Compliance · The complete guide

EU-M4all

TL;DR

EU-M4all (EU Medicines for all, formerly the Article 58 procedure) is the European Medicines Agency's scientific-opinion procedure under Article 58 of Regulation (EC) No 726/2004 + EU-M4all Guideline (EMA/CHMP/SAWP/89537/2020), allowing EMA's Committee for Medicinal Products for Human Use (CHMP) to provide a scientific opinion on medicinal products — including vaccines + biologics + small molecules + paediatric products + treatments for diseases of major public-health interest — intended exclusively for markets outside the European Union, in cooperation with the World Health Organization (WHO) + the recipient-country National Regulatory Authorities (NRAs). The procedure was originally established in 2004 under the umbrella term 'Article 58' + formally rebranded EU-M4all (EU Medicines for all) in 2020 with updated Guideline + expanded scope to include treatments for non-communicable diseases + paediatric formulations. EU-M4all evaluations follow substantively the same scientific assessment standards as EMA's centralised procedure for EU marketing-authorisation applications — using the same CHMP Rapporteur + Co-Rapporteur model, the same scientific guidelines + the same inspection framework — but result in a CHMP Scientific Opinion (not a marketing authorisation) that supports WHO Prequalification + recipient-country NRA decision-making rather than authorising EU placement on the EU market. The procedure is one of the most rigorous global regulatory frameworks supporting LMIC access to high-quality medicines + has been used for several high-impact products including vaccines for Ebola, malaria, COVID-19 + treatments for HIV, tuberculosis + sleeping sickness.

Reviewed · By V5 Ultimate compliance team· 3,940 words · ~18 min read

01What EU-M4all actually is

EU-M4all (EU Medicines for all, formerly known as the 'Article 58 procedure') is the European Medicines Agency's scientific-opinion procedure under Article 58 of Regulation (EC) No 726/2004 — the foundational regulation establishing EMA + the EU centralised marketing-authorisation procedure. Article 58 was added to the regulation specifically to create a framework where EMA could lend its scientific assessment capability to support medicines intended exclusively for markets outside the European Union, in cooperation with WHO + the recipient-country NRAs. The procedure was originally established in 2004 under the umbrella term 'Article 58' + was formally rebranded EU-M4all (EU Medicines for all) in 2020 with updated EMA Guideline (EMA/CHMP/SAWP/89537/2020) + expanded scope to include treatments for non-communicable diseases + paediatric formulations.

Key structural elements include:

  • CHMP Scientific Opinion — the procedure results in a Scientific Opinion (not a marketing authorisation) issued by EMA's Committee for Medicinal Products for Human Use (CHMP); the Opinion is published + supports WHO Prequalification + recipient-country NRA decision-making.
  • Exclusively non-EU markets — products assessed under EU-M4all are explicitly intended for markets outside the European Union; products that may eventually be marketed in the EU should use the standard centralised procedure.
  • Same scientific assessment standards — EU-M4all uses substantively the same CHMP scientific assessment standards as the EU centralised procedure including the same CHMP Rapporteur + Co-Rapporteur model, the same EMA scientific guidelines + the same EU GMP / GCP / GLP inspection framework.
  • WHO + NRA cooperation — EU-M4all procedure is conducted in cooperation with WHO + the recipient-country NRAs from initial scientific advice through final Opinion + post-Opinion lifecycle.
  • Eligible products — vaccines + biologics + small molecules + paediatric formulations + treatments for diseases of major public-health interest including HIV, malaria, tuberculosis + neglected tropical diseases; expanded post-2020 to include non-communicable diseases.
  • EU manufacturer or non-EU manufacturer eligibility — EU-M4all applications can be filed by EU-established manufacturers OR by non-EU manufacturers (provided they meet specific procedural + GMP requirements).
  • Same fee structure as centralised procedure — substantial fees apply but with EMA + WHO + EC discussions on fee reduction or waiver for high-impact LMIC products.
  • Post-Opinion lifecycle — variations, line extensions, periodic safety update reports + post-Opinion commitments all follow procedurally similar processes to the EU centralised procedure with WHO + NRA involvement.

