Questions and answers on variations and extensions HMP

The most important information can be found in the guidance document Variations and extensions HAM, guidance document Formal requirements (particularly section 3.12), and the form Variations and extensions HAM on the Swissmedic website.

If an applicant has submitted the incorrect variation type, it will be notified in the interim decision. It will then have to revise its notification of variation so that the correct type is submitted. If a variation cannot be accepted or approved, it may be necessary to demand cancellation of the implemented variation. This rarely happens, however.

Type IA_IN variations must be notified to Swissmedic no later than one month after implementation.

In these cases an interim decision will be issued and the notification will then have to be submitted as a type IB variation. If the applicant notices that the deadline has passed before submitting the corresponding type IA or type IA_IN variation, the application should be submitted as a type IB variation from the outset. Both deadline and fee requirements for type IB variations will be applied.

Yes. The definition for type IA/IA_IN is "Minor variation to be reported subsequently" (TPO Art. 21). These variations must already have been implemented at the time of submission; the implementation date must be in the past and must be stated on the form Variations and extensions HAM.

An exception applies if the type IA or IA_IN variations form part of a multiple application that also contains other types of variations (type IB, type II or extensions). In these cases, the variations can be implemented after the variations in the multiple application have been approved, and an implementation date does not need to be stated. However, if the type IA-/IA_IN variation has already been implemented as part of the multiple application, we would then also require an implementation date.

Any deviations from the requirement to state the implementation date (e.g. not necessary for E.101, PMF) are mentioned in the Variations and extensions HAM form.

Swissmedic follows the definition stated by the EMA in its Q&A.
Implementation of an IA/IA_IN quality change: Date on which the company makes the change in its own quality system. For Switzerland, the Switzerland-specific quality system is relevant in this context.
Implementation of a IA/IA_IN variation for product information and/or packaging texts: Date of internal release by the company / approval of the revised product information and/or packaging texts. Here too, the Switzerland-specific release is relevant for Switzerland.
The implementation date should be stated in the format "DD.MM.YYYY".

Although this type of submission for a multiple application is possible in principle, it does raise the question of the usefulness of a multiple application. Swissmedic therefore recommends that such applications be submitted together as a multiple application only if their subject matter is related.

Yes. If the relevant conditions are met, type IA variations for a medicinal product may be collected and submitted as a multiple application.

For variations of type IA, IA_IN involving a change to the product information texts, the date of revision (month/year) should, if applicable, be adjusted to match the implementation date, taking account of the requirements stated in section 2.20 and Annex 1 of the guidance document Product information for human medicinal products.
It is important to note that any requirements in the guidance document Product information for human medicinal products (section 2.20 and Annex 1) may override this requirement (e.g. the requirement that the date of revision should not be adjusted).

For variations of type IB involving a change to the product information texts, the date of revision in the form month/year should, if applicable, be adjusted to match the date of application submission, taking account of the requirements stated in section 2.20 and Annex 1 of the guidance document Product information for human medicinal products.

It is important to note that any requirements in the guidance document Product information for human medicinal products (section 2.20 and Annex 1) may override this requirement (e.g. the requirement that the date of revision should not be adjusted).

No extension of the time limit for corrective actions is granted for companies, either for type IA/IA_IN or type IB variations. For both variation types, a maximum of 30 calendar days is granted for corrective actions.

While Switzerland does not recognise "Annual Report" as a concept, the authorisation holder can collect all type IA variations for a medicinal product and submit these once a year. But this is not mandatory in Switzerland. Type IA variations can continue to be submitted on an ongoing basis, i.e. "uncollected". For a collection over the course of a year ("Annual Report"), it is important that the implementation date for the "oldest" type IA variation should not be more than 12 months before the reporting date (see also Q&A 1.8).

A form consisting of the administrative part (sections 1-7) plus the requested variation (e.g. Q.II.b.1.a "Secondary packaging site"). In the administrative part, the table under section 1 (Basic information) must be reproduced and completed according to the number of authorisation numbers/medicinal products concerned.

