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MHRA - Template Letter for EU Article 120 Extension Confirmation


In a continuous effort to ensure the smooth regulation of medical products in the United Kingdom, the Medicines and Healthcare products Regulatory Agency (MHRA) has recently made updates to its guidance and template letter pertaining to the EU Article 120 extension confirmation. These updates aim to provide clarity and streamline the process for pharmaceutical companies seeking an extension for marketing authorization in the UK.

Understanding the EU Article 120 Extension

The EU Article 120 extension is a regulatory provision that allows marketing authorization holders to request an extension for certain medicinal products in cases where they are unable to meet the required post-authorization data obligations. This extension, if granted, allows the pharmaceutical companies to continue marketing and distributing their products in the UK market beyond the initial authorization period while fulfilling their data obligations.

MHRA's Updated Guidance

The MHRA's updated guidance is a comprehensive document outlining the requirements and procedures for companies seeking an EU Article 120 extension confirmation. The guidance covers essential aspects such as eligibility criteria, the application process, and the documentation needed for a successful extension request.

  1. Eligibility Criteria: The guidance clearly defines the types of medicinal products that may be eligible for an EU Article 120 extension. It also highlights the specific circumstances under which the extension request can be made.

  2. Application Process: The updated guidance provides step-by-step instructions on how to submit an extension request to the MHRA. This includes details on the application form, the necessary supporting documents, and any fees associated with the process.

  3. Deadline and Timing: Companies seeking an extension must be mindful of the deadline for submitting their application. The updated guidance clarifies the timeline for submitting extension requests and emphasizes the importance of adhering to these timeframes.

  4. Assessment and Decision-Making: The MHRA's evaluation process for extension requests is explained in detail in the guidance. This section outlines the factors considered by the agency when making decisions, as well as the possible outcomes of an extension request.

MHRA's Revised Template Letter

In addition to the updated guidance, the MHRA has also introduced a revised template letter that companies can use when applying for an EU Article 120 extension. This template letter aims to standardize the application process and ensure that all essential information is included in the submission.

The template letter includes sections that require the applicant to provide the following details:

  1. 1. Justification: Companies must provide a clear and compelling justification for their extension request, explaining the reasons why they cannot meet their post-authorization data obligations within the specified time frame.

  2. Supporting Evidence: The template letter prompts applicants to attach relevant supporting evidence or data to strengthen their case for an extension.

  3. Compliance Plan: Companies should outline a detailed plan on how they intend to fulfill their data obligations during the extended period.

Benefits of the Updates

The MHRA's recent updates to the guidance and template letter offer several benefits for both pharmaceutical companies and regulatory authorities:

  1. Clarity and Transparency: The updated guidance provides clearer instructions and requirements, reducing confusion and ambiguity surrounding the extension application process.

  2. Efficiency: Standardizing the application process with the template letter enables faster and smoother evaluations, allowing companies to receive timely decisions on their extension requests.

  3. Continued Access to Medicines: The EU Article 120 extension allows patients in the UK to maintain access to critical medicines, even if some post-authorization data obligations cannot be met immediately.


The MHRA's commitment to continuously improve its regulatory processes is evident through the recent updates to the guidance and template letter for EU Article 120 extension confirmation. These updates streamline the application process, enhance transparency, and ultimately contribute to the sustained availability of essential medicinal products in the UK market. Pharmaceutical companies should closely follow the new guidance and utilize the revised template letter to ensure a seamless extension request submission and maximize their chances of a successful outcome.

Template Letter for EU Article 120 Extension Confirmation

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