1What each system is for.
A laboratory information management system (LIMS) is organised around the sample. It registers what arrived, assigns the tests, methods and specification that apply, records each result and sends it for review. An electronic laboratory notebook (ELN) is organised around the experiment. It takes the place of the bound paper notebook: the scientist records the aim, the procedure followed, observations, calculations and conclusions as the work is done.
Neither term is defined in the GMP or GLP regulations, which set requirements for records and controls rather than for kinds of software. FDA’s data integrity guidance names a LIMS as a system that “can be designed to automatically save after each entry”, and lists “electronic worksheets, laboratory notebooks, and MPCRs” among the blank forms the quality unit or another document control method should control.¹ The EU GMP guide expects quality control procedures to cover records “including test worksheets and/or laboratory notebooks”, and says raw data such as laboratory notebooks should be “retained and readily available” in addition to the batch documentation.²
2How the two compare.
| LIMS | ELN | |
|---|---|---|
| Organised around | The sample, its tests and its specification | The experiment and its protocol |
| Typical work | Release, stability, incoming-material and environmental testing | Research, process development and method development |
| GMP record | The laboratory record of each test, under 21 CFR 211.194 and EU GMP 6.17 | Notebooks and worksheets, kept as raw data under EU GMP 6.10 |
| GLP record | Results within a study’s raw data | Worksheets, notes and records, which 21 CFR 58.3(k) defines as raw data |
| What it produces | A result against an assigned limit, for review and disposition | The record of an experiment and its conclusions |
The record rows carry the legal weight. A QC test record must contain what 21 CFR 211.194(a) lists: a description of the sample with its source, quantity, lot and dates; each method used; the weight or measure of sample; “a complete record of all data secured in the course of each test, including all graphs, charts, and spectra from laboratory instrumentation”; every calculation; the result compared with its standard; and the initials or signature of the analyst and of a second person who reviewed the original records.³ EU GMP section 6.17 asks for much the same and adds a clear statement of approval or rejection and a reference to the equipment used.²
For a nonclinical laboratory study, FDA’s GLP regulations define raw data as “any laboratory worksheets, records, memoranda, notes, or exact copies thereof” that result from original observations and are needed to reconstruct the study. Each entry is dated and signed or initialled by the person making it, and a change must not obscure the original entry and must give its reason.⁴
3The same rules apply to both.
Under 21 CFR 211.68(b), changes to records held in a computer system may be made only by authorised personnel, input and output must be checked for accuracy, and backup data must be exact, complete and secure from alteration or loss.⁵ When a record that a predicate rule requires is kept electronically in place of paper, or relied on in electronic form, Part 11 applies.⁶ The system must then be validated, limit access to authorised individuals and keep secure, computer-generated, time-stamped audit trails that do not obscure what was recorded before.⁷ In the EU, Annex 11 applies to “all forms of computerised systems used as part of a GMP regulated activities”.⁸
Validation is for the intended use, not for the product in general. FDA expects each CGMP workflow on a computer system to be validated.¹ The MHRA says accepting vendor-supplied validation data “in isolation of system configuration and users intended use is not acceptable”, and that data transfer should be validated, with an audit trail, so that data are not altered during or after transfer to a worksheet or other application.⁹ Neither system replaces an instrument’s original electronic record: FDA says a printout of a dynamic record, such as an FT-IR spectral file that can be reprocessed, does not satisfy the requirement to keep original records or true copies.¹ The MHRA says moving between paper and computerised systems “will not in itself remove the need for appropriate data integrity controls”, and that a validated system may lower but not eliminate data integrity risk.⁹
4Where GMP begins, and where each fits.
The EU GMP guide says GMP applies from the manufacture of investigational medicinal products, through technology transfer and commercial manufacturing, to product discontinuation. The pharmaceutical quality system can extend to development as ICH Q10 describes, which the guide calls optional.¹⁰ ICH Q10 itself says its content beyond regional GMP requirements is optional.¹¹ An ELN used for discovery research can therefore sit outside GMP, while nonclinical laboratory studies that support an application to FDA fall under Part 58.⁴
Data comes under GMP when it is used for a GMP purpose. FDA’s position is that “when generated to satisfy a CGMP requirement, all data become a CGMP record”.¹ A method developed in an ELN does not become a QC method by being copied into a LIMS: 211.194(a)(2) requires the suitability of every testing method to be “verified under actual conditions of use”,³ and EU GMP says a laboratory that did not perform the original validation should verify that the method is appropriate.²
5Choosing one, the other or both.
Start from the records. If the work is testing samples against specifications to release materials and products or to report stability timepoints, the records are the ones 211.194 and EU GMP Chapter 6 describe, and a LIMS is built around them. If the work is a series of experiments whose design changes from run to run, the record is a notebook, and an ELN is built around that. A laboratory that does both kinds of work may need both.
When they are separate systems, decide which one holds each record. EU GMP Chapter 4 says the relationships and control measures for master documents, official copies, data handling and records need to be stated for hybrid and homogeneous systems alike, and that it should be clear which record relates to each manufacturing activity and where it is kept.¹² Data exchanged between systems should pass built-in checks for correct and secure entry and processing, and validation of a migration should include checks that data are not altered in value or meaning.⁸ The MHRA warns that “the challenges of migrating data are often underestimated”.⁹
6How it runs in Seal.