When categorising an "Other change", Swissmedic takes account of the published list "CMDh Recommendations for classification of unforeseen variations according to Article 5 of Commission Regulation (EC) No 1234/2008".

Swissmedic does not require covering letters for applications for variations of types IA, IA_IN and IB, provided no further information or explanations in addition to those in the form Variations and extensions HAM are required.

Yes, co-marketing products must make the adaptations to the revised TPLRO (Full declaration) only after these have been implemented for the basic product.

Both for the form Variations and extensions HAM and the form New authorisations of human medicinal products the eCTD file name starts with 1.2.1 ch-foapplvar-. In the variable part it is then up to the applicant to generate an appropriate file name, provided it is not too long.

If you receive an interim decision as a result of shortcomings in form or content and these have been answered within 30 days, you must wait for 60 days from the date of confirmation of receipt / Acceptance of delivery (for Portal users) of the replies before you can assume that the variation has been accepted/approved.

The curriculum vitae of experts is not necessary for type IA/IA_IN variations.

If the content of the existing Module 2 does not change as a result of the type IB variation, then Module 2 and Module 1.4.1 do not need to be submitted.

No, for a multiple application all the information and proposed variations should be requested in one pdf file.

As before – and as also applies with other applications (e.g. renewal) – you submit one form for each medicinal product/authorisation number, not one form for each medicinal product dosage strength.

No. E.109 cannot be submitted as collective or collective-multiple applications because they do not meet the requirements of Art. 22b TPLRO.

Applications for variations that are submitted as part of ongoing new authorisation applications are not recorded as separate applications, but are included in the ongoing review of the new authorisation. Submitting additional documentation while an application is being processed or submitting a variation for an ongoing new authorisation procedure may result in Swissmedic taking additional time or charging additional fees (see Chapter 1.1 “Additional time” of guidance document “Time limits for authorisation applications”)

All variations in a multiple application will be completed together. This means that if an individual variation within a multiple application has to be improved, the total processing time for all the variations will increase.

No, applications for variations that are processed under an FTP or PPN cannot form part of a multiple application.

For this application type, the Manufacturer information form only needs to be submitted if the secondary packer has changed.

No. Please see Section 9.1, Z.4 of the guidance document ‘Variations and extensions HAM’. In this case, a Z. 2. d) Modification or addition of a pharmaceutical form authorisation extension must be submitted, as the new container is deemed to be a new pharmaceutical form.

Swissmedic understands a complete set of documentation to refer to the entire life cycle of the basic product, i.e. including all submissions in chronological order from application to first authorisation of the basic product.

As an alternative to submission of the complete set of documentation, if there is a relevant declaration of consent from the authorisation holder of the basic product, only the actually approved documentation (Module 2 to Module 5) and any forms to be amended from Module 1 can be submitted, see section 3.11.2. of the guidance document Formal requirements.

The marketing authorisation holder of the basic product must give an appropriately formulated declaration of consent to Swissmedic as the regulatory authority stating that it is making available the scientific documentation on the product. For example: “The marketing authorisation holder of the basic product [...] hereby gives its consent to Swissmedic for its scientific documentation for the basic product [...] being placed on file in the process regarding conversion of the co-marketing medicinal product [...] to a regular authorisation.”

No, variation E.3 should only be submitted when the ATC code has been incorporated in the WHO final index. The application will not be dealt with if it is submitted too early.

Regardless of the implementation date, with effect from 1 February 2026 type IA and type IA_IN variations should be reported using the new form and the corresponding variation number. In case of doubt, the corresponding z- variation box should be checked (e.g. Q.z, type IA), together with a description and the variation number that was valid at the time of implementation.

No, application E.109 should be submitted separately.

No, E.109 only applies to the implementation of new requirements according to the revised TPLRO. In connection with a multiple application, in addition to E.109 you can also submit other pooled variations for the specific medicinal product. However, safety-related variations cannot form part of multiple applications.

