Guides

Regulatory Watch, October 2026

Five regulatory events from October 2026. For each one: what happened, and what to check in your own Quality Management System.

Updated · 4 min read

In 30 seconds

  1. 1Averaging a failed result is not an investigation
  2. 2Your contract laboratory's data is your data
  3. 3A repeat finding is a CAPA that did not work
  4. 4EU Annex 11 has not changed yet
  5. 5New EU GMP rules for veterinary medicines
Class I recall

FDA Warning letter · 5 October 2026

1Averaging an out-of-specification result is not an investigation

2020No stability study reports since then

What happened

  • Microbiological tests on component lots failed for yeast and mold in November 2025.
  • The firm did not investigate. FDA writes that it "invalidated the OOS results by averaging".
  • The lots were released and used. A customer later started a Class I recall for potential fungal contamination.
  • The corrective action did not work. FDA also found annual product reviews missing since 2024.

Check in your QMS

  • Can anyone close an out-of-specification result without a documented root cause?
  • Does every CAPA carry an effectiveness check, with a date and a measurable criterion?
  • Does someone see when an annual product review or a stability report is late?

Letter 320-27-04 to Silgan Dispensing Systems, for its site in Spokane, Washington. It cites 21 CFR 211.192 and 211.22. Read the letter

Since Feb 2025

FDA Warning letter · 6 October 2026

2Your contract laboratory's data is your data

0 CFURecorded on a plate where the investigator found a colony

What happened

  • A contract laboratory recorded only passing plate counts. Results too numerous to count were left out.
  • Cracked and dried-out plates were recorded as 0 CFU and discarded without a second review.
  • The laboratory found that this selective recording went back to February 2025.
  • FDA rejected its response: it did not say whether certificates sent to customers were affected.

Check in your QMS

  • Does each of your contract laboratories have a quality agreement and a current audit?
  • Does that audit look at raw data, or only at certificates of analysis?
  • If a laboratory reports a data problem, do you record a deviation that names your batches?

Letter 320-27-05 to Eurofins SF Analytical Laboratories, for its site in Horsham, Pennsylvania. It cites 21 CFR 211.194(a), 211.192 and 211.22. Read the letter

Repeat finding

FDA Warning letter · 2 October 2026

3A repeat finding is a CAPA that did not work

"Repeated failures demonstrate that executive management oversight and control over the manufacture of drugs is inadequate."

FDA, letter 320-27-03

What happened

  • FDA cited a sterile drug maker for aseptic practice, contamination control and its quality unit.
  • An earlier warning letter, 320-19-01, had cited similar violations at the same site.

Check in your QMS

  • When you close a CAPA, does anything check later that the problem has not come back?
  • Can you list your past inspection observations, each with the CAPA that answered it?
  • Does management review see repeat deviations and repeat audit findings?

Letter 320-27-03 to Hanlim Pharm, for its site in Yongin, South Korea. It cites 21 CFR 211.113(b), 211.42(c), 211.110(a) and 211.22. Read the letter

Still 2011

EU EU GMP Guide · checked 1 November 2026

4In Europe, Annex 11 and Chapter 4 have not changed yet

2011The versions of Annex 11 and Chapter 4 still in force

What happened

  • The EU GMP Guide still lists Annex 11 (computerized systems) and Chapter 4 (documentation) in their 2011 versions.
  • It lists no Annex 22 on artificial intelligence yet.
  • Drafts of all three were open for public comment from 7 July to 7 October 2025.

Check in your QMS

  • Your computerized systems are still inspected against the 2011 Annex 11.
  • Read the drafts now. They show what inspectors will ask for once the new texts apply.
  • If you use artificial intelligence in a GMP process, list where.

EudraLex Volume 4, the EU GMP Guide. Open the guide · Read the drafts

In force

EU EU GMP Guide · checked 1 November 2026

5New EU GMP rules for veterinary medicines

16 JulyThe day both regulations started to apply, in 2026

What happened

  • Regulation (EU) 2025/2091 lays down good manufacturing practice for veterinary medicinal products.
  • Regulation (EU) 2025/2154 does the same for their active substances.

Check in your QMS

  • If you make veterinary medicines for the EU market, do your procedures cite these two regulations?

Regulation (EU) 2025/2091 · Regulation (EU) 2025/2154

Regulatory Watch summarizes public documents. It is not legal or regulatory advice.