Recommendation on HMA Article 5 on unforeseen variations
- Jeremy Jakob
- Mar 9, 2023
- 1 min read

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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