No, a modified pack design corresponds to an E.100 variation (Change in the product information and/or packaging texts without the submission of scientific data) and cannot be processed under E.102 since E.102 is only intended for the additional pack size. A multiple application should therefore be submitted (E.100 and E.102).

The full declaration for co-marketing medicinal products should be implemented with E.101, not separately.

The scenario described above involves a regulatory change E.4: Change in the name and/or address of a marketing authorisation holder, DMF / ASMF holder, storage site for the Master Cell Bank and/or Working Cell Bank, manufacturing site for an active substance, intermediate or finished product, primary and/or secondary packaging site, manufacturer responsible for batch release, site for quality control and/or supplier of a packaging component, medical device component, starting material, reagent and/or excipient (if mentioned in the dossier), type IA_IN, or IA, depending whether the corresponding manufacturer is responsible or not for batch releases.

If the product information and/or packaging texts are now modified in connection with this change, a separate E.100 variation is not necessary. E.4 changes must be notified for each medicinal product concerned.

In this case we consider the submission of an E.100 to be unnecessary. E.4 is sufficient.

Yes, you can submit the deletion of a manufacturer that involves several sections of the Manufacturer information form as an E.5 variation (type IA).

The wording (singular or plural) of a variation in the Variations and extensions HAM form should be followed in all cases. In this case, the variation reads: "Deletion of sites..." (Plural).

The adaptations of a co-marketing medicinal product to its basic product should be notified to Swissmedic via the regulatory change E.101.

If this involves a change in the packaging code, or if not all the conditions are fulfilled, this would be a type IB variation, otherwise a type IA_IN variation. In both cases, the changes to the co-marketing medicinal product must be notified to Swissmedic within 30 days of approval of the corresponding changes to the basic product.

Since the implementation of the change(s) to the co-marketing medicinal product must be made at the same time as that for the basic product, and since this rarely occurs within the 30 days described above, Swissmedic does not require an implementation date for E.101 b) (type IA_IN).

Sample packs should be notified to Swissmedic on the Variations and extensions HAM form (regulatory change: E.102).

The promotional section of sample packs is checked only if an advertising permit needs to be obtained (sensitive groups: laxatives, anorectics, analgesics, sedatives and sleeping aids, with the potential for dependence or abuse). Authorisation of the sample pack must be applied for in the normal manner, and the promotional section must satisfy the legal provisions applicable to therapeutic products.

Since Swissmedic does not check the promotional section (apart from the exceptions mentioned above), a variation does not need to be submitted to us unless a product subject to compulsory prior control is involved. The legal provisions applicable to therapeutic products must be satisfied (direct responsibility of the authorisation holder).

Variation E.110 is included in Annex 7 to TPLRO. However, since authorisation holders do not need to notify E.110 separately, but this variation is rather initiated by Swissmedic in connection with a corresponding variation application for the establishment licence (change of name/domicile), E.110 is not included in the Variations and extensions HAM form.

No, the above-mentioned change should be submitted as a C.2 a) variation. Regardless of whether the conditions stated in the form can be satisfied or not, the application should be classified as type IA_IN or type IB.

This is C.2 a) (type IA_IN or IB).

No, it is not sufficient to submit only one application. For multiple applications of the basic product, all variations (same amount) of the multiple application must be submitted for the co-marketing medicinal product.

Yes, provided these specific variations are processed in an Assessment Report (AR) by the reference authority. For multiple applications, all variations within the same multiple application must be processed in the same Assessment Report.

No, the adaptation of a co-marketing medicinal product may only be submitted once the corresponding variation of the basic product has been approved.

On expiry of the document protection for the reference preparation, the authorisation holder submits a C.2 variation for its biosimilar. If this variation entails new, additional data (e.g. data on comparability or clinical trial results), a type II variation – C.2 b) – must be submitted. However, if the extrapolation is backed up by a scientific assessment which also specifies explicitly why a biosimilar does not require any additional clinical data, then a type IB variation should be submitted: C.2 a).

