EU-GMP Consultancy

EU-GMP readiness without improvisation.

We support medical cannabis producers and operators in building and reviewing quality systems, GMP documentation, batch records, Site Master File, CAPA, change control, qualification, and validation to prepare for inspections, European buyers, and regulated markets.

No certification promises. Technical evaluation of readiness status.

EudraLex Volume 4

Annex 7 · Annex 11 · Annex 15

QMS, validation, audit readiness

Self-assessment

How aligned is your operation with EU-GMP?

Six questions covering QMS, documentation, and quality control. A structured diagnostic before your first inspection or buyer audit.

6 questions, around 5 minutes
Personalised PDF report with archetype classification and gap analysis
Optional 30-minute review call with a Clear consultant

We collect your email at the halfway point. Privacy policy.

PREVIEW
Your Report
Foundation
CoverageYou
Maturity
Optimisation
Pages3
FormatPDF
Time5 min

Methodology

Built on real audit experience.

Based on EudraLex Volume 4 and EU pharmaceutical manufacturing directive. Clear's consultants are IRCA-qualified with direct experience across European GMP inspections for medical cannabis manufacturers.

Sample

The questions that matter.

Do you have a formally documented Quality Management System covering all critical manufacturing processes?

Are your batch manufacturing records complete, legible, and retained in accordance with EU-GMP requirements?

Has your site undergone a self-inspection programme or mock inspection in the last 12 months?

5 archetypes

Where you stand. What you can do.

Foundation

First stages of the compliance journey. Basic systems and documentation not yet formally in place.

Coverage

Compliance frameworks in progress, with partial implementation. Gap analysis and prioritisation are the main focus.

Maturity

Mature systems with specific gaps remaining. Targeted remediation to close priority observations.

Optimisation

Near full compliance with refinement needs. Audit readiness and continuous improvement as the next horizon.

Next steps

A report, then options.

Right after submission

  • Your 3-page PDF report delivered to your email
  • Archetype classification with detailed reasoning
  • Concrete next steps tailored to your position

If you want to discuss

  • Optional 30-minute call with a Clear consultant
  • No commitment, no sales follow-up unless requested
  • Schedule directly via Zoom Scheduler

Recognition

These six situations indicate that GMP readiness needs attention.

01

SOPs exist but lack version control, are out of date, or get applied inconsistently across the team.

02

Batch records are filled in by production but never formally reviewed or reconciled.

03

Deviations are managed informally, without root cause analysis, CAPA, or closure.

04

Qualification and validation documentation is incomplete, in draft, or missing entirely.

05

Data integrity has never been formally assessed and nobody tracks audit trail status.

06

Nobody has a clear picture of what the next competent authority inspector will examine.

The problem

GMP is proven with a quality system that withstands inspection.

Many medical cannabis operations arrive late to the problem: facility already built, production started, SOPs written quickly, partial training, incomplete batch records, open validation, deviations and CAPA managed informally.

The risk extends across documentary, commercial, regulatory, and financial dimensions: critical inspection findings, lost buyers, delayed exports, immobilised capital, teams under pressure. The gaps surface at the worst possible moment.

What looks compliant

What inspection actually needs

SOPs exist on the shared drive

SOPs are controlled, current, applied, and trainable

Batch records are filled in by production

Batch records are reviewed, consistent, and reconciled

Equipment is installed and running

Equipment is qualified through DQ, IQ, OQ, PQ with documentation

Deviations are handled when they happen

Deviations are logged, investigated, and linked to CAPA

The team knows the procedures

Training is documented, current, and connected to roles

Cleaning is performed regularly

Cleaning is validated and records support the validation

Inspection focus

What inspectors look at.

Competent authority inspectors assess six core areas. Each one requires documented evidence on the table.

01

Document control

SOPs are controlled, version-numbered, current, and held by trained personnel who apply them.

02

Batch record review

Records are complete, consistent, reconciled, and formally reviewed and approved before release.

03

Qualification and validation

Equipment, utilities, processes, and computerised systems are validated with lifecycle documentation.

04

Deviation and CAPA management

Problems are detected, logged, investigated, root-caused, actioned, and formally closed.

05

Data integrity

Records are original, accurate, complete, and legible. Audit trails are active and periodically reviewed.

06

Training and competence

Personnel competency is documented, current, and traceable to assigned roles and responsibilities.

Scope clarification

This page covers the pharmaceutical phase.

GACP covers the cultivation and harvest of the botanical raw material. EU-GMP covers what happens once that raw material enters a manufacturing environment: processing, extraction, packaging, quality control, documentation, QMS, and release.

Dimension

GACP

EU-GMP

Scope

Cultivation, harvest, primary processing of botanical raw material

Manufacturing, extraction, packaging, QC, release of medicinal products

Regulatory frame

Good Agricultural and Collection Practices (EMA)

EudraLex Volume 4, applicable Parts and Annexes

Documentation

Cultivation records, batch traceability of raw material

Site Master File, batch records, QMS, validation, change control

Quality system

Quality controls focused on agronomic and harvest steps

Pharmaceutical QMS covering all manufacturing stages

Inspection

Buyer audits, GACP certification bodies

Competent authority inspection, GMP certificate

If your operation is upstream of manufacturing, see our GACP consultancy.

Who it is for

Find your scenario.

Each starting point leads to an engagement calibrated to that specific situation.

Facility under construction

Design layout, flows, equipment, and QMS with EU-GMP logic before structural mistakes lock in cost.