The procedure has been used for several high-impact products including: Mosquirix (RTS,S/AS01) — the first WHO-recommended malaria vaccine for children + the first EU-M4all-supported vaccine for sub-Saharan Africa use; Ervebo (rVSV-ZEBOV) — the Ebola vaccine used in the 2014-2016 + subsequent West + Central African outbreaks; Comirnaty for LMIC use — the Pfizer-BioNTech COVID-19 vaccine with EU-M4all support for COVAX + LMIC distribution; tafenoquine + several HIV/tuberculosis/sleeping-sickness treatments. EU-M4all has been particularly important for vaccines + treatments where the primary commercial market is LMIC + where WHO Prequalification + reliance by LMIC NRAs are the principal regulatory targets.

02From Article 58 to EU-M4all — history + 2020 rebranding

The procedure has evolved substantially since its 2004 establishment, with the most significant change being the 2020 rebranding from 'Article 58 procedure' to 'EU-M4all' (EU Medicines for all) + accompanying scope + procedural updates.

  • 2004 — Article 58 of Regulation (EC) No 726/2004 establishes the procedure as part of the broader EMA centralised-procedure regulation; initial scope focused on vaccines + medicines for major communicable diseases (HIV, malaria, tuberculosis).
  • 2004-2010 — slow initial uptake; small number of applications + Opinions issued; primary focus on vaccines + treatments for diseases of major LMIC public-health concern.
  • 2010-2020 — gradual expansion of use including landmark Opinions for Mosquirix malaria vaccine (2015) + Ervebo Ebola vaccine (2019) + several HIV / tuberculosis treatments; growing recognition of the procedure's value for WHO Prequalification + LMIC NRA reliance.
  • 2020 — formal rebranding to EU-M4all (EU Medicines for all) by EMA + publication of updated Guideline EMA/CHMP/SAWP/89537/2020; expanded scope to include treatments for non-communicable diseases + paediatric formulations + improved procedural framework.
  • 2020-2021 — extensive use during the COVID-19 pandemic including EU-M4all support for Comirnaty + several COVID-19 vaccines for COVAX + LMIC distribution; demonstrating the procedure's value during global public-health emergencies.
  • 2022-present — continued use + progressive adoption by additional manufacturers; growing WHO + EMA + EC support for fee reduction or waiver for high-impact LMIC products; integration with WHO Collaborative Registration Procedure (CRP) for streamlined LMIC NRA assessment.
  • The Article 58 / EU-M4all terminology change reflects broader EMA strategic positioning of the procedure as a substantive contribution to global health + LMIC access rather than a narrow technical procedure.
  • Procedural distinctions — pre-2020 Article 58 procedure had several procedural ambiguities + limitations that the 2020 EU-M4all Guideline substantially clarified including post-Opinion lifecycle, WHO + NRA cooperation mechanics + extension to non-communicable diseases.
  • Future evolution — ongoing discussions on further integration with WHO Listed Authority (WLA) framework + on potential expansion of EU-M4all to support additional therapeutic areas + on fee structure reform for LMIC-impact products.

03EU-M4all procedure mechanics + CHMP assessment

EU-M4all uses substantively the same procedural framework as the EU centralised procedure for marketing-authorisation applications, with key differences reflecting the procedure's non-EU-market focus + WHO + NRA cooperation requirements.

