New PIC/S Q&A Document regarding Distribution Activities for APIs
Recommendation

22 October 2026
Good Distribution Practice of Active Substances for Human and Veterinary Medicinal Products
The range of documents (Aide Memoires and Guidance Documents) available for PIC/S inspectors has been extended to the category of Questions & Answers documents.
The first Q&A document published is intended to support inspectors during API inspections regarding distribution activities and repackaging.
Some answers refer to
Part II of the PIC/S Guide. It seems to be useful against the background of the revised Pharma Directive 2001/83/EC through which inspections in the logistics chain will become more and more important.Here are some of the topics dealt with in the 13 questions and answers:
- Should financial records in addition to GMP documents be examined during inspections?
- How can the finished product manufacturer be sure about the integrity of the whole API supply chain?
- Which kind of information is requested about transport conditions of APIs and is a transport validation needed?
- On which aspects should inspectors focus on during inspections of brokers/traders?
- What are repackaging and relabelling activities, particularly since PIC/S GMP Guide Part II gives no definition of them?
- Should stability studies be conducted on repackaged APIs?
For details please see the
new Q&A document available on the PIC/S website.Author
Dr Robert Eicher
CONCEPT HEIDELBERG (a service provider entrusted by the ECA Foundation)
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