Procedure: Authorized Representative
Country: Global Procedure
Version #: 11/30/2023
Author: Daria Kostiuchenko
Editor: Daria Kostiuchenko
ID: GP-PhR-AR-SR
Category: Pharmaceuticals
Validity: 1 year with optional extension
Certified by: Vlad Reznikov
Copyright: Pattern of USA Inc.
SUMMARY
Legally Authorized Representative (AR, LAR, or US Agent in the United States) is a local person or legal entity appointed by foreign manufacturer to act on their behalf regarding certain regulatory obligations under local regulations as a point of contact for authorities (NRA) and customers, maintaining technical documentation, and handling post-market surveillance including vigilance.

Must-Have Requirements, Recognized Standards, and Certifications:
- POA
Nice-to-have: No requirements
Typical Gaps and Deficiencies: Lack of clear guidelines, inadequate training, poor communication, insufficient monitoring and oversight, conflict of interest, inadequate documentation, inadequate reporting and feedback mechanisms
Implementation Period: Immediately
Deliverables: Legally Established AR
PHASE | TASK | TASK | START | DURATION | Fee | KPI | ||
NUMBER | TITLE | OWNER | W/M/Q/Y | in weeks | 3rd Party | Service | State | |
0 | In-house Pre-Submission Activity | |||||||
0.1 | NDA signing or validation | Executor | week 1 | 1 | ||||
0.2 | Contract Closing | MAH | week 1 | 1 | ||||
0.3 | POA issuance and shipping | MAH | week 1 | 1 | ||||
0.4 | Invoice is sent to MAH and paid | Executor | week 1 | 1 | ||||
0.5 | Legal Document processing | Executor | week 2 | 1 | ||||
0.6 | Legal Document Translations, Notary, and Apostilles | 3rd party | week 2 | 2 | ||||
0.7 | SOW is approved by MAH | Executor | week 4 | 1 | SOW | |||
I | Assignment | |||||||
I.1 | Communication chain setup | Executor | week 5 | 1 | ||||
I.2 | NRA verification | Executor | week 6 | 1 | ||||
I.3 | Update Labeler Code SPL NRA records | Executor | week 6 | 1 | ||||
I.4 | Update Registration SPL NRA records | Executor | week 6 | 1 | NRA records | |||
II | Activity | |||||||
II.1 | Receiving information and documents from NRA | Executor | year 1 | 52 | ||||
II.2 | Emergency communication with NRA and MAH | Executor | year 1 | 52 | ||||
II.3 | Acting as a contact point for compliance activity | Executor | year 1 | 52 | ||||
II.4 | Assisting NRA in scheduling inspections | Executor | year 1 | 52 | ||||
II.5 | Regular communication and reporting to MAH | Executor | year 1 | 52 | Report | |||
III | Discontinuation | |||||||
III.1 | Discontinuation and communication plan development | Executor | TBD | 2 | ||||
III.2 | NRA notification | Executor | TBD+3w | 1 | ||||
III.3 | Deregistration with NRA | Executor | TBD+3w | 1 | ||||
III.4 | Labeler code inactivation | Executor | TBD+3w | 1 | ||||
III.5 | Drugs delisting (with last lot expiration date) | Executor | TBD+3w | 1 | ||||
III.6 | Closeout activities for healthcare providers, patients, etc. | Executor | TBD+18 | 1 | Report | |||
F | Final Phase In-house Post-Authorization Activity | |||||||
F.1 | Service Acceptance Certificate signing | MAH | TBD | 1 | ||||
F.2 | Final Invoice | Executor | TBD | 1 | ||||
F.3 | Final Payment | MAH | TBD | 1 | ||||
F.4 | Contract Termination | Executor | TBD | 1 | ||||
F.5 | Archiving and limiting access | Executor | TBD | 1 | Archiving |
Feel free to submit a Request for Proposal (RFP) for a specific country or territory to info@patternofusa.com