  • Pre-submission scientific advice — applicants are strongly encouraged to engage in EMA Scientific Advice or Protocol Assistance with the EU-M4all option flagged from the outset; WHO + recipient-country NRAs may also participate in scientific advice meetings.
  • Letter of Intent + Eligibility Confirmation — applicants submit a Letter of Intent to EMA specifying the EU-M4all procedure + the intended LMIC markets + WHO PQ alignment; EMA confirms eligibility based on Article 58 + EU-M4all Guideline criteria.
  • Application submission — applicants submit the EU-M4all application via the same EMA submission portals as the centralised procedure with EU-M4all-specific Module 1 elements including LMIC-market identification + WHO PQ alignment statement.
  • CHMP Rapporteur + Co-Rapporteur assignment — EMA assigns a Rapporteur + Co-Rapporteur from CHMP membership (national EU regulator experts); same model as EU centralised procedure.
  • Day 120 + Day 180 + Day 210 clock — substantively the same 210-day CHMP assessment clock as the centralised procedure including applicant-response stops; some flexibility for EU-M4all reflecting the procedure's collaborative nature.
  • EU GMP / GCP / GLP inspections — EU-M4all applications are subject to the same EU GMP / GCP / GLP inspection framework as the centralised procedure; inspections conducted by EU national inspectorates with EMA coordination.
  • WHO + NRA observer participation — WHO + recipient-country NRAs may participate as observers in CHMP discussions + may provide their own scientific perspectives + concerns; substantial collaborative element distinguishing EU-M4all from pure EU centralised procedure.
  • CHMP Scientific Opinion — final CHMP Scientific Opinion published + transmitted to WHO + recipient-country NRAs; the Opinion includes summary product characteristics-equivalent information, assessment report + commitments.
  • Post-Opinion lifecycle — variations, line extensions, periodic safety update reports + post-Opinion commitments all follow procedurally similar processes to EU centralised procedure with continued WHO + NRA involvement.
  • EMA Public Assessment Report (EPAR) equivalent — EU-M4all Opinions are published with an EPAR-equivalent assessment report providing transparency + supporting LMIC NRA reliance.

04EU-M4all + WHO Prequalification integration

EU-M4all's value proposition is substantially enhanced by its tight integration with WHO Prequalification (WHO PQ) — the WHO programme that assesses medicines, vaccines, IVDs + vector-control products for UN procurement + LMIC use. EU-M4all-supported products typically receive WHO PQ via streamlined assessment leveraging the CHMP Scientific Opinion.

  • WHO PQ submission — once a product has received a CHMP Scientific Opinion under EU-M4all, the manufacturer can submit to WHO PQ with the Opinion + EPAR-equivalent assessment report as the primary basis.
  • WHO PQ streamlined assessment — WHO PQ typically conducts a streamlined assessment of EU-M4all-supported products leveraging the CHMP Scientific Opinion + EU GMP inspections; substantial reduction in WHO PQ assessment timeline + effort.
  • WHO PQ + EU-M4all collaboration — formal collaboration agreements between EMA + WHO PQ enable joint scientific discussions + reliance on each other's assessments + inspection findings; WHO + EMA staff may participate in each other's processes.
  • WHO Collaborative Registration Procedure (CRP) — once a product has received both CHMP Scientific Opinion under EU-M4all + WHO PQ listing, LMIC NRAs participating in the WHO CRP can leverage the WHO PQ assessment to issue national marketing authorisations with substantially reduced national assessment.
  • Tri-level reliance — EU-M4all → WHO PQ → LMIC NRAs via CRP provides a three-step reliance cascade that has substantially accelerated LMIC access to high-quality medicines + vaccines.
  • Examples — Mosquirix (malaria vaccine, WHO recommendation 2021), Ervebo (Ebola vaccine, WHO PQ 2019 + LMIC NRA registrations), Comirnaty for LMIC use (COVID-19 vaccine, COVAX distribution) all benefited from the EU-M4all → WHO PQ → CRP cascade.
  • Limitations — not all EU-M4all-supported products are submitted to WHO PQ; not all WHO PQ-listed products use EU-M4all (many use WHO PQ direct assessment); the cascade is most valuable for high-impact LMIC products where multiple reliance steps are needed.
  • WHO Listed Authority (WLA) framework — EMA is a WHO Listed Authority + the WLA framework is progressively replacing the older 'Stringent Regulatory Authority (SRA)' framework; EU-M4all + WLA together provide a comprehensive global reliance architecture.

