For medicines, the EMA and various other national medicine evaluation agencies require that certain documents, including the Summary of Product Characteristics (SmPC), the Patient Information Leaflet (PIL), and the packaging and labeling texts, be presented in the official language or languages of the Member States or markets in which the medicinal product is to be placed. When more than one (01) language is employed, there should be a text available in each language and their contents should all be identical. A manufacturer cannot apply for a drug registration without submitting these relevant documents, all appropriately translated and localized as per the European Union (EU) labeling requirements or national Regulatory Authorities. Even after obtaining the authorization, the company must inform the concerned authority about all the post-authorization labeling changes, done in line with the product updates, through relevant communication channels.
The organization must also be on the lookout for periodic recommendations given by the Pharmacovigilance Risk Assessment Committee (PRAC) which may impose a change in the EU product labeling requirements. Additionally, tracking the EMA’s reviews and updates on Quality Review of Documents (QRD) templates for product information will help in local label comparison and thus, align with the latest applicable template.
Language Translation and Localization Challenges for Pharmaceutical Industry in the EU
Pharmaceutical companies manufacturing within the borders of the EU need to make the SmPC, the PIL, and the packaging and labeling texts available in up to twenty-three (23) official languages of the EU.
Languages of the European Economic Area, new EU candidate countries, and recognized minorities’ additional languages are those countries that are non-EU but EEA members (Norway and Iceland), and candidate EU countries (Croatia, Serbia, and Macedonia). Other possible required languages are those of the recognized minorities in the EU (such as Catalan, Corsican, Frisian, and Welsh).
Twenty (20) Days to Produce Translations
The EMEA sets a strict timeframe of twenty (20) days for the submission of the translated versions of all documents. Initial translations must be provided within five (05) days. After the marketing authorization is given by the CPMP, the EMEA committee is responsible for assessing the marketing authorizations. By the 20th day, the revised versions of the translations must also be provided to the EMEA in their final publishing format.
Culture-specific Translation and Localization Problems: Differences in norms and conventions of the source and target culture (e.g., legal guidelines for PIL, differences in PIL usability regulations, and differences in expressions, symbols, and pictograms established by the Member States) must also be considered while translating documents.
Multilingual PIL Readability Testing: Each language package leaflet must be written clearly, comprehensively, and legibly. The patient should be able to understand what is written on it. PIL readability testing is the procedure by which PILs are tested and reformulated to ensure that they meet the EU labeling requirements.
Product Updates: Updates to product information can result from changes in legislation or product changes through discoveries. Such updates generally take place a couple of times every year. In each case, the pharmaceutical company must go through processes quite similar to those they undergo when applying for initial drug approval. For this reason, the translation of documents is again required.
Consequences of Mistranslations: When it comes to medicine specifications, usage, dosage, and side effects, incompetent translations and mistranslations can lead to disastrous consequences. Developing a new medicine is a costly and lengthy process. A faulty translation can result in a market delay or lead to product recalls. In some cases, it can even lead to product liability lawsuits. To eliminate these risk factors, RA experts need to collaboratively work with professional language translation providers, preferably on a long-term basis.
To assist organizations to sail through the EU labeling requirement business imperatives, Freyr offers specialized labeling services for the region, including:
To streamline end-to-end Regulatory labeling practice from creation to tracking to managing in company of any size, Freyr offers a centralized labeling life cycle management software, Freyr LABEL. Right from creating, tracking and managing company core data sheet (CCDS) deviations, CCDS updates, and developments to creating, implementing, and inspecting multi-lingual regional labels as well as custom reporting. Freyr LABEL puts companies in total control of all their Regulatory labeling compliance needs.
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