Operating producers

Production runs but the quality system is informal. Move toward an auditable structure.

Incomplete or weak SOPs

Documents exist but lack control, training links, and connection to batch records.

Pre-inspection companies

Approaching the first EU-GMP inspection. Need a documented readiness state.

Post-inspection observations

Findings open from a previous inspection. Need a structured, defensible CAPA response.

Exporters and premium suppliers

Already exporting, but selective European buyers require stronger QMS evidence.

Regulatory framework

Four pillars of the EU-GMP system.

EU-GMP for medical cannabis is structured around EudraLex Volume 4 and its applicable Annexes. Knowing which rules govern which activity is the first step toward a defensible QMS.

EudraLex Vol. 4: Parts I and II

Core GMP requirements

Part I covers medicinal products for human use. Part II covers APIs. Together they define QMS, personnel, premises, equipment, documentation, production, and QC requirements.

Annex 7

Herbal medicinal products

The Annex specifically applicable to cannabis-derived products. Governs starting material specifications, cultivation, harvesting, processing, and quality control of herbal substances.

Annex 11

Computerised systems

Governs all digital systems used to create, modify, or store GMP-relevant data. Drives data integrity requirements, audit trails, access controls, and computerised system validation.

Annex 15

Qualification and validation

The framework governing the validation lifecycle: design qualification, installation, operational, performance qualification, process validation, cleaning validation, and change control.

What we do

EU-GMP services that turn processes into an auditable QMS.

Three areas of intervention, twelve services. We can work on a single area or run the full path to readiness.

Area A

Diagnosis

EU-GMP gap analysis

Map the current state of QMS, documentation, facility, and operations against applicable Parts and Annexes.

Site Master File review

Strengthen or build the key document describing the site, activities, QMS, and responsibilities.

EU-GMP due diligence

Risk evaluation for investors, boards, or M&A: gaps, certifiability, timelines, and cost exposure.

Area B

QMS and documentation

QMS setup or review

Structure a quality system aligned with production, QA, QC, document control, and clear responsibilities.

SOP creation and remediation

Transform generic SOPs into controlled, applicable, and trainable operating procedures.

Batch record design or review

Improve traceability, consistency, and batch review across manufacturing stages.

Deviation, CAPA, OOS

Build a system that manages quality problems in a traceable and defensible way.

Change control

Avoid unevaluated changes to processes, equipment, facility, computerised systems, and documents.

Area C

Validation and readiness

Qualification and validation

Support across equipment, utilities, processes, cleaning, and computerised systems through the validation lifecycle.

Annex 11 readiness

Review of digital systems: data integrity, access controls, audit trails, backups, periodic review, validation.

Audit readiness

Mock audit, evidence pack, team preparation, and inspector-question simulation.

Post-inspection CAPA plan

Structured response to observations and non-conformities with a defensible roadmap.

Not sure which areas you need?

The gap analysis identifies that. Start there.

How we work

From gap to readiness.

Seven steps with defined outputs at every stage. You always know where we are and what comes next.

01

GMP Discovery

Collect information on site, activities, target markets, regulatory status, processes, documents, systems, and urgencies.

02

Gap analysis

Map the current state against applicable EU-GMP requirements. Document review plus on-site assessment.

03

Risk-based action plan

Classify gaps by criticality, regulatory impact, and priority. Build the sequenced roadmap.

04

QMS and documentation remediation

Build or revise SOPs, records, Site Master File, training, deviation, CAPA, OOS, and change control.

05

Qualification and validation

Support on equipment, cleaning, computerised systems, process validation, and other relevant areas.

06

Audit readiness

Mock audit, checklist, evidence pack, team training, and preparation for inspector questions.

07

Follow-up support

Possible management of observations, CAPA execution, and remediation after inspection.

What you receive

Twelve concrete deliverables.

Operational documentation ready for use in your specific context.

Quality system foundation

Gap analysis report scored by EU-GMP dimension

Risk-classified gap register (critical, major, minor)

Risk-based remediation roadmap with ownership and timeline

Site Master File aligned with EudraLex Volume 4

Documentation and data integrity

SOP master list and updated procedure library

Batch record templates fit for the operation

Training matrix and competency records

Deviation log and CAPA plan

Change control procedure and documentation

Inspection and validation

Cleaning procedures and cleaning validation framework

Validation master plan

Audit readiness checklist and evidence pack

Authority

EU-GMP expertise applied to medical cannabis reality.

The convergence of botanical raw material, pharmaceutical processes, quality control, traceability, and regulated-market requirements demands more than generic GMP knowledge.

EU-GMP approach grounded in EudraLex Volume 4, Part I, Part II, Annexes 7, 11, and 15

Chapter 4 documentation discipline applied across QMS, training, and batch records

Annex 11 readiness with focus on data integrity, audit trails, and computerised system validation

Annex 15 qualification and validation lifecycle support

Experience across production, extraction, packaging, QC, import, and release

Continuous regulatory monitoring of EMA, EDQM, and competent authorities

Frequently asked questions

Questions we hear most often.

If you manufacture, process, extract, package, perform quality control, or release medicinal products intended for the European market, the general principle is that the manufacturer must comply with European GMP requirements, even when located outside the EU. A short technical call is the fastest way to determine which Parts and Annexes are applicable to your specific scope.

Before facing buyers, inspections, or investors, verify the strength of your EU-GMP system.

Request a gap analysis to understand the real state of your QMS, identify critical gaps, and build a realistic path toward readiness.

Book a technical GMP call