinal products, the reporting obligations under § 52b AMG and the framework of Regulation (EU) 2022/123 apply. A late notification becomes a separate compliance finding in its own right, independent of the shortage itself.
The shortage is treated as a purely logistical problem.
Without a link to risk management and quality, the root cause remains open, the allocation decision undocumented and recurrence likely; shortage management belongs within the QM system, not in an isolated procurement action.
Supply Chain & Technical Operations
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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