No, if the sample pack corresponds to the smallest authorised pack size, it is the responsibility of the marketing authorisation holder to ensure that the sample pack is correctly labelled.

Swissmedic will not consider the submission of an application E.102 for such a sample pack.

Application E.102, type IB should be used to submit applications for inclusion of a new pack size or a change in pack size of, for example, 5 to 10 ampoules (i.e. the 10 ampoule pack replaces the 5 ampoule pack). It should be noted that a separate application E.102 must be submitted for each new or modified pack. Several variations can be submitted as a multiple application.

Yes, it is possible to change only individual dosage strengths for export. However, it must be ensured that the remaining product presentations for the main authorisation conform to the dosage instructions and treatment duration defined in the Information for healthcare professionals or that the dosage instruction can be met using the remaining dosage strengths.

New rules on the issuing of packaging codes apply to applications received by Swissmedic on or after 1 June 2024. These rules have been simplified so as to considerably reduce the number of packaging codes issued by Swissmedic in the future. No new packaging codes will be issued in the following cases in future:

a)    Change from export licence to main authorisation

b)    Change(s) to the medical device component in the case of combination products

c)     New excipients or changes to the excipient composition

d)    Change in the dispensing category

e)    Change, subject to compulsory declaration, in the specification of a herbal product

f)      Change to the pack contents (e.g. omission of the solvent/dilution container from the pack)

g)    Reclassification from active substances to excipients or deletion of active substance

A type IB application to change the pack size from 10 to 20 tablets means that the packs of 10 tablets will be discontinued with immediate effect. Selling off the remaining packs of 10 tablets is therefore not permitted. In order to be able to continue distributing packs of 10 tablets until they have been sold off, an application E.102 type IB must be submitted for the new pack size of 20 tablets and, only at the appropriate time, discontinuation of the pack size of 10 tablets must be applied for using an application E.103 type IA.

No. Changing the language in which the medicinal product information is submitted is subject to a one-time application E.100 type IB. In addition, the applicant must provide confirmation that the new language version submitted corresponds to the currently approved version.

For variations that were approved by the EMA according to the "old" catalogue, but that are submitted to us after 1 February 2026 in the procedure according to Art 13 TPA, the company must submit the corresponding variation using the new Variations and extensions HAM form. The EMA decision is accepted. The number (e.g. B.II.b.1.c) under which the variation was submitted to the EMA and approved is irrelevant, what matters is the EMA's Assessment Report on the variation. However, the company must check the box for the appropriate variation number in the new Swissmedic form (e.g. Q.II.b.1.c).

The wording (singular or plural) of a variation in the Variations and extensions HAM form should be followed in all cases. It is necessary to submit one variation per CEP when presenting a new or updated Ph. Eur. certificate of suitability. If deleting Ph. Eur. certificates of suitability, several deletions can be combined in one application.

Exception: In the case of Ph. Eur. certificates of TSE Suitability for an excipient (e.g. gelatine), it is acceptable to submit several CEPs within the same variation number (Q.III.1.b.2 or Q.III.1.b.3).

No, each individual PACMP must be submitted with a B.II.g.2 variation, and the variation template for Q.II.g.2 must be copied accordingly.

No. A separate template Q.II.b.1 must be completed for each change (3 copies of template Q.II.b.1). The three changes (secondary packaging site (Q.II.b.1.a), primary packaging site (Q.II.b.1.b), and new manufacturing site for the finished product (Q.II.b.1.e)) may not be checked on one template.

We expect the copy of the approved release and end-of-shelf-life specifications to be inserted in Module 1 under "additional data".

This is an integral combination product. Please submit your described variation as Q.IV.2.z Other variation (type IB). Please note that, according to the new MDR, for integral combination products with a medical device component higher than Class I, a Notified Body Opinion must be submitted (see also the guidance document Formal requirements, section 2.5.15 and the information on combination products on the Swissmedic website: Information).

A name change for suppliers of primary packaging should be submitted as Q.II.e.7.z (type IA).

