Regulatory PathRegulatory requirements compared

SFDA item 91 · IV. PMF/VAMF

Change in the steps that would be taken if it is found retrospectively that donation(s) should have been excluded from processing (“look-back” procedure).

Variation category under SFDA, EU and US FDA rules for this change, with the variant wording as published.

Open in the Variation Compass

SFDA Saudi Food and Drug Authority

Guidelines for Variation Requirements v6.3 (DS-G-006), item 91 — official PDF, p. 78 ↗

VariantChangeType
-Change in the steps that would be taken if it is found retrospectively that donation(s) should have been excluded from processing (“look-back” procedure).Type II

EU European Union

Commission Guidelines C/2025/5045 — EUR-Lex ↗

M.16 · Change in the steps that would be taken if it is found retrospectively that donation(s) should have been excluded from processing (‘look-back’ procedure)

VariantChangeType
-Change in the steps that would be taken if it is found retrospectively that donation(s) should have been excluded from processing (‘look-back’ procedure)Type II

US FDA US Food and Drug Administration

21 CFR 314.70 and FDA guidance — Outside 21 CFR 314.70 — 21 CFR 610.46–610.47

ChangeCategoryReference
Look-back is a codified blood-establishment duty, not a filed procedureNo US equivalent

Note: US look-back duties are codified for blood establishments (21 CFR 610.46–610.47) and handled under their CBER licenses; there is no PMF to vary.

Other items in IV. PMF/VAMF

Not regulatory advice. The binding text is each regulator's current official document; confirm the category with the authority before filing. FDA publishes no classification table: the US category follows FDA guidance or, where the guidance does not name the change, the closest example under 21 CFR 314.70.