05EU-M4all use cases + landmark Opinions

  • Mosquirix (RTS,S/AS01, GSK, CHMP Scientific Opinion 2015) — the first WHO-recommended malaria vaccine for children + the first EU-M4all-supported vaccine for sub-Saharan Africa use; subsequently WHO PQ + WHO Recommendation for pilot implementation + 2021 broader WHO recommendation.
  • Ervebo (rVSV-ZEBOV, Merck, CHMP Scientific Opinion 2019) — Ebola vaccine used in 2014-2016 West African outbreak + subsequent 2018-2020 Democratic Republic of Congo outbreak + 2022 Uganda outbreak; WHO PQ 2019 + multiple African NRA registrations via CRP.
  • Comirnaty for LMIC use (Pfizer-BioNTech, CHMP Scientific Opinion 2021) — COVID-19 vaccine with EU-M4all support for COVAX + LMIC distribution; substantial use during 2021-2022 pandemic response.
  • Tafenoquine (Kozenis / Krintafel, GSK, CHMP Scientific Opinion 2018) — single-dose treatment for Plasmodium vivax malaria relapse prevention; WHO PQ + LMIC NRA registrations supporting global malaria elimination.
  • Several HIV antiretroviral combinations + paediatric formulations — EU-M4all has supported several fixed-dose combinations + paediatric formulations of antiretrovirals critical for HIV programmes in sub-Saharan Africa.
  • Tuberculosis treatments — EU-M4all has supported several new TB drug regimens including for multidrug-resistant TB; complementing WHO PQ + Global Fund + Stop TB Partnership procurement.
  • Sleeping sickness (Human African Trypanosomiasis) treatments — EU-M4all has supported new HAT treatments including fexinidazole + acoziborole (oxaborole class), substantially improving HAT treatment access.
  • Visceral leishmaniasis treatments — EU-M4all has supported several treatments for visceral leishmaniasis (kala-azar), a neglected tropical disease primarily affecting LMIC populations.
  • Pediatric formulations + non-communicable diseases — post-2020 EU-M4all expansion has supported paediatric formulations + non-communicable disease treatments for LMIC markets.
  • Vaccines for future epidemic + pandemic preparedness — ongoing EU-M4all discussions for vaccines for Lassa fever, Nipah, MERS-CoV + other epidemic-prone diseases as part of WHO R&D Blueprint + CEPI portfolio.

06EU-M4all advantages + limitations

EU-M4all provides substantial advantages for manufacturers + WHO + recipient-country NRAs + ultimately LMIC patients — but also has limitations that should be understood when planning regulatory strategy.

  • Advantage — EMA scientific assessment credibility: EMA is one of the world's most respected regulators + a WHO Listed Authority; CHMP Scientific Opinion under EU-M4all carries substantial credibility supporting WHO PQ + LMIC NRA reliance.
  • Advantage — alignment with EU centralised procedure standards: substantive alignment with EU centralised procedure scientific standards + GMP / GCP / GLP inspections provides consistency + minimises duplicate assessment effort.
  • Advantage — WHO + LMIC NRA cooperation: formal cooperation mechanisms with WHO + recipient-country NRAs ensures the Opinion is responsive to LMIC needs + supports downstream reliance.
  • Advantage — three-step reliance cascade: EU-M4all → WHO PQ → CRP cascade substantially accelerates LMIC access compared to separate national assessments.
  • Advantage — paediatric + non-communicable disease scope expansion: post-2020 scope expansion makes EU-M4all relevant for a broader range of LMIC public-health priorities.
  • Limitation — exclusively non-EU market constraint: products that may eventually be marketed in EU should use centralised procedure; this can create strategic constraints for products with potential dual-use.
  • Limitation — substantial fees + resources: EU-M4all fees + assessment effort are substantially similar to centralised procedure; can be prohibitive for low-margin LMIC products without external funding (CEPI, BMGF, etc.).
  • Limitation — limited LMIC NRA capacity: full benefit of the reliance cascade requires LMIC NRAs with sufficient capacity to engage with CRP + reliance; smaller NRAs may still require substantial direct support.
  • Limitation — not all products fit: EU-M4all is most valuable for products with substantial LMIC public-health impact + WHO PQ alignment; products targeting smaller LMIC markets or specific bilateral arrangements may benefit more from alternative reliance pathways.
  • Limitation — post-Opinion lifecycle complexity: post-Opinion variations + commitments require continued EMA + WHO + NRA engagement which can be operationally complex for manufacturers.
  • Limitation — no EU market authorisation: EU-M4all Opinion does not authorise EU placement; manufacturers seeking EU access must separately file centralised procedure or national MAs.