For the change in batch release Q.II.b.2.c) provides subitems 1, 2 or 3, each of which starts with "Addition or replacement of a site responsible for batch release". "Replacement" means that a deletion and new notification can be implemented in the same step.

An additional manufacturing site for the primary and secondary packaging involves two changes: Q.II.b.1.a) and Q.II.b.1.b).

A distinction should be made between the establishment of a new MCB or a new WCB.

a) Establishment of a new MCB: type II, Q.I.a.2.b)

b) Establishment of a new WCB (provided that no approved protocol is followed): type IB, Q.I.a.2.a)

c) Establishment of a new WCB (provided that an approved protocol is available in Module 3): no application.

d) Establishment of a new WCB and a protocol: type II, Q.I.a.2.b)

A variation can be submitted as "Other change" if it is not listed in Annex 7 TPLRO (List of variations according to articles 21-24 TPO). An "Other change" is by default a minor variation of type IB. If a more extensive variation is involved, both Swissmedic and the marketing authorisation holder can upgrade this to a variation of type II.

When categorising an “Other change”, Swissmedic also takes account of the published list “CMDh Recommendation for classification of unforeseen variations according to Article 5 of Commission Regulation (EC) No 1234/2008”. An "Other change" can then be submitted as type IA or type IA_IN only if it was also classified as such in the published CMDh list. The submission must reference the list "CMDh Recommendation for classification of unforeseen variations according to Article 5 of Commission Regulation (EC) No 1234/2008", the corresponding EU variation number and the "Date issued".

The use of a new working virus stock that has been qualified according to an approved protocol does not need to be reported to Swissmedic.

The Annual Update for an authorised seasonal influenza vaccine must be submitted as a Q.I.a.5 change: Changes to the active substance of a seasonal, pre-pandemic or pandemic vaccine against influenza (type II). The corresponding documents should be made available to Swissmedic as soon as possible. The procedure is identical to the former procedure. If possible, the application is processed as a matter of priority.

N.B.: This change may not be part of a multiple application. The Annual Update may only include changes connected with the new strains.

Yes. An update to a DMF / Module 3.2.S can be submitted with the Q.I.z “Other quality change to active ingredient”, type II variation. All updated sections of Module 3.2.S and all changed parameters must be set out in detail in the “Present” / "Proposed” list.

This variation should be submitted as Q.IV.1.z, type IA.

Editorial changes to Module 3 can be submitted as an “Other change” Q.z, type IA (also see the guidance document Formal requirements, section 3.12).

Yes, this is possible provided the specifications for the glass container remain unchanged. The application must be accompanied by reasons and/or by a confirmation that there is no risk, with the preparation concerned, of there being an incompatibility between the preparation and the glass container such as may arise, for example, with formulations containing phosphate, citrate, gluconate or tartrate salts or complex-forming agents such as EDTA or formulations with alkaline pH values. A confirmation must also be provided stating that, in the event of a future change of supplier/manufacturer, the compatibility of preparation and glass container will be subjected to compatibility testing on a case-to-case basis, as described in the Production Statement in Ph. Eur. section 3.2.1 (Glass containers for pharmaceutical use).

In the case of rubber closures for parenterals, the manufacturer and/or the precise, manufacturer-specific designation for the closure as well as the specifications for the closure must be stated in section 3.2.P.7. Closures may exhibit the following differences, which can influence the finished product quality:

• surface treatment (e.g. silicon or Teflon coating);
• type of rubber closure (e.g. halobutyl type), i.e. exhibiting a different qualitative and quantitative composition;
• dimensions (even minor deviations can impair the impermeability of the closed vial).

Moreover, Ph. Eur. section 3.2.9, “Rubber closures for containers for aqueous parenteral preparations, for powders and for freeze-dried powders”, states the following: “The manufacturer of the preparation must obtain from the supplier an assurance that the composition of the closure does not vary and that it is identical to that of the closure used during compatibility testing”.

