If your company plans to manufacture medicinal products in Ireland, or import them from a third country into Ireland, you will typically need to establish the relevant manufacturing or import authorisation before those activities begin. In most cases, that means securing a Manufacturer’s/Importer’s Authorisation (MIA) from the Health Products Regulatory Authority (HPRA). The requirement itself is straightforward; the application process is less well understood, particularly by companies applying for the first time. This article sets out the MIA requirements, what the application process actually involves, and what realistically affects the MIA timeline.

What an MIA Authorises

A Manufacturer’s/Importer’s Authorisation is the authorisation issued by HPRA that permits a company to manufacture medicinal products in Ireland and/or import them from outside the European Economic Area (EEA). It is often referred to informally as an “MIA licence,” although HPRA and EU legislation use the term “authorisation” rather than “licence.”

Under HPRA’s Irish framework, authorisations are grouped into three categories, depending on the products involved:

Each authorisation is specific to the named site, the activities carried out there, and the products covered. Changes to the authorised site, activities or scope may require a variation to the existing authorisation, rather than a new application, depending on the nature of the change.

Why an MIA Is Required

The requirement for a manufacturing authorisation is set out in EU legislation, not simply industry convention. Directive 2001/83/EC requires Member States to ensure that the manufacture of medicinal products within their territory is subject to an authorisation. This requirement applies equally to products imported from third countries into a Member State.

This is a legal requirement, not a matter of best practice. A company that manufactures medicinal products in Ireland, or imports them from outside the EEA, without a valid MIA is operating outside the legal framework, regardless of how well its facilities or systems perform in practice.

It is worth being precise about what the MIA covers, because it is often confused with related but distinct regulatory activities:

Holding an MIA does not mean a batch has been certified or released. It means the site and its holder are authorised to carry out the relevant manufacturing or importation activity. This authorisation is one of the preconditions for certification and release to happen at all. We’ve covered the certification and release stages separately in our guide to QP certification and batch release.

MIA Application Requirements

Under Directive 2001/83/EC, an applicant for a manufacturing authorisation must, at minimum:

These are the legal minimums. In practice, HPRA will expect to see a broader set of practical preparations already in place, or close to finalised, including:

These preparatory expectations are not themselves listed in Article 41. They reflect what is generally needed in practice to satisfy the legal requirements above and to be ready for HPRA’s assessment.

For companies specifically applying for an authorisation to import from outside the EEA, EU GMP Annex 21, in force since 21 August 2022, sets out the GMP expectations that apply to MIA holders carrying out importation activities. This is a distinct annex from Annex 16, which concerns certification by a Qualified Person and batch release. The two are often referenced together because they sit close together in the supply chain. However, they address different regulatory activities, and an application should not conflate the two.

The HPRA MIA Application Process

HPRA structures new MIA applications around a pre-submission process rather than accepting applications cold.

1. Pre-submission meeting. Companies intending to apply for an MIA within the next six months are advised to request a pre-submission meeting with HPRA’s Compliance department, using HPRA’s dedicated request form. This meeting is held with HPRA’s inspection team and gives the company an opportunity to present its planned manufacturing or importation activities and raise questions about what needs to be in place.

2. Readiness confirmation. Based on that discussion, HPRA will issue the formal MIA application form once it has confirmed the company is likely to be ready for inspection within four to six weeks. This step exists specifically to avoid applications being submitted, and inspections scheduled, before a site is genuinely prepared.

3. Application submission. The company completes and submits the application, along with supporting documentation covering the site, its activities, and the nominated Qualified Person.

4. GMP inspection. HPRA’s inspection team assesses the site against the relevant Good Manufacturing Practice requirements for the activities applied for. For an importation-focused application, this will include assessment against the requirements in Annex 21.

5. Outcome and any follow-up. Depending on the inspection findings, HPRA may request further information, corrective action, or evidence of remediation before an authorisation is granted. HPRA does not routinely issue hard-copy authorisations. Granted MIAs are recorded on the EudraGMDP database, where their validity can also be verified.

For companies that want to discuss facility design at an earlier stage, particularly where a new site is being built or substantially upgraded, HPRA also facilitates earlier regulatory review meetings with its GMP inspectors, separate from the formal pre-submission process.

What Affects the Timeline

HPRA does not publish a fixed, guaranteed turnaround time for new MIA applications, and any figure quoted without qualification should be treated with caution. What HPRA does confirm is the shape of the process rather than a single overall duration:

In practice, the main variables that influence how long an application takes, and the points where delays most often arise, are:

Because these factors vary from one application to the next, there’s no fixed industry-wide duration to assume in advance. The pre-submission stage is generally where a company gets its clearest indication of timing. Addressing the points above before requesting that meeting, rather than during it, is generally the most effective way to keep the process on track.

How MIA Authorisation Fits the Wider Picture

An MIA is a starting point, not an end point. Once a site holds a valid authorisation covering the relevant manufacturing or importation activity, batches can then proceed through Qualified Person certification and, ultimately, batch release. For imported products specifically, EU GMP Annex 21 states that QP certification or confirmation of a batch takes place only after physical importation and customs clearance into the customs territory of an EU/EEA state. The site carrying out that importation must hold the appropriate MIA.

For a company weighing up how to structure EU market access, the practical reality to plan around is this sequence: MIA authorisation, then certification, then release — whether the MIA involved is the company’s own or one it accesses through an authorised partner.

How We Can Help

Not every company needs, or wants, to establish and hold its own MIA. Inglasia holds its own Manufacturer Importation Authorisation. Our EU pharmaceutical importation and MIA services manage imports under that authorisation on behalf of clients, for products and importation activities within its scope. This can allow a company to access a compliant EU import route without establishing and maintaining its own MIA.

This route doesn’t remove the regulatory picture described above. It simply changes who holds the authorisation. HPRA’s requirements for importation still apply, and QP certification and batch release still follow the same sequence. Responsibilities such as those of the Marketing Authorisation Holder remain with the client company. Whether this route or your own MIA is the better fit depends on your products, volumes and longer-term plans for the EU market.

We are not the regulator and cannot influence HPRA’s assessment of any authorisation, whether it’s ours or a company’s own application. If you’d like to talk through which route suits your situation, contact our team.

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