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Registrar Corp
Hampton, Virginia (HQ), Shenzhen, China, London, United Kingdom, Paris, France, Madrid, Spain, Hyderabad, India, Kuala Lumpur, Malaysia, Tel Aviv, Israel, Guatemala City, Guatemala, Cape Town, South Africa
A global FDA compliance firm assisting businesses in the food, medical device, drug, and cosmetic industries with registration, U.S. Agent services, labeling, and regulatory software solutions.
MedEnvoy Global
The Hague, Netherlands, London, United Kingdom, United States, Switzerland, Australia
A global regulatory compliance partner specializing in in-country representation (EC Rep, UKRP, CH Rep, US Agent) and independent importer services for medical device and IVD manufacturers. We help companies navigate complex regulations in Europe, the UK, Switzerland, and the US while maintaining supply chain flexibility.
KoBridge Co Ltd
Seoul, Korea, Lausanne, Switzerland
We offer fast, effective, and flexible solutions for medical device manufacturers needing to navigate the increasing complexity of global regulations. Their core competencies cover CE Marking, FDA 510(k)/PMA, MDSAP, and especially Korea MFDS registration and KGMP compliance. They handle active, non-active, combination, and animal-origin devices, providing services from strategic planning and dossier preparation to quality system implementation (ISO 13485) and audits.
IMed Consultancy Ltd
United Kingdom, Ireland
Helping medical device and in-vitro diagnostic companies with CE marking, quality management systems, auditing, and global registrations.
October 1, 2025
Approximately 5 minutes
Variations to Marketing Authorisations (MAs) in the UK
Variations to Marketing Authorisations (MAs) in the UK
1. What is a Variation
A variation is a formal change to the terms or conditions of an existing marketing authorisation (MA) for a medicinal product. Variations ensure that the authorised product’s regulatory documentation remains up to date with current scientific, quality, safety and efficacy information.
Source: Variations to marketing authorisations (MAs) - GOV.UK
2. Regulatory Framework
In the UK, the Medicines and Healthcare products Regulatory Agency (MHRA) oversees the assessment and approval of variations to MAs, applying national procedures that reflect the UK’s regulatory independence. Variations may be submitted as direct national applications or through the International Recognition Procedure (IRP).
Source: Variations to marketing authorisations (MAs) - GOV.UK
3. When to Apply for a Variation
Changes requiring a variation include, but are not limited to:
- Updates to product labelling or packaging;
- Modifications to the manufacturing process;
- Changes to safety information or pharmacovigilance requirements; and
- Administrative updates such as company name or address.
These changes must be formally assessed unless they fall under specific minor “do-and-tell” procedures.
Source: Guidance: apply for a variation to your marketing authorisation
4. Classification of Variations
4.1 Minor Variations
Minor variations are changes that do not significantly impact the quality, safety or efficacy of the product. They are divided into:
- Type IA: Changes with minimal impact, where notification can occur after implementation; and
- Type IB: Minor changes that require prior approval by the MHRA before implementation.
Source: Guidance: apply for a variation to your marketing authorisation
4.2 Major Variations
Major variations (Type II) are more substantial changes that may significantly affect product quality, safety or efficacy. Examples include:
- New therapeutic indications;
- Substantial changes to manufacturing; or
- Significant alterations to clinical data supporting the MA.
These require full assessment and approval before implementation.
Source: Guidance: apply for a variation to your marketing authorisation
5. Submission and Assessment
Variation applications are submitted to the MHRA using the relevant application form and dossier. Depending on the category (minor or major), different supporting information and timelines apply.
For example, Type IB and Type II applications typically follow assessment periods that can vary depending on complexity, urgency and whether further information is requested by the MHRA.
Source: Guidance: apply for a variation to your marketing authorisation
6. Grouping and Bulk Submissions
The MHRA guidance also includes advice on grouping multiple variations within a single application, and submission strategies for bulk changes across one or more products. This can improve efficiency when several related changes are needed.
Source: Example guidance on groupings (MHRA)
7. Summary
In summary, variations to marketing authorisations in the UK are formal regulatory processes that allow changes to existing medicinal product licences. All variations must be classified appropriately—either minor (Type IA/IB) or major (Type II)—and submitted with supporting information to maintain compliance with UK medicinal product standards.
Source: Variations to marketing authorisations (MAs) - GOV.UK
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