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2026-04-137 min read0

2026 Pre-GMP Evaluation Document Simplification and Raw Material Certification Pilot — Practical Guide for Bio SMEs

Korea's MFDS is simplifying pre-GMP evaluation from 11 to 4 document types and launching a raw material certification pilot in 2026. Here's what bio SMEs need to know for practical compliance.

KITIM Consulting Team

Key Changes in MFDS GMP Regulatory Reform for 2026

In 2026, Korea's Ministry of Food and Drug Safety (MFDS) is dramatically simplifying pre-GMP evaluation documentation and launching a raw material manufacturing site certification pilot. For bio SMEs, this opens a dual opportunity: reduced regulatory costs and stronger export competitiveness.

Pre-GMP Submission Documents: From 11 to 4

Previously, pre-GMP evaluation required 11 separate document types, including facility overviews, hygiene standards, quality control manuals, manufacturing control manuals, equipment lists, organizational charts, and process validation reports. The 2026 revision consolidates these into 4 documents: a general site overview, an integrated quality and manufacturing management summary, a key validation summary, and a self-inspection report.

  • 3 documents eliminated: organizational charts (merged into site overview), equipment lists (replaced by on-site inspection), and raw material test certificates (separated into raw material certification)
  • 4 documents merged: three separate standards manuals combined into a single integrated summary
  • Expected impact: average preparation time reduced from 6–8 months to 3–4 months, with greater focus on actual manufacturing capability
  • CDMO Special Act and Export Manufacturing Registration

    Subordinate regulations under the CDMO Special Act are set for implementation in the second half of 2026. A new export-only pharmaceutical manufacturing registration system will allow production for export with GMP certification alone, without requiring domestic marketing authorization. Combined with simplified pre-GMP procedures, this significantly lowers market entry barriers for new CDMO companies.

    Strategies for the Raw Material Certification Pilot

    Pilot Scope and Certification Process

    The raw material manufacturing site certification pilot targets domestic facilities producing active pharmaceutical ingredients (APIs) and key intermediates. The process consists of document review (approximately 60 days), on-site inspection (2–3 days), and certificate issuance (valid for 3 years). During the pilot period, certification fees are reduced by 50%.

    Practical Impact on Finished Product Approvals

    When using raw materials from a certified manufacturing site, documentation related to raw materials is waived during finished product approval review. This typically shortens review timelines by 45–60 days on average — a benefit that compounds for companies producing multiple products from the same API source.

    Global GMP Trends and Domestic Alignment

    The European Medicines Agency (EMA) will tighten API GMP requirements starting December 2026, mandating Written Confirmation of GMP compliance for all APIs distributed within the EU. Korea's raw material certification program is expected to serve as a foundation for mutual recognition arrangements with EMA standards.

    Practical Checklist for Bio SMEs

    Writing Tips for the 4 Simplified Documents

  • General site overview: Include organizational structure and personnel details, with specific qualifications and experience of key quality personnel (QA/QC managers)
  • Integrated quality and manufacturing summary: Consolidate essentials from the previous three manuals — common deficiency reasons include *missing deviation management procedures* and *undocumented change control histories*
  • Key validation summary: Must include 3-batch process validation results and cleaning validation summaries
  • Self-inspection report: Include results from inspections conducted within the past year, along with corrective actions for any non-conformities
  • Transition for Companies with Existing GMP Certificates

    Companies with valid GMP certificates will automatically transition to the simplified format at renewal. However, those scheduled for renewal within 2026 should confirm with MFDS in advance whether the new format applies to their submission.

    Leveraging the Bio Raw Materials User Testing Support Program

    The Ministry of Trade, Industry and Energy's Bio Raw Materials User Testing Support Program (2026 budget: KRW 15.6 billion) covers up to 70% of quality verification costs for domestically sourced raw materials. When combined with the raw material certification pilot, companies can significantly reduce costs from quality verification through certification.

    KITIM Consulting — GMP Certification Advisory and Regulatory Support

    KITIM provides end-to-end consulting from GMP documentation preparation to on-site inspection readiness and raw material certification pilot participation strategy. Our practical support includes submission document coaching aligned with the simplified pre-GMP requirements, mock self-inspections, and validation document reviews to maximize your certification success rate. For expert guidance on GMP certification and bio regulatory affairs, please reach out through KITIM Contact Us.

    Pre-GMP EvaluationDocument SimplificationRaw Material CertificationMFDS Regulatory InnovationBio Quality Management
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