Facility under construction
Design layout, flows, equipment, and QMS with EU-GMP logic before structural mistakes lock in cost.
EU-GMP Consultancy
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
Six questions covering QMS, documentation, and quality control. A structured diagnostic before your first inspection or buyer audit.
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Methodology
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
“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
First stages of the compliance journey. Basic systems and documentation not yet formally in place.
Compliance frameworks in progress, with partial implementation. Gap analysis and prioritisation are the main focus.
Mature systems with specific gaps remaining. Targeted remediation to close priority observations.
Near full compliance with refinement needs. Audit readiness and continuous improvement as the next horizon.
Next steps
Recognition
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SOPs exist but lack version control, are out of date, or get applied inconsistently across the team.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
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.
Inspection focus
Competent authority inspectors assess six core areas. Each one requires documented evidence on the table.
Scope clarification
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.
If your operation is upstream of manufacturing, see our GACP consultancy.
Who it is for
Each starting point leads to an engagement calibrated to that specific situation.
Design layout, flows, equipment, and QMS with EU-GMP logic before structural mistakes lock in cost.
Production runs but the quality system is informal. Move toward an auditable structure.
Documents exist but lack control, training links, and connection to batch records.
Approaching the first EU-GMP inspection. Need a documented readiness state.
Findings open from a previous inspection. Need a structured, defensible CAPA response.
Already exporting, but selective European buyers require stronger QMS evidence.
Regulatory framework
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.
What we do
Three areas of intervention, twelve services. We can work on a single area or run the full path to readiness.
Area A
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 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
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
Seven steps with defined outputs at every stage. You always know where we are and what comes next.
What you receive
Operational documentation ready for use in your specific context.
Quality system foundation
Documentation and data integrity
Inspection and validation
Authority
The convergence of botanical raw material, pharmaceutical processes, quality control, traceability, and regulated-market requirements demands more than generic GMP knowledge.
Frequently asked questions
Request a gap analysis to understand the real state of your QMS, identify critical gaps, and build a realistic path toward readiness.