Overseas GMP documentation

Registrants of veterinary chemical products where one or more steps of manufacture are conducted overseas need to provide certain types of documentation as evidence of overseas GMP compliance.

Decisions often need to be made on a case-by-case basis due to differences in individual circumstances and the underlying legislation in different countries.

Decisions on the types of evidence the APVMA accepts often need to be made on a case-by-case basis due to differences in individual circumstances and the underlying legislation in different countries.

Where equivalence is established, the APVMA can accept overseas certificates of GMP compliance or similar documentation from that country.

1. Quality of overseas documentation

All certificates must be fully legible and complete. If certificates or other documents have accompanying pages, ensure all pages are supplied to the APVMA.

Bilingual certificates are acceptable provided one of the languages is English. If the certificate has been issued in a language other than English, a notarised English translation must be provided as well as a notarised copy of the original certificate.

2. Validity of overseas documents

Documents should usually be obtained from a government authority that is recognised by the APVMA.

We do not usually accept documents from non-government inspection bodies as primary evidence of GMP compliance. There must be no qualifying statement on a certificate that renders it invalid—such as a statement that ‘the certificate is issued for the Government of the UK and must not be used for any other purpose’.

Certificates and audit reports are only accepted for three years after the date of the last inspection or until the expiry date shown on the certificate (whichever is earlier). Certificates that claim validity for more than three years are only accepted for a maximum of three years after the last inspection date. A certificate that has an expiry date less than three years hence will only be accepted until the stated expiry date.

3. Information to include in the documents

The certificate or audit report must be dated. The document must clearly communicate:

  • it has been issued for the manufacture of veterinary chemical products or veterinary medicines
  • the manufacturing facility is authorised to manufacture the type of product under consideration
  • the facility is regularly inspected for compliance with the relevant GMP Code.

The scope of a certificate or audit report must cover the type of product to which the application relates and the relevant steps of manufacture.

The name and street address of the manufacturer on the certificate must be identical to that shown on the application form for registration.

It is also preferable that the last inspection date be listed on the certificate. If no satisfactory documentary evidence of compliance can be provided, the overseas manufacturing facility will need to be audited by an APVMA-authorised auditor for compliance with the Manufacturing Principles and the GMP Code.

4. Audit reports of overseas sites

The APVMA will consider audit reports from:

  • an APVMA-authorised GMP auditor from Australia
  • an auditor from one of the overseas authorities recognised by the APVMA.

In certain circumstances, the APVMA may consider an audit report from an alternative quality assurance certifying body that is internationally recognised. However, manufacturers must seek and attain permission from the APVMA before the audit takes place.

5. Submitting overseas documents to the APVMA

Certificates and other evidence of GMP compliance should be submitted electronically to the APVMA.  However, the APVMA expects that the original certificate or a copy of the original certificate is maintained and provided to the APVMA on request.

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