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Pharmacovigilance requirements in Montenegro

In Montenegro, Pharmacovigilance is regulated by the Agency for Medicines and Medical Devices (CALIMS). The system is robust and fully aligned with EU Good Pharmacovigilance Practices (GVP) as part of the country's EU accession process.

1. Clinical Safety (Clinical Trials)

Clinical trials are strictly regulated under the Law on Medicines and aligned with EU Regulation 536/2014 principles.

  • Expedited Reporting: Sponsors must report Suspected Unexpected Serious Adverse Reactions (SUSARs) to CALIMS:

    • Fatal or Life-Threatening: Within 7 calendar days.

    • Other Serious Unexpected: Within 15 calendar days.

  • Periodic Reporting: Development Safety Update Reports (DSURs) are mandatory annually (ICH E2F format).

  • Oversight: Sponsors are responsible for causality assessment and reporting to CALIMS and Ethics Committees.

2. Post-Marketing Pharmacovigilance

Post-approval obligations mirror EU standards, requiring strict compliance and local oversight.

  • Personnel:

    • QPPV: A Qualified Person for Pharmacovigilance is mandatory.

    • Local Contact: If the QPPV resides outside Montenegro (e.g., in the EU), a Local Contact Person residing in Montenegro is required for liaison with CALIMS.

  • Documentation: A Pharmacovigilance System Master File (PSMF) is mandatory (EU GVP Module II) and must be available for CALIMS inspections.

  • Incident Reporting (ICSRs):

    • Serious Cases: Report within 15 calendar days.

    • Non-Serious Cases: Report within 90 calendar days.

    • Submission: Electronic reporting via E2B(R3) is preferred.

  • Risk & Periodic Reporting:

    • PSURs: Submitted in ICH E2C(R2) format. Typically every 6 months (first 2 years), then annually.

    • RMPs: Mandatory for new active substances and high-risk products (EU GVP Module V).

    • Additional Monitoring: The Black Triangle (▼) scheme applies to new or high-risk medicines.

Summary of Requirements

Component Requirement in Montenegro
Regulatory Authority CALIMS (Agency for Medicines and Medical Devices)
Framework EU GVP Aligned / Law on Medicines
Local Personnel QPPV (Mandatory) + Local Contact (if QPPV foreign)
PSMF Required
SUSAR Reporting 7 days (fatal) / 15 days (other serious)
ICSR Timelines 15 days (serious) / 90 days (non-serious)
RMPs Mandatory (EU Style)
Special Monitoring Black Triangle (▼) Scheme applies

For clinical trials pre-marketing: Sponsor must have a local person in the country that forwards the safety reports to the Agency.

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