Key Points for China Pharmacovigilance Inspections

by Grace Wang Apr 21, 2022

On April 15, China National Medical Products Administration (NMPA) issued the Pharmacovigilance Inspection Guidelines with immediate effect. The Guidelines lists key points for national and provincial medical products administrations to carry out pharmacovigilance inspections.1

The key points include the inspections' items and methods, which are worth the attention of marketing authorization holders (MAHs) for fulfilling pharmacovigilance responsibilities.

RELATED: China Implements Good Pharmacovigilance Practices;

Decoding China's Good Pharmacovigilance Practices (GVP).

1. What is Pharmacovigilance?

Pharmacovigilance refers to the monitoring, identifying, evaluating and control of adverse drug reactions (ADRs) and other negative reactions related to medication.2

In China, pharmacovigilance is also a legal obligation of drug MAHs and applicants since the GVP came into force in December 2021. An MAH can entrust pharmacovigilance activities to a third party but the MAH is still the main legal entity to bear the liability.

2. What Does the Pharmacovigilance Inspection Guidelines Apply to?

The Guidelines applies to inspections of pharmacovigilance activities conducted by the MAH itself or by an entrusted third party.

The Guidelines can also be a reference for inspections for pharmacovigilance activities of drug applicants who have been authorized to carry out clinical trials and applicants who are applying for marketing authorization.

3. What Kind of MAHs Will Receive Special Attention in Routine Inspections?

In routine inspections, inspectors will pay special attention to MAHs with any of the following characteristics:

  • The MAH owns numerous drug products with high sales.

  • The MAH has never received a pharmacovigilance inspection before.

  • The MAH has obtained drug marketing authorization in China for the first time.

  • The MAH is experiencing a merger or structural change, leading to a major change in the pharmacovigilance system or significant influence on the pharmacovigilance organization's structure. 

  • The MAH has entrusted manufacturing activities to a third party.

  • The MAH has entrusted pharmacovigilance activities to a third party.

4. How and Where Will the Inspections Take Place?

Pharmacovigilance inspections take place in two forms:

  1. On-site inspection;

  2. Remote inspection via phone, video, etc.

Inspections sites are mainly where the MAHs carry out critical pharmacovigilance activities. When necessary, inspections will also cover sites where the entrusted pharmacovigilance activities are conducted.

5. Pharmacovigilance Inspection Items and Deficiency Levels

NMPA lists 100 pharmacovigilance inspection items in 28 categories. The deficiencies are classified into three levels:

  1. 12 items that could be evaluated as with severe deficiency;

  2. 40 items that could be evaluated as with major deficiency;

  3. 48 items that could be evaluated as with moderate deficiency.

An MAH's pharmacovigilance compliance will hinge upon the deficiency levels. An MAH will be evaluated as not complying with requirements if it meets any of the following conditions:

  • One or more items have severe deficiencies;

  • 10 or more items have major deficiencies, and no items have severe deficiency;

  • 0-9 items have moderate deficiencies and no items have severe deficiency. The number of total deficient items exceeds 25.

The following table lists the 28 categories of pharmacovigilance inspection items. 


Category of Pharmacovigilance Inspection Items

1. Personnel and Resources


Drug Safety Committee: e.g. if the MAH has established such a committee; if the committee has clear and reasonable responsibilities.


Pharmacovigilance Department: e.g. if the MAH has launched such a special department.


Relevant Departments: if the MAH has assigned pharmacovigilance responsibilities to other departments (perhaps involving R&D, manufacturing, sales, marketing, quality assurance & control, etc.)


Responsible Person for Pharmacovigilance


Special Staff for Pharmacovigilance


Personnel Training


Devices and Resources

2. Quality Management and Document & Record


Quality Management System


Internal Review of the Pharmacovigilance System


Management of Documents about Systems and Procedures


Pharmacovigilance Master Files


Records and Data Management


Entrusted Management: e.g. whether the MAH has evaluated the entrusted party's pharmacovigilance conditions and capabilities, whether the two parties have signed agreements in paper, etc.


Information Registration and Updates, e.g. if the MAH has registered the drug information and updated the drug label in the National ADR Monitoring System.

3. Monitoring and Report


Approaches to Collecting ADR Information


Handling of ADR Information


ADR Evaluation and Report


Enhancing Post-market Monitoring

4. Risk Identification and Evaluation


Monitoring of ADR Signals


Signal Analysis and Evaluation


Risk Assessment


Post-market Safety Research


Periodic Safety Update Report (PSUR)/Periodic Benefit-Risk Evaluation Report (PBRER)

5. Risk Control


Risk Management


Risk Control Measures


Risk Communication


Pharmacovigilance Plan


Investigation and Handling of Intensive Adverse Events (AE)

6. Related Webinar

ChemLinked BaiPharm Webinar: Decoding China's Good Pharmacovigilance Practices (GVP)

Contact BaiPharm if you'd like to know more about pharmacovigilance in China.

Grace Wang
ChemLinked Regulatory Analyst & Editor
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