Thus the manufacturer of rubber closures for a parenteral dosage form may only be deleted from section 3.2.P.7 by way of a type IA application Q.II.e.7.a if it is explicitly stated in section 3.2.P.7 that only alternative closures with the same quantitative and qualitative composition and identical specifications may be used.

See Q.I.b.3, Change to an in-house reference standard/reference preparation for a biological active substance.

Submission of an updated CEP for a heparin as type IA (Q.III.1.a.2) is only possible in the case of a change of name and/or address of the CEP holder or a manufacturer of the active substance. The manufacturing location and all manufacturing steps must remain unchanged.

In the case of other content changes to the CEP, the following applies:

• Because the starting material for heparins (including low-molecular-weight heparins) is of animal origin, condition 4 is not met. Type IB should therefore be checked for the Q.III.1.a.2 variation.
• If an assessment of the risk of potential contamination with adventitious agents is required, a type II variation (Q.III.1.b.5) should be submitted.

The types of variations that can be included in this type of protocol depend on the complexity of the medicinal product and its manufacturing process as well as the knowledge the authorisation holder has gained of it. It is therefore not possible to compile a list of acceptable variations.

A PACMP is not possible for a biological medicinal product for which non-clinical/clinical data are required as part of the comparability study.

All variations resulting in an authorisation extension (see guidance document Variations and authorisation extensions HAM) can also not be applied for as an PACMP.

Yes. The following complex related changes could be considered for submission under a single type II scope Q.II.b.1.z - Addition of a new finished product (FP) manufacturing site: changes to the manufacturing process, batch size and in-process controls to adapt to the new manufacturing site settings.

Complex related changes submitted under a single type II should always be clearly identified in the application form as follows: a clear description of all the related changes should be provided in the “Scope / justification for the change”. All the related changes should be listed in the “Present / Proposed” table.

Changes affecting the FP not directly related to the introduction of the new manufacturing site – such as changes in excipients, specification parameters /limits for the FP, container closure system including suppliers – should be submitted as additional variations.

Regarding the procedure, requirements and restrictions for submitting a PLCM document, Swissmedic refers to the relevant EMA document (Guidance on Product Lifecycle Management Document) and to the currently valid version of the form Changes and marketing authorisation extensions HAM (variation types Q.I.e.6 and Q.II.g.6).

Before submitting a PLCM, Swissmedic must be contacted in a ‘meeting before application submission’ to clarify procedural questions (ZL105_00_003 Meetings for applicants for authorisation procedures).

If a manufacturing or testing site in Switzerland is affected by a PLCM, Swissmedic must be contacted in advance via a ‘Scientific GMDP Meeting’ (I 321.AA.01 A05e Scientific GMDP Meetings for establishment licence holders). In this context, it must be clarified how the maturity and effectiveness of the pharmaceutical quality assurance system (PQS) are to be demonstrated before submitting the PLCM.

Any existing communication with the EMA must be submitted in each case.

The company requests the following variations in connection with a multiple application:

C.6. a): Addition of a new, or a variation to, an approved therapeutic indication for bacterium D (type II) and

C.6. b): Deletion of a therapeutic indication for bacterium A (type IB)

The amount levied will be that for the new authorisation of a medicinal product, but no more than CHF 30,000.

No. Submit a C.4 variation (type II) in this case. The PRAC recommendations and corresponding PRAC minutes are adequate documentation. The PRAC assessment report should also be submitted if available. If applicable, the relevant CMDh documentation on the variation will also be accepted.

For changes to product information texts, Swissmedic expects the following under “currently approved – proposed”:

• E.100: List of sections that have been changed
• C.2:     Status of “old” information compared with status of “new” information.
• C.4:     List of sections that have been changed

The Variations and extensions HAM form now specifies what information has to be provided for a variation to medicinal product information texts for the relevant applications.

No, an application for implementation following the expiry of document protection for the reference medicinal product/preparation may only be submitted once the document protection has expired.