07How V5 Ultimate supports EU-M4all readiness

V5 Ultimate provides the operational infrastructure manufacturers need for EU-M4all preparation + ongoing EU-M4all lifecycle compliance — particularly for vaccines, biologics + sterile products where EU GMP Annex 1 + ICH Q-series compliance are critical.

  • EU GMP control framework — full EU GMP including EU GMP Annex 1 (2022 revision) sterile manufacturing compliance, computerised systems compliance per Annex 11 + ICH Q10 PQS implementation; ALCOA+ data-integrity expectations aligned with PIC/S PI 041.
  • EMA submission packaging — full EU-CTD eCTD submission packaging with EU-M4all-specific Module 1 elements including LMIC-market identification, WHO PQ alignment statement + recipient-country NRA cooperation arrangements.
  • CHMP Rapporteur + Co-Rapporteur engagement workflow — pre-submission Scientific Advice / Protocol Assistance engagement, Day 120 / Day 180 / Day 210 response management, CHMP question + applicant-response tracking.
  • EU GMP + GCP + GLP inspection readiness — EU GMP inspection preparation including Annex 1 sterile + Annex 13 IMP requirements, EU GCP inspection preparation for clinical trials supporting EU-M4all applications, EU GLP inspection preparation for preclinical studies.
  • WHO PQ + CRP integration workflow — CHMP Scientific Opinion + EPAR-equivalent assessment report packaging for WHO PQ submission, WHO PQ + LMIC NRA CRP coordination, three-step reliance cascade tracking.
  • EU-M4all variation + post-Opinion lifecycle — Type IA / IB / II variation packaging following EU centralised procedure framework with WHO + NRA notification + cooperation.
  • PSUR + safety reporting — EU-aligned PSUR cycle, ICH E2B(R3) ICSR generation, 15-day SUSAR timeline, EU + WHO + LMIC NRA safety information sharing.
  • Multi-LMIC NRA engagement — for products targeting multiple LMIC markets via CRP, V5 surfaces NRA-specific Module 1 customisation + country-specific labelling + pharmacovigilance commitments alongside EU-M4all core dossier.
  • Vaccine + biological lot release — EU OMCL (Official Medicines Control Laboratory) lot release coordination for vaccines + biologics under EU-M4all; alignment with WHO PQ NIB (National Institute for Biological Standards and Control)-equivalent lot release.
  • CEPI / BMGF / Global Fund / Gavi alignment — for products developed with CEPI, BMGF, Global Fund or Gavi support, V5 surfaces funder-specific reporting + milestone tracking alongside EU-M4all + WHO PQ submissions.
  • Cold chain + LMIC distribution — for vaccines + biologics requiring cold chain (2-8°C, -20°C or ultra-cold), V5 surfaces cold-chain qualification + LMIC distribution planning workflow including COVAX-equivalent logistics.
  • Pediatric + paediatric-friendly formulation — post-2020 EU-M4all scope expansion supports paediatric formulations; V5 surfaces paediatric clinical development + EU PIP-equivalent planning workflow.

Frequently asked questions

Q.What's the difference between Article 58 procedure + EU-M4all?+

Article 58 procedure was the original name for the EMA scientific-opinion procedure under Article 58 of Regulation (EC) No 726/2004, established 2004 for medicines intended exclusively for non-EU markets. In 2020, EMA formally rebranded the procedure as EU-M4all (EU Medicines for all) + published an updated Guideline (EMA/CHMP/SAWP/89537/2020) with expanded scope (including non-communicable diseases + paediatric formulations) + improved procedural framework. The legal basis remains Article 58 of Regulation 726/2004 but the operational name is now EU-M4all. The two terms are sometimes still used interchangeably + older documents reference 'Article 58 procedure' while current EMA documents use 'EU-M4all'.

Q.Is an EU-M4all Scientific Opinion a marketing authorisation?+

No — an EU-M4all CHMP Scientific Opinion is NOT a marketing authorisation. EU-M4all is explicitly for products intended exclusively for markets outside the European Union; the Opinion does not authorise placement on the EU market. Instead, the Opinion supports WHO Prequalification + recipient-country NRA decision-making for non-EU markets. Manufacturers seeking EU market access must separately file a standard EU centralised procedure marketing-authorisation application or national MAs. The Opinion is, however, a substantive scientific assessment using the same standards as EU centralised procedure + carries substantial credibility for WHO + LMIC NRA reliance.

