Veterinary Biologicals (OCABR/OBPR)
These activities involve the EU/EEA OMCL Network and Mutual Recognition Agreement (MRA) partners countries only.
Background: Veterinary Batch Release Network (VBRN)
The VBRN consists of Competent Authorities and OMCLs from the EU/EEA and any countries with a formal mutual recognition agreement with the EU that includes official batch release e.g. Switzerland via a Mutual Recognition Agreement (MRA). This network is an important forum for the confidential exchange of quality and technical information on immunological veterinary medicinal products (IVMPs) and related methods and is a key link in the regulatory chain. As mandated by the European Commission, the EDQM acts as its secretariat. VBRN is a specific network within the General OMCL Network, thus subject to its operating rules. It is supervised by an elected advisory group consisting of 4 representatives from different member states. A plenary meeting is held annually bringing together all the representatives (their details are available in a contact list) to review the year's activities and to discuss issues concerning the network. This meeting also serves as an opportunity to reconsider the needs for testing different product types and to officially adopt the VBRN procedures and guidelines, which must be approved by all the network's members.
Legal Framework
- Official Control Authority Batch Release (OCABR)
OCABR is based in Regulation (EU) 2019/6, article 128, which repeals article 82 of Directive 2001/82/EC, as amended. The Regulation is applicable as of 28/01/22. Paragraphs 3 to 9 of Article 128 allow, for reasons of human or animal health, a member state to request samples of each batch of a given immunological veterinary product (IVMP) to be submitted to a Competent Authority (CA) for official testing by an OMCL before it is placed on the market and establishes the conditions under which a restricted test list can be applied. This is referred to as OCABR.
OCABR performed by any given member state must be recognised by all other member states requiring OCABR for that product.
- Official Batch Protocol Review (OBPR)
Paragraph 1 of Article 128 Reg (EU) 2019/6 (following the principles of former article 81 of Directive 2001/82/EC as amended) allows a member state to ask a Marketing Authorisation Holder (MAH) to provide documentation to a control authority or an OMCL proving that control tests were carried out in accordance with the methods laid down in the marketing authorisation (MA). This is referred to as an OBPR. A goodwill agreement has been adopted by the VBRN to mutually recognise OBPR certificates between member states provided the procedure and rules codified by the network are followed.
The Procedure
The core administrative procedure for OCABR and OBPR of IVMPs is the "EU Administrative Procedure for Official Batch Release of Immunological Veterinary Medicinal Products in Application of Article 128 of Regulation (EU) 2019/6". This is used by OMCLs when implementing OBPR or OCABR at the national level. It is also intended for use by MAHs. It provides guidance on documents used for communication between MAHs and OMCLs.
- Official Control Authority Batch Release (OCABR)
The steps involved in the OCABR process are summarised below:
The member state informs the MAH that its authorised IVMP is subject to OCABR. Samples of the batch to be released are sent, along with control reports, to an OMCL within the VBRN. If the results are satisfactory, the CA issues an 'Official Control Authority Batch Release Certificate' to the MAH. This certificate means that the batch has been examined and tested by an OMCL in accordance with the OCABR guidelines pertaining to the medicinal product and is in compliance with the approved specifications laid down in the relevant monographs of the European Pharmacopoeia and in the relevant marketing authorisation (MA). The MAH must provide a copy of the OCABR certificate to any other member state where the batch will be marketed and where OCABR is required for the product. The certificate is recognised by all members of the network.
If the results are unsatisfactory, the batch is given a certificate of non-compliance and may not be placed on the market. All members of the VBRN are informed.
A short list of IVMPs for which paragraph 6 of article 128 may be applied using a restricted test list has been agreed upon. This short list is reviewed on a regular basis to ensure it continues to address appropriately product quality and safety needs.
The current list can be found in annex I of the EU Administrative Procedure For Official Batch Release Of Immunological Veterinary Medicinal Products in Application of Article 128 of Regulation (EU) 2019/6.
In order to help MAHs identify contacts for OCABR testing, a list of OMCLs able to provide OCABR certificates for the different products on the short list has been compiled by the VBRN and is available here.
- Official Batch Protocol Review (OBPR)
A similar procedure is applied for OBPR with the difference being that only the completed batch protocols are sent to the competent authority/OMCL for evaluation. If the results are satisfactory, an ‘Official Batch Protocol Review Certificate' is provided to the MAH. The OBPR certificate is recognised by other member states requiring the OBPR procedure. If an OCABR certificate is provided instead it must also be recognised.
If the results are unsatisfactory, the batch is given a certificate of non-compliance and may not be placed on the market. All members of the VBRN are informed.
- OCABR and OBPR Submissions
To facilitate recognition of certificates throughout the EU a Marketing Information Form (MIF) should also be provided to the CA/OMCL when submitting an OCABR or OBPR certificate.
Product Specific Guidelines & Model Protocol Templates
In addition to the procedures, a number of product specific guidelines were developed by the VBRN, in close collaboration with the Commission of the EU, the Veterinary Pharmaceutical Committee and industry. These documents facilitate the implementation of Article 128 of Reg. (EU) 2019/6, and promote mutual recognition by enhancing transparency and mutual confidence. They were initially endorsed at the 18th meeting of the Veterinary Pharmaceutical Committee and adopted by the network. Five model templates for the submission of protocols by the MAH for OCABR/OBPR and fifteen product specific guidelines for OCABR are currently in force.
The procedures and guidelines for running OCABR/OBPR apply equally in all member states. Please see the right-hand menu for further information.
VBRN guidelines and procedures are available exclusively on our website. The complete list is presented in a table from which the files may be downloaded. The guidelines will be updated on an on-going basis as needed. New and revised versions will be placed on the website within one month of their date of entry into force. Users are encouraged to visit the site regularly to ensure they are using the most recent versions. Highlights on recent addition and revision updates can be found in the right-hand menu.
To download the administrative procedures, product-specific guidelines, model protocol templates and MIF, please see:
- Annex IV to the Procedure for the Application of Article 128: VBRN Contact List (updated 05/07/2024)
- List of OMCLs able to provide OCABR certificates (updated 10/07/2024)
- Decision Flowchart for Control Authorities for the Control of IVMPs
- Benefits of official batch control and surveillance for immunological VMPs. Jungbäck et. al. Regulatory Rapporteur, Vol 13, No 4, April 2016
Revised Procedure (in force from 1 July 2022)
New combined format for the Administrative Procedure for Batch Release of IVMPs in Application of Article 128 of Regulation (EU) 2019/6 replacing the formerly separate procedures for OBPR and OCABR
Revised: All Guidelines and model protocol templates (in force from 28 January 2022)
Revised Procedure (in force from 28 January 2022)
EU Administrative Procedure for Application of Official Control Authority Batch Release of Immunological Veterinary Medicinal Products According to Article 128
EU Administrative Procedure for Application of Official Batch Protocol Review of Immunological Veterinary Medicinal Products According to Article 128