In Seal the ELN and LIMS share one platform and its sample, material and method records. Scientists develop a method in the ELN, and the approved version comes into QC with its parameters, calculations, system-suitability checks and review requirements, keeping the development evidence that explains those choices. Each QC result keeps its sample, method and specification versions and its instrument file, laboratory review feeds batch disposition, and earlier runs keep the version they used.
You can start with one release test beside the LIMS you already run: Seal reads samples and results from LabWare, LabVantage and SampleManager without writing to them. The LIMS comparison sets out what to check when choosing.
References
- 1Data Integrity and Compliance With Drug CGMP: Questions and Answers, Guidance for Industry, FDA, December 2018, questions 3, 6, 10 and 12. https:/
/ www. fda. gov/ media/ 119267/ download (read 6 November 2026) - 2EudraLex Volume 4, Chapter 6: Quality Control, European Commission, in operation from 1 October 2014, sections 6.7, 6.10, 6.15 and 6.17. https:/
/ health. ec. europa. eu/ system/ files/ 2016- 11/ 2014- 11_ vol4_ chapter_ 6_ 0. pdf (read 6 November 2026) - 321 CFR 211.194, Laboratory records, eCFR. https:/
/ www. ecfr. gov/ current/ title- 21/ section- 211. 194 (read 6 November 2026) - 421 CFR Part 58, Good Laboratory Practice for Nonclinical Laboratory Studies, sections 58.1, 58.3(k) and 58.130(e), eCFR. https:/
/ www. ecfr. gov/ current/ title- 21/ chapter- I/ subchapter- A/ part- 58 (read 6 November 2026) - 521 CFR 211.68, Automatic, mechanical, and electronic equipment, eCFR. https:/
/ www. ecfr. gov/ current/ title- 21/ section- 211. 68 (read 6 November 2026) - 6Guidance for Industry: Part 11, Electronic Records; Electronic Signatures, Scope and Application, FDA, August 2003, section III.B. https:/
/ www. fda. gov/ media/ 75414/ download (read 6 November 2026) - 721 CFR 11.10, Controls for closed systems, eCFR. https:/
/ www. ecfr. gov/ current/ title- 21/ section- 11. 10 (read 6 November 2026) - 8EudraLex Volume 4, Annex 11: Computerised Systems, European Commission, in operation from 30 June 2011, principle and sections 4.8 and 5. https:/
/ health. ec. europa. eu/ system/ files/ 2016- 11/ annex11_ 01- 2011_ en_ 0. pdf (read 6 November 2026) - 9‘GXP’ Data Integrity Guidance and Definitions, Revision 1, MHRA, March 2018, sections 3.7, 4.5, 6.8 and 6.19. https:/
/ assets. publishing. service. gov. uk/ media/ 5aa2b9ede5274a3e391e37f3/ MHRA_ GxP_ data_ integrity_ guide_ March_ edited_ Final. pdf (read 6 November 2026) - 10EudraLex Volume 4, Chapter 1: Pharmaceutical Quality System, European Commission, in operation from 31 January 2013, section 1.2. https:/
/ health. ec. europa. eu/ system/ files/ 2016- 11/ vol4- chap1_ 2013- 01_ en_ 0. pdf (read 6 November 2026) - 11ICH Q10, Pharmaceutical Quality System, ICH, Step 4, 4 June 2008, section 1.1. https:/
/ database. ich. org/ sites/ default/ files/ Q10%20Guideline. pdf (read 6 November 2026) - 12EudraLex Volume 4, Chapter 4: Documentation, European Commission, in operation from 30 June 2011, sections 4.1 and 4.10. https:/
/ health. ec. europa. eu/ system/ files/ 2016- 11/ chapter4_ 01- 2011_ en_ 0. pdf (read 6 November 2026)
AQuestions and answers
Do you need both a LIMS and an ELN?
Not always. A QC laboratory testing materials and products against specifications needs the structured test records a LIMS is built for, while a development laboratory needs notebook records of experiments. Many companies run both. If you do, decide which system holds each record and validate the transfer of data between them.
Can an ELN be used in a GMP QC laboratory?
Yes, if it is validated for that use and its records contain what GMP requires of a laboratory record: the sample, the method, complete data, calculations, the result against its specification, and the analyst’s and a second person’s review. The question to test is whether its workflows enforce those contents or leave them to free text.
Is an ELN subject to 21 CFR Part 11?
When it holds records that FDA regulations require, such as CGMP laboratory records or GLP raw data, and those records are kept or relied on electronically, Part 11 applies. Notebook entries that no predicate rule requires are outside Part 11. FDA’s view is that data generated to satisfy a CGMP requirement become a CGMP record, so an entry made for a GMP purpose is in scope.
Where should an instrument’s raw data be kept?
With the original electronic record and its metadata, in whichever system holds it. FDA does not accept a printout of a reprocessable record, such as a chromatogram or FT-IR spectrum, as a true copy. A result in the LIMS or ELN should point to that original rather than stand in for it.
Does moving from paper notebooks to an ELN remove data integrity risk?
No. The MHRA says moving between paper and computerised systems does not in itself remove the need for data integrity controls, and that a validated system may lower but not eliminate the risk. The access rights, audit trails, review and training around the system still matter.