Additional editorial changes may be made as part of a C.4, type II variation. It is not necessary to apply for an additional E.100, type IB variation for this purpose.

In this case, no application is necessary. The date of revision can be amended independently.

If the reference product is no longer authorised, it is basically the responsibility of every authorisation holder of a KAS without innovation that is still authorised to keep its product information texts up to date and in line with the state of the art. However, it is also possible to adapt the product information texts to another KAS without innovation if more recent texts are available for the latter.

This first-time adaptation should be submitted as a C.2 a), type IB variation

If in the future the text should consistently be adapted to the same KAS without innovation, the following applications can be submitted as type IA_IN variations, provided that the conditions according to the Variations and extensions HAM form are met.

No. Pursuant to Art. 28 TPO, the marketing authorisation holder is obligated to adapt the medicinal product information on an ongoing basis without being requested to do so and notify Swissmedic of this promptly. A C.2 a) application should be submitted per variation of the medicinal product information for the original preparation, i.e. per text revision date. If the variations concerning the original preparation follow in quick succession, a multiple application with several C.2 a) variations can be submitted; however, it should be noted that the completion deadline – as of the implementation date for the first Type IA_IN application – must not lie more than 1 month ahead.

For PMFs, an Annual Update must be submitted each year as an authorisation condition. A PMF Annual Update (without PMF changes) is submitted in a cover letter without the Variations and extensions HAM form.

Changes to a PMF should be submitted using the Variations and extensions HAM form.

A PMF update and changes to this PMF can be submitted together, in which case they will be treated as a multiple application.

To ensure a clearer distinction between

• PMF changes submitted together with a PMF Annual Update and
• PMF change(s) submitted without a PMF Annual Update, we would ask companies to add the following clarification* in the cover letter:
  • Changes to PMF with Annual Update PMF or
  • Changes to PMF without Annual Update PMF *

A corresponding publication can be found in the Swissmedic Journal 09/2018 (page 826).

* The corresponding box should be checked in the Variations and extensions HAM form

Swissmedic is not intending to harmonise its practice with European requirements.

Indirectly yes, in Switzerland there will be "grouping" by the highest category taking account of the PMF classifications according to M1-M16

For each PMF, applications for one or more PMF variations are submitted according to the highest category (type II, IB, IA/IA_IN) as classified in the updated EU Guideline* under "Q.V.a) PMF" or "M. PMF".

Example 1: The applicant plans to submit two type IA variations and one type II variation together: All three variations are to be submitted as a type II application.

Example 2: The applicant plans to submit four type IB variations together: All four variations are to be submitted as a type II application.

* Guideline on the details of the various categories of variations, on the operation of the procedures laid down in Chapters II, IIa, III and IV of Commission Regulation (EC) No 1234/2008 of 24 November 2008 concerning the examination of variations to the terms of marketing authorisations for medicinal products for human use and on the documentation to be submitted pursuant to those procedures (C/2025/5045)

No, Swissmedic is not involved in the EU’s PMF certification process.

Not at all. Swissmedic has no access to the PMF registered centrally in the EU.

As a type II variation, Inclusion of a new PMFs (X.d).1).

a) Yes, that is correct. An additional (higher) dosage strength corresponds to an extension 2.c) and may be marketed under the same trade name with the addition of the dosage strength in mg / mL

b) A new dosage strength (formerly sequence) will be issued for the new dosage strength, with corresponding new packaging codes for the new packs (see guidance document Variations and extensions HAM, sections 9.2).

c) Generally speaking, it can be stated that a new dosage strength (number) is issued within the same authorisation number, provided no effects on efficacy, interactions, absorption etc. are expected. In conclusion however, your question cannot be answered since not enough information is provided.

An extension that requires a new authorisation number (according to the guidance document: Variations and extensions HAM, section 9, e.g. new pharmaceutical form) can be submitted at any time.

