Nitrosamine Impurities: Further Update of EMA's Question and Answer Document
Recommendation
18-20 November 2025
Practical approaches for assessing the risks of Impurities
The Q&A document developed by EMA and CMDh is updated at irregular intervals to reflect the latest knowledge. On 12 October 2022, the EMA published on its "What's new" website a new update of the Q&A document "Questions and answers for marketing authorisation holders/applicants on the CHMP Opinion for the Article 5(3) of Regulation (EC) No 726/2004 referral on nitrosamin impurities in human medicinal products" - now the 14th revision.
The document contains the following innovations:
Question 10: Which limits apply for nitrosamines in medicinal products?
The two nitrosamine compounds 4-(methylnitrosoamino)-1-(3-pyridinyl)-1-butanone (NKK) and N-nitrosoduloxetine were newly included in the table with corresponding limits (100 ng/day). The limit for nitrosoduloxetine was derived from structure-activity relationships. The value for NKK is based on the TD50 dataset of a database on carcinogenic potencies of numerous compounds (carcinogenic potency database; CPDB).
New question 21: What is the approach to control the presence of nitrosamines until a substance specific AI is established?
If new types of nitrosamine contaminants occur for which an acceptable intake (AI) has not yet been established due to a lack of toxicological data, a temporary limit, t-AI, of 178 ng/day (as the value for the sum of all nitrosamines present) can be applied. The validity of this t-AI value is 12 months, i.e. within this period no intervention (recall etc.) is required from the regulatory side for batches with a nitrosamine content up to 178 ng/day. If this period is exceeded, a special agreement with the authorities is required.
The t-AI value cannot be used automatically; a case-by-case assessment by the authority is required in each case.
Related GMP News
29.01.2025Revision of USP <1032> Design and Development of Biological Assays
23.01.2025English Translation of Supplement II to the Japanese Pharmacopoeia (JP18) Published
23.01.2025How to keep Analytical Systems Current and Compliant
23.01.2025FDA 483s due to Deficiencies in the Stability Program: Evaluation of Fiscal Year 2024
23.01.2025PharmaLab 2024 Brief Summary - Save the Date for 2025!
22.01.2025USP Chapters <31> and <1331> on Volumetric Apparatus again Published for Comments