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Recommendation on HMA Article 5 on unforeseen variations

  • Writer: Jeremy Jakob
    Jeremy Jakob
  • Mar 9, 2023
  • 1 min read


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Recommendation on HMA Article 5 on unforeseen variations

Art.5 on Unforeseen Variations

See guidance on when to follow an Article 5 procedure:

  • All Article 5 recommendation are published under http://www.hma.eu/293.html

  • The CMD(h) would remind applicants that the default position is a Type IB variation

  • If the specific change is not listed. Is change covered by any of the high-level scopes?

    • YES: Type IB by default, use an additional box using the sub-indent ‚z‘

    • NO: Would you recommend to classify as a Type IA?

      • NO: Submit as a Type IB by default or as a Type II (safeguard clause)

      • YES: Follow Article 5 recommendations


As a summary, Article 5 is to be followed only if change is not listed and a Type 1A would be recommended

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