Extensions that do not require a new authorisation number (e.g. new dosage strength for solid and semi-solid forms) can be submitted in connection with the ongoing first authorisation procedure (submission of additional documents with possible delay in the first authorisation). Alternatively, the application can be submitted after the conclusion of the first authorisation procedure.

A seq. 0000 may be submitted only if a new eCTD lifecycle is started. This is the case if an existing product is switched from eDok/paper (with/without baseline) to eCTD or in the event of new notifications. For extensions, Swissmedic recommends working with the existing lifecycle and e.g. integrating the new pharmaceutical form in the existing lifecycle. If a new lifecycle is to be started for an extension, Regulatory Management or Operational Support Services must always be consulted beforehand.

No. When categorising variations and considering the modalities of their submission, Swissmedic is guided by the relevant directives, specifically Regulation (EC) no. 1234/2008 and the European Commission Guidelines based on this Regulation (cf. Art. 25 para. 1 of the Therapeutic Products Ordinance [TPO; SR 812.212.21]).

Yes, medicinal products may continue to be supplied to druggists with those old packaging elements (C vignette) during the published transitional periods. This does not apply to medicinal products that must incorporate a warning on the packaging.

The automated notification via e-mail will still happen.

As in the EU, the transfers of authorisations are also not classified as variations in Switzerland, but as "Übrige/Other" applications. These applications will continue to be requested by the future authorisation holder. The application must be submitted to Swissmedic at least three months before the planned transfer date. Further details can be found in the guidance document Transferring an authorisation.

Your proposed sentence may not be included in package leaflets. The reasons for this include the transfer of responsibility for publication from Swissmedic to the "institution in the form of a foundation" (refdata) and the fact that the wording of section 16 of the Patient Information is fixed according to the annex to the TPLRO and that no addition is possible.

The Swissmedic Portal has been adapted and for multiple applications, all variations of the multiple application can now be seen under Application Type.

When categorising variations and considering the modalities of their submission, Swissmedic is guided by the relevant generally accessible directives, specifically Regulation (EC) no. 1234/2008 and the European Commission Guidelines based on this Regulation (cf. Art. 25 para. 1 of the Therapeutic Products Ordinance [TPO; SR 812.212.21]). However, individual agreements that the EMA or a national authority has concluded bilaterally with individual authorisation holders cannot be considered in applications submitted to Swissmedic.

A multiple application with two applications for extension (AE) 2.c) “Modification or addition of a dosage strength”, one new indication (C.6.a) “Addition of a new, or a variation to, an approved therapeutic indication”, and one new administration route (AE 2.e) “Change or addition of an administration route” must be submitted, i.e. the multiple application includes four variations and four crosses should be entered in the relevant variation form. Multiple applications are capped at a maximum of CHF 30,000.

One application for extension 2.d) “Modification or addition of a pharmaceutical form” should be submitted.

Yes, a cost cap does apply and the maximum amount is CHF 30,000.

Authorisation extensions are extensions in the EU’s sense of the term. You can find them in Chapter 1.6 “Extensions” of Annex 7 to the TPLRO. Extension of indications (modification of an indication or new indication) are classified as type II variations.

In addition to the discontinuation of the medicinal product, an application for a variation C.7 a) “Deletion of a pharmaceutical form”, type IB should be submitted for the remaining medicinal products in the collective Information for healthcare professionals text.

Please note that “Discontinue preparation” applications are not variations in accordance with the Variations and extensions HAM form and cannot therefore be submitted in a multiple application.

Discontinuation of a dosage strength must be submitted as a variation C.7 b), type IB. In grouped Information for healthcare professionals, the C.7 b) application should only be submitted for the medicinal product concerned (no collective application required).

See updated Q&A no. 7.8.

This is an application for variation Q.IV.1 a): Addition or replacement of a medical device component included in the packaging or a referenced medical device. We also require proof of the CE marking and the EU declaration of conformity of the medical device included in the packaging (see also the information on combination products on the Swissmedic website: Information). This variation involves a substantial change to the medicinal product information and/or packaging text and is therefore a type IB variation. An additional E.102 application is not required.