Q.Who can apply for EU-M4all?+

EU-M4all applications can be filed by EU-established manufacturers OR by non-EU-established manufacturers (provided they meet specific procedural + GMP requirements). The applicant must demonstrate that the product is intended exclusively for non-EU markets + must have WHO + recipient-country NRA cooperation arrangements in place. Eligible products include vaccines, biologics, small molecules, paediatric formulations + treatments for diseases of major LMIC public-health interest. The post-2020 EU-M4all Guideline expanded scope to include non-communicable diseases + paediatric formulations alongside the original focus on communicable diseases + vaccines.

Q.How does EU-M4all relate to WHO Prequalification?+

EU-M4all is closely integrated with WHO Prequalification (WHO PQ) — products that receive a CHMP Scientific Opinion under EU-M4all can typically receive WHO PQ via streamlined assessment leveraging the Opinion + EPAR-equivalent assessment report. Formal collaboration agreements between EMA + WHO PQ enable joint scientific discussions + reliance on each other's assessments + inspection findings. Once a product has both an EU-M4all Opinion + WHO PQ listing, LMIC NRAs participating in the WHO Collaborative Registration Procedure (CRP) can leverage the WHO PQ assessment to issue national marketing authorisations with substantially reduced national assessment effort — creating a three-step reliance cascade (EU-M4all → WHO PQ → CRP) that substantially accelerates LMIC access.

Q.What products have been approved via EU-M4all?+

Landmark EU-M4all Opinions include: Mosquirix (RTS,S/AS01, GSK, 2015) — the first WHO-recommended malaria vaccine for children; Ervebo (rVSV-ZEBOV, Merck, 2019) — Ebola vaccine used in West + Central African outbreaks; Comirnaty for LMIC use (Pfizer-BioNTech, 2021) — COVID-19 vaccine with EU-M4all support for COVAX + LMIC distribution; tafenoquine (Kozenis/Krintafel, GSK, 2018) — single-dose treatment for Plasmodium vivax malaria relapse prevention; several HIV antiretroviral combinations + paediatric formulations; tuberculosis treatments including for multidrug-resistant TB; sleeping sickness treatments including fexinidazole + acoziborole; visceral leishmaniasis treatments. EU-M4all has been particularly valuable for vaccines + treatments for diseases of major LMIC public-health impact.

Q.How long does an EU-M4all procedure take?+

EU-M4all uses substantively the same 210-day CHMP assessment clock as the EU centralised procedure, including applicant-response stops. Total elapsed time from pre-submission Scientific Advice to final CHMP Scientific Opinion is typically 18-24 months including: pre-submission Scientific Advice / Protocol Assistance (6-12 months), application preparation + submission (variable), 210-day CHMP assessment (10-14 months elapsed including applicant-response stops), CHMP Opinion adoption + publication (1-2 months). Subsequent WHO PQ submission + assessment typically adds 6-12 months. Individual LMIC NRA registrations via CRP typically take 2-6 months following WHO PQ listing. Total cascade time from EU-M4all start to LMIC market authorisation typically 30-48 months.

Q.Why use EU-M4all instead of direct WHO PQ submission?+

Direct WHO PQ submission (without EU-M4all) is the standard pathway for many WHO PQ-listed products + works well for established products + manufacturers with strong WHO PQ relationships. EU-M4all adds value when: (1) the product requires substantial scientific assessment beyond WHO PQ scope (e.g., novel vaccines, complex biologics, new chemical entities), (2) the manufacturer + WHO benefit from EMA's specific scientific expertise + Rapporteur + Co-Rapporteur model, (3) the product targets multiple LMIC NRAs via CRP where the EU-M4all + WHO PQ cascade provides stronger reliance support, (4) the product has substantial development costs + CEPI / BMGF / Global Fund / Gavi support where EU-M4all credibility is valuable for funder reporting + ongoing engagement. For products that fit EU-M4all criteria, the procedure typically results in higher-quality assessment + stronger LMIC reliance support than direct WHO PQ alone.

Primary